Electronic Comment Filing System

Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Maritime Communications/Land Mobile LLC and Southern California Regional Rail Authority (?SCRAA?) Applications to Modify License and Assign Spectrum for (allegedly) Positive Train Control Use, and to Request Waivers of Part 80 Rules ) ) ) ) ) ) ) ) DA 10-556 WT Docket No. 10-83 File Nos. 0004153701, 0004144435 File No. 00023033551 Call Sign: WQGF318 To: Office of the Secretary Attn: Wireless Telecommunications Bureau Motion to Dismiss Motion for Conditional Grant2, or in the Alternative, Opposition to Motion for Conditional Grant ?Petitioners? hereby file this motion to dismiss (the ?D-Motion?) to the Maritime Communications/Land Mobile LLC (?MCLM?) motion for conditional grant (the ?Motion? or the ?MCLM Motion?) of the above-captioned applications (together the ?Applications?), one Application of which seeks to modify (the ?Modification?) the above-captioned license (the ?License?) and the other that seeks to partition and assign to Southern California Regional Rail Authority (?SCRRA?) (the ?Assignment?) part of the License, along with associated rule waiver requests (the ?Waivers?). Petitioners note here that SCRRA filed a similar motion of its own in the past and Petitioners have filed an initial opposition of it (the ?SCRRA Motion?). In the alternative, if the FCC accepts the MCLM Motion and does not dismiss it, then Petitioners submit under Section II below an opposition, in the alternative (the ?Opposition?) 1 Petitioners are including here the MCLM Auction No. 61 Form 601 for the reasons stated in Petitioners? opposition to the SCRRA motion for conditional grant and since the MCLM Form 601 for Auction No. 61 resulted in the subject License and many of the facts and arguments contained herein also relate to that MCLM Form 601. Any capitalized term not defined herein the meaning given in the Petition to Deny. Warren Havens (?Havens?), Environmentel LLC (?ENL?), Verde Systems LLC (?VSL?), Intelligent Transportation & Monitoring Wireless LLC (?ITL?), Telesaurus Holdings GB LLC (?THL?) and Skybridge Spectrum Foundation (?Skybridge?) (together, the ?Petitioners?). I. Motion to Dismiss For the reasons given in this section and also discussed in part in the section II below, the MCLM Motion is procedurally defective and not allowed by rule, and therefore, should be dismissed. - A - In sum, the Motion is defective and must be summarily dismissed since: (1) the Motion states a modification of the subject Assignment Application but it was not filed as required on Form 601 as a modification amendment, (2) motions for a interim grant of a license application are not specifically authorized in any rule, (3) a motion cannot be used to evade substantive requirements of rules, only for permitted procedure not in conflict with said substantive requirements, (4) the Motion effectively seeks waivers but was not filed as a waiver request and does not meet the standards for grant of waivers, (5) the Motion is in direct conflict with the only permitted actions by the FCC in this case for the subject assignment application subject to Petitioners petition to deny under rule section 1.945(d) and (e), (6) the Motion is in direct conflict with Section 309(d) of the Communications Act and the FCC has no authority to act contrary to this section, and (7) for other reasons given herein (including in the referenced and incorporated materials). While these reasons that the Motion is procedurally defective and must be dismissed are clear, we discuss some of them below, as well as in the referenced and incorporated materials. - B - The requested relieve is also spurious, since SCRAA has no radios to use for the quick deployment it asserts justifies grant of the extraordinary relief. See Exhibit 3: it is self explanatory for the most part. The other part is that Union Pacific, which is a major owner of PTC 220, and which together are partners with SCRAA in seeking the subject MCLM spectrum and in deploying the planned PTC (and other applications) system with it in the SCRAA area, is the entity that filed this experimental license shown in Exhibit 3. There are other clear statements in the railroad industry public domain information with the same content: that the PTC radios on 217-222 MHz are in development, and not yet completed and ready for use. SCRAA and MCLM are misleading the FCC on this matter also, in addition to their other fundamental assertions that 1 MHz is needed for PTC (that is contradicted not only by SCRAA internal documents, but by every source in the industry).5 - D - In effect, the Motion is a request for waiver of FCC?s rules including but not limited to waiver of Section 1.939(h), Section 1.945(d), Section 1.948(j)(viii), Section 1.927(i), Section 1.929, Section 1.933, and Section 1.1102 (waiver fee). However, MCLM and SCRRA have not amended the Applications to request waivers, paid the required fees, or shown that they have met the requirements for grant of the waivers. As such, the MCLM Motion and SCRRA Motion are defective and must be dismissed. - E - The Motion should be dismissed for all the above reasons. It would be a waste of Commission staff resources to consider the ?substance? of such a procedurally defective request, indeed, it would have the opposite effect of what the Motion pretends to seek, certain timely relief. In fact, the Motion is a specious attempt to get a final decision on the ?merits? of the SCRAA- PTC 220 LLC asserted public interest assertions that, as PTC 