Tuesday, July 5th, 2011

The Urgency of Reforming the Federal Railroad Administration by Alon Levy

[ If you’ve spent any time around urbanist blogs, you’ve no doubt come across Alon Levy, one of the most prolific commenters around. Now that he’s a newly minted PhD – congrats! – he’s back to writing his own blog, Pedestrian Observations, which is a must for the serious urbanist. Levy brings encyclopedic knowledge, insight, and his own strong point of view to create some really provocative and informative posts. His tag line of “For Walkability and Good Transit, and Against Boondoggles and Pollution” basically sums it up, especially when you get that he’s as opposed to transit boondoggles as highway ones.

One of my pet peeves has always been how even high speed rail advocates have no interest in implementing the regulatory and managerial reforms necessary to make HSR work. Chief among these is fixing the broken regulatory approach of the FRA. Here is a post that is composed of a couple of Levy’s woven together that illustrates this problem. Thanks to him for letting me run them. – Aaron. ]

House Transportation Committee Chair John Mica (R-FL) has finally come out explicitly in favor of privatizing the Northeast Corridor and letting private consortia bid for high-speed rail construction. Mica’s rationale is that Amtrak is an inefficient government provider, and its proposal for spending $117 billion over 30 years to build high-speed rail in the Northeast is deficient.

Not mentioned anywhere in the article is the FRA, which is the real obstacle to modern rail operations. Mica has to my knowledge said nothing about the FRA, which is too bad, since it could feed into the Republican narrative of bad government and the need for privatization and deregulation.

Under present FRA regulations, not much more than NEC service levels can be done: rolling stock would have to meet guidelines developed for the steam era, curve speeds would be limited, and the signaling would not provide enough capacity for adequate service levels on shared track. This is independent of the incompetence of every FRA-compliant railroad; in fact part of the incompetence is manifested in unwillingness to try to get waivers, even though Caltrain, a small operator, applied for a partial waiver and got it.

On the other hand, under modern regulations, even Amtrak could provide somewhat better results, and an Amtrak that Mica and the Obama administration pressured to reform could provide much better results. Although such reforms would include less staffing per amount of service provided, ridership could increase so much that total employment would increase, making this at least in principle fathomable by the bureaucrats. If top management wants to make it happen, it will happen.

In contrast, no reform of the FRA is possible short of a complete overhaul. The appropriate passenger rail regulation in the US is that everything that’s legal in Japan or Europe is legal in the US, and the only local task should be a skeletal staff reconciling European and Japanese rules where necessary. A piecemeal approach leads to partial and suboptimal reforms, requiring additional testing of already extensively used trains. For example, in Europe, tilting trains can have up to 270-300mm of cant deficiency, but the FRA won’t permit more than 229 (9″).

JNR’s problems in the 1980s involved overstaffing and operation of marginal lines; these are the things privatization could fix. This is not true of bad regulations, which remain no matter what. Private vendors could lobby for a fix, but they have other interests in mind than maximum efficiency – for example, making life harder for competitors – and besides, what’s the point of hoping for private lobbyists to do a task that as chair of the relevant committee you can do yourself? At the end, a government that’s too incompetent to do things by itself is probably too incompetent to be trusted to ensure the private sector will provide better service rather than looting the taxpayer.

To give more specifics of regulatory problems, I’m hoisting a comment I wrote on the Infrastructurist detailing some of the FRA regulations that are the most destructive.

The original references for this are from Zierke’s website and the East Bay Bicycle Coalition, but those are a few years out of date, and recently the FRA has made noises about reforming the first two rules, which are the most destructive to intercity rail. Unfortunately, those reforms are not good enough, chiefly because they are designed to preserve the FRA’s bureaucracy, piling more obstacles on any attempt to modernize US trains.

1. 945 tons buff strength for locomotives and end cars and 360 for coaches (link); the maximum that’s even partly defensible is Europe’s 200, and Japan’s 100 is perfectly safe. This is by far the most important: as a result of this rule, the Acela power cars weigh 90 metric tons, vs. 68 for the TGV power cars they’re derived from. Zierke notes that the lighter the train, the higher the FRA weight penalty is.

2. 4″ maximum cant deficiency for non-tilting trains, except 5″ on track connected to 110+ mph rail (derisively called the magic HSR waiver by railfans). The Acela is limited to 7″ despite tilting. Non-tilting TGVs do 180 mm in France (about the same as the Acela) and tilting trains do 250-300 mm in Japan and a bunch of European countries, no special testing required except on actual track. In addition, superelevation is limited by regulation to 7″ minus a safety margin; high-speed lines around the world have 180 mm actual superelevation, and the Tokaido Shinkansen, which has tighter curves, has 200 mm.

Those two regulations are already being somewhat modified. Amtrak seems to believe that the nationwide mandate for positive train control (PTC), passed in 2008 in response to the Chatsworth crash, will allow it to run lighter trains; the FRA has granted Caltrain a waiver from the FRA buff strength rule provisioned upon PTC installation. As for cant deficiency, the FRA has already decided on a revision allowing tilting trains up to 225 mm cant deficiency, and non-tilting trains up to 150 mm by testing.

Unfortunately, those two reforms only look good at first glance. The Caltrain waiver application from the buff strength rule was devised in consultation with the biggest rolling stock manufacturers – Bombardier, Kawasaki, Alstom, and Siemens – which indicates which rules they could comply with and which they could not. This may well lock out smaller vendors, such as Stadler and CAF. Stadler’s FLIRT is the fastest-accelerating, highest-powered regional train on the market; it is also very light, and may well not comply even with regulations Caltrain did not ask out of.