220 LLC instructed the FCC ?militate? grant for PTC. SCRAA and PTC seek that not because they are ready to test or deploy anything soon with the spectrum, as shown above, but since they are worried about Petitioners increasing showings in this proceeding that their ?substance? lacks merit and is deceptive. They want to cut that off, and that should not be permitted. SCRAA has joined MCLM and brought PTC 220 LLC along, in practice of deception and cover ups before the FCC. That is why there are petitions against the MCLM spectrum and why the FCC Enforcement Bureau are investigating MCLM. II. Initial Opposition, in the Alternative A. Reference and Incorporation We present this initial opposition only if the FCC does not grant our motion to dismiss presented above. Since the MCLM Motion referenced and incorporated the SCRRA Motion, including its exhibits, and states it is supplementing the SCRRA Motion, Petitioners hereby reference and incorporate in opposition all of their facts and arguments in the following initial opposition, including all attachments and exhibits, they filed against the SCRRA Motion: Initial Opposition to Motion for Conditional Grant, including all attachments and exhibits, filed by Skybridge Spectrum Foundation et al. on November 9, 2010 in WT Docket No. 10-83 and filed via ULS regarding File Nos. 0004153701 and 0004144435 (the ?First Opp?). As noted in the First Opp, Petitioners could not complete it at that time due to the unlawful delays of SCRRA not fulfilling Petitioners? CPRA request, which SCRRA has still not entirely fulfilled, and delays in the Federal Railroad Administration (?FRA?) providing documents to Petitioners? FOIA Request related to SCRRA?s PTC plans, which were only recently provided (November 17, 2010?after the date the First Opp was due) to Petitioners after Petitioners threatened that they would file a court suit if the FRA did not provide responsive documents. Exhibit B hereto is a chart indicating documents and records that from Petitioners review of the records provided by SCRRA to date have not been provided yet to SSF. It contains a partial list of those documents discussed or referred to in certain of the documents and communications provided by SCRRA to Petitioners. The listed documents are not contained in the records provided to SSF (For example, emails that reference an attachment, but then that attachment is not included). SCRRA has informed SSF that it is still working on providing further records. The FRA is also still gathering documents responsive to SSF?s FOIA request. Petitioners are still reviewing the documents eventually disclosed by SCRRA and FRA and are still trying to get the additional documents not yet provided yet. Therefore, Petitioners reserve the right to supplement their filings against the Applications, including this Motion and their Petition, with further relevant information once they have finished their review of the documents received to date and after receipt and review of the additional documents. B. 1MHz Not Needed for PTC (far less than half needed) This is partly discussed in the Motion to Dismiss section above. The following is in addition. First, the point of this section is (i) the entire Application and defense is specious as to its asserted need for 1 MHz for PTC, and (ii) the asserted need for special relief in the Motion is undercut as well, where SCRAA does not need the spectrum subject of the special relief, and it will not be honest with the FCC as to its real needs (for amount of spectrum, for timing?see above regarding no equipment yet, for AMTS vs other spectrum, and in other matters). Petitioners are attaching hereto as exhibits some documents that show SCRRA is not applying for 1 MHz of AMTS for its own PTC use, but it is applying for the AMTS in a partnership with PTC-220 LLC and it is not admitting that to the FCC. See for example, Exhibit A hereto and the other exhibits attached that reflect this. From Exhibit A it is clear from SCRRA?s own internal communications that it needs far less than the entire 1 MHz of spectrum for PTC, yet the Applications do not state this and SCRRA does not explain why it needs grant of its waivers, which it says it needs to operate its PTC system, with respect to the majority of the spectrum on which it will not be using PTC. In fact, the evidence shows that SCRRA actually intends to use the spectrum in partnership with PTC-220 LLC and that PTC-220 LLC will be using the channels for its needs. Further, in the documents received by SSF to date from SCRRA, there is a study entitled ?Spectrum Estimation Study for Metrolink?s PTC Project? by an Alan Polivka with Transportation Technology Center, Inc. (a division of the Association of American Railroads). It is dated July 2, 2010. Thus, SCRRA only recently commenced a detailed study to assess what amount of spectrum it may need for PTC, despite having asserted to the FCC that it needs the entire 1 MHz for PTC. Petitioners have not been able to review in detail that study yet or have their engineering consultant experts do so in order to determine if any of its findings, assumptions, etc. are erroneous. Once they do so, then they will provide further comments on that. However, as indicated in Exhibit A hereto, SCRRA says it needs far less than the 1 MHz. However, the Applications did not disclose any of this to the FCC. Thus, those exhibits only show further that SCRRA has lacked candor before the FCC regarding the Applications. C. Motions are Really Waivers in Disguise First, in this Opposition section, we refer to and incorporate the section in the Motion to Dismiss section on this topic. In addition is the following: What MCLM and SCRRA are seeking by their respective motions is not permissible under any FCC rule. There is no basis in the FCC?s rules for filing a motion for conditional grant of an assignment application that has been petitioned to deny. In effect, what they are both seeking, but do not candidly admit, is that they seek waiver of the FCC?s rules under Section 1.925, including but not limited to waiver of Section 1.939(h), Section 1.945(d), Section 1.948(j)(viii), Section 1.927(i), Section 1.929, Section 1.933, and Section 1.1102 (waiver fee). Calling a waiver a motion does not make it one. A motion for conditional grant cannot be used to waive rule sections. A waiver must be filed to do that. However, MCLM and SCRRA have not amended the Applications to request waivers, paid the required fees, shown that they have met the threshold requirements for grant of the waivers, including that grant is in the public interest, and the Applications have not gone on the required Public Notice. Without doing all of this, the MCLM Motion and SCRRA Motion are both defective, notwithstanding all of the other reasons Petitioners give herein and in their First Opp to the SCRRA Motion. Even if the SCRRA and MCLM motions could be filed as motions and not waivers, which they cannot, they would have to be filed as amendments to the Applications since they ask for a change to how the Applications are processed and the petitions to deny are handled. D. Attempt to Circumvent Petitioners? Section 309 Petition to Deny It appears that MCLM and SCRRA, both represented by practiced FCC-legal counsel, are attempting to camouflage their waivers as a ?motion? with the hope that they will be granted by the FCC so that they can circumvent Petitioners? petition to deny of the Applications and proceed to take certain actions, which will then be more difficult or impossible for the FCC to undo later if necessary.6 Otherwise, they would have amended the Applications, instead of filing their motions in WT Docket No. 10-83 and as ?pleadings? for expedited relief as reflected on ULS (pleadings for expedited relief are not for the purpose of waiving Commission rules in order to avoid dealing with petitions to deny that must be addressed as part of the normal application processing process prior to any grant of an application?see Sections 1.939(h), 1.945(d) and 1.948(j)(viii)). Thus, the MCLM Motion and SCRRA Motion are defective as filed and should be dismissed as requested above or denied. Petitioners make clear that they will not waive their petition rights under Section 1.939, Section 1.945 and Section 1.948, including to have their petitions of the Applications decided upon in accord with the FCC?s rules. Petitioners will be irreparably prejudiced and damaged if Donald DePriest, who from evidence filed by Petitioners in FCC records is the real controlling interest in MCLM, has been shown to be insolvent and to have a laundry list of creditors seeking repayment, including the IRS, the State of Alabama, Oliver Phillips, an employee of his American Nonwovens company that suffered an injury, but later found out that Mr. DePriest had not paid for the employee insurance plan, etc. Based on the evidence shown in the Petitioners petition pleadings challenging MCLM?s AMTS licenses and in the FCC Enforcement Bureau investigation of MCLL, it is reasonable to assume that one possibility is that any payment to MCLM will likely be distributed to Mr. DePriest?s numerous creditors and then MCLM dissolved if the FCC later finds it to have violated its rules and be subject to disqualification and revocation of its licenses, thereby leaving no MCLM entity to repay any amounts obtained from SCRRA or others to whom it sold or leased spectrum. Thus, it will likely create an administrative and legal quagmire, consuming even more Commission resources, if the Applications are granted conditionally now, and then later rescinded if Petitioners? petitions are granted. the impermissibly filed waivers?MCLM Motion and SCRRA Motion?are granted. Petitioners have already shown they are direct competitors with MCLM and that one of two of Petitioners, as the only lawful qualified high bidders in Auction No. 61, have the actual legal rights under Supreme Court precedent and a fair and just FCC auctions process to the spectrum subject of the License. E. Petitions of the Applications Should Already Haven Been Granted and a Hearing Commenced Given Ongoing Section 308 Proceeding The MCLM Motion and SCRRA Motion cannot be granted since the FCC, as shown herein, must proceed to grant Petitioners? petitions to deny of the Applications and hold an evidentiary hearing. Given the pending Section 308 proceeding, and the fact that it is dealing with facts that raise serious questions about MCLM as a licensee and the License, including ones that affect and relate to whether grant of the Application is in the public interest, Petitioners do not see how the FCC cannot have already granted Petitioners? petitions to deny of the Applications (and for that matter all of their other petitions against MCLM) and moved to hold a hearing under Section 309. If evidence in Petitioners? petitions against MCLM has been sufficient for the FCC to have commenced a Section 308 investigation, then that same evidence clearly must be sufficient prima facie evidence to require a hearing under Section 309 (the Wireless Bureau?s and the Enforcement Bureau?s letters to MCLM and its affiliates clearly referenced facts in Petitioners? petitions to deny filed against MCLM as the basis for commencing the inquiry and investigation, and the questions asked of MCLM and its affiliates all related to matters raised by Petitioners? petitions, including the issue of MCLM control and ownership that pertains to all MCLM applications, including the Applications). Since Petitioners have already given the FCC the evidence it used for its Section 308 investigation, it makes sense for the FCC to immediately grant Petitioners? petitions of the Applications (and other MCLM applications) so that Petitioners can begin to obtain further information and evidence from MCLM and its affiliates and related parties as part of discovery in a hearing proceeding. The evidence the FCC obtains under both a Section 308 investigation and Section 309 hearing could then be used to decide on the Applications and MCLM as a licensee, as well as any parties that have aided or abetted it in its unlawful actions already evidenced by the clear facts and admissions in the record. Unless this is done, then any action on the Applications by the FCC would be premature and prejudicial to Petitioners. F. MCLM and SCRRA Seek to Avoid Additional Evidence in the Proceedings Based on the evidence presented and MCLM and SCRRA?s actions to date, Petitioners believe that MCLM and SCRRA want to circumvent the Section 309 petitions to deny filed by Petitioners? against the Application because MCLM and SCRRA realize the facts they contain are substantial and call for disqualification of MCLM and criminal prosecution of its controlling interests, including for perjury and fraud. Also, they fear that the longer the FCC takes the more likely Petitioners and the FCC Enforcement Bureau are to find additional evidence supporting Petitioners? petitions to deny. This is evidenced by the fact that both the MCLM and SCRRA motions incorrectly suggest that the Section 308 proceeding is the only obstacle to grant of the Applications, when that is clearly not true?there are also Petitioners? petitions under Section 309. Petitioners? petitions gave facts and arguments against granting the Applications that were not just based on matters relating to Auction No. 61. Also, a separate Section 308 proceeding is not the same as a Section 309 proceeding, under which Petitioners have specific petition and appeal rights. Basically, as Petitioners? petitions stated, MCLM and SCRRA are working together to try to speed along the process in order to get grant of the Applications before the FCC has time to fully consider and investigate the evidence already presented by Petitioners and before any further damning evidence is found that would be an additional basis for dismissal of the Applications or disqualification of MCLM as an FCC licensee. Petitioners and the FCC Enforcement Bureau will likely find more evidence regarding MCLM?s actual control, ownership, affiliates, gross revenues, misrepresentations, perjury, etc. That has been the case to date. In addition, SCRRA probably does not want Petitioners to uncover more evidence, including from documents that SSF has not yet been provided by SCRRA in response to SSF?s California Public Records Act (?CPRA?) Request, that shows that SCRRA?s representations to the FCC about their PTC plans and spectrum needs were inaccurate or lacked candor, as Petitioners have shown so far in their petitions to deny of the Applications. Further, SCRRA may be worried that Petitioners will bring the matters involved up to the appropriate State of California authorities, including that SCRRA may have violated California state law by not holding a proper request for proposal and spectrum bid process to obtain bids and spectrum proposals from other 200 MHz and other spectrum band licensees, including VSL, Havens and SSF, who all hold 220-222 MHz or AMTS spectrum in California and are located in California. G. California Law Issues Also, Contrary to SCRRA?s internal memos and documents, MCLM was not the single source of spectrum for SCRRA?s PTC needs, SCRRA knew this and Petitioners intend to demonstrate that to the California Attorney General and other appropriate authorities due to violations of California law that appear to be involved, with sufficient evidence on hand. These are not subject to preemption under Section 332 of the Communications Act: they are matters of violation of California law independent of ?entry? as meant in that Section. H. SSF?s Pending CPRA Request As stated above in the Motion section I, the SCRRA has yet to completely fulfill SSF?s CPRA Request and the FRA has not completely fulfilled SSF?s FOIA Request. Thus, Petitioners? maintain the right to amend this Opposition and their petitions to deny of the Applciations based on any additional relevant evidence SSF may obtain from that, as well as what they may find in the hundreds of pages of records that have been obtained by SSF to date, including just a few weeks ago. Exhibit B hereto contains a partial list of some of the documents that appear to not have been provided to SSF yet by SCRRA. I. Other materials Other exhibits filed herewith support this filing for reasons shown therein, in added text notes and other indications added. In addition, Petitioners have been delayed by unlawful delays and ongoing withholding of information requested by Petitioners of SCRAA under the California Public Records Act, and by unlawful delays and withholdings by the Federal Railroad Administration of