In addition, since such waivers depend on PTC, if the freight railroads succeed in their attempt to delay or water down PTC implementation, which they consider too expensive, then future rolling stock purchases will remain heavy. Indeed, Amtrak’s purchase of new electric locomotives, due to enter service in 2013, is FRA-compliant and more expensive than purchases of similar locomotives in Europe; this despite the fact that they are intended to run on the Northeast Corridor, which has a PTC system.

As for the cant deficiency waiver, it was obtained by testing existing outdated technology in the US, such as Amtrak locomotives and the EMUs used on commuter rail in the Northeast. No attempt was made to use high-cant deficiency European technology, a point also made by Drunk Engineer. Such trains would have to be tested to the FRA’s satisfaction, and not be allowed to run at the same speeds as they do in Europe. In fact the FRA’s proposed rule revision includes a language about higher track standards for cant deficiency higher than 5″, never mind that TGVs run on less than perfect legacy track at 7″ cant deficiency.

In addition, for high-cant deficiency operation, it’s important to regulate both cant deficiency and the rate at which it changes. The muscles can adjust to lateral acceleration, given enough time; thus the jerk, or the rate of change of acceleration, must also be prescribed. With a proper superelevation ramp and change in cant deficiency based on the abilities of existing trains, high speeds and high cant deficiencies can combine well, as found in a Swedish study about the feasibility of very high-speed trains on legacy track.

Additional FRA regulations, which hamper regional rail more than intercity rail, seem to be here to stay. These include the following:

3. Two employees per train; regional trains should have one. But, bear in mind, many regional operators have multiple conductors, and the limit to lower staffing is antiquated trains or managerial incompetence rather than the FRA. For example, the MBTA believes it needs one conductor per two cars.

4. Brake tests at every turnaround. Intercity trains can enter a stub-end station and back away in 3-4 minutes, and do every day in Germany; regional trains turn around in 3-4 minutes in Japan. However, Amtrak makes Keystone trains dwell 10 minutes at Philadelphia.

5. Four-quadrant gates required for quiet zones; these make quiet zones expensive, and as a result trains have to blare loud horns at grade crossings, alienating neighbors and creating NIMBYism.

6. No regulations encouraging high-performance lightweight cars and good signaling. The FRA should mandate a modern system, preferably ETCS, which permits a throughput of up to 37 trains per hour at standard speeds. This is 12 tph more than currently can run between New Jersey and New York, and would be about $13 billion cheaper than Amtrak’s Gateway tunnel proposal, which would add 21 tph.

The multitude of bad regulations is why I think FRA reform has to be intensive, without any half-measures. The new rail regulations in the US should as much as possible be based on UIC (predominantly European) and Japanese regulations, with the present status quo ignored.

The only role of American regulators should be to devise a coherent system to allow European and Japanese trains to interact with each other. In some places, such as PTC and jerk, it requires greater regulation, based on best industry practices in the rest of the developed world. But in most other areas, the rule should as far as possible be that everything that’s legal in Europe or Japan is legal in the US.

I’ll repeat my exhortation in my post on Mica’s privatization plan: please contact the relevant Congressional representatives and let them know that any real reform must include extensive FRA reform. Organization and electronics should come before concrete, and such deregulation of rolling stock could jive well with the conservative mood in Congress that Mica is channeling. And if it does not, then never mind – the Democrats could seize FRA reform, too, as a good-government issue. It’s more important than whether future railroads are run publicly or privately.

This post originally appeared in modified form in Pedestrian Observation. Reprinted with permission.

6 Comments
Topics: Public Policy, Transportation

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6 Responses to “The Urgency of Reforming the Federal Railroad Administration by Alon Levy”

  1. david vartanoff says:

    In general Alon is spot on. The very sad Silver Spring MD Amtrak-MARC Feb 1996 head on typifies FRA. The wreck (11 dead) occurred because the MARC engineer behaved as if the last signal he had seen was clear whereas it should have been approach medium. Cab Signals–common on many high density rail lines over half a century ago–would have shown him the speed restriction with all lives saved. So, after NTSB finished their work FRA did NOT mandate ANY signal enhancement. Instead they upped the buff strength requirements. Chatsworth again was a case of disobeying the signal instructions apparently because of prohibited cell phone usage. Automatic Train Stop, also 50 year old technology would have put the train in emergency sooner perhaps lessening the damage. FRA still hasn’t demanded these safety enhancements.

  2. Alon Levy says:

    The FRA has demanded positive train control, which includes ATS as well as other things, namely speed control (accidents can be caused by overspeeding, e.g. Amagasaki) and temporary speed restrictions for work crews.

    Unfortunately, the FRA has said nothing about how modern train control should look like, and as a result commuter agencies are trying to reinvent the wheel and come up with one-of-a-kind train control (Caltrain), get their own steam-era systems grandfathered (LIRR, Metro-North), or come up with a freight-oriented systems (most other agencies).

  3. John Morris says:

    Wasn’t the original bankruptcy of the private passenger railroads very influenced by regulation?

    Anyway, I strongly agree with the general concept that if the regualtory schemes don’t change-the whole privately vs public owned issue is not too important.

    A lot of the rest of this goes over my head.

  4. david vartanoff says:

    regulation did not build the interstates or the gov’t owned airports.

  5. John Morris says:

    Google, Interstate Commerce Commission for starters.

  6. Andrew says:

    May I suggest that we start a change.org petition to help get this more traction? I would do it, but I don’t know enough about the regulations and appropriate people to send it to. But I think it would make a big difference.

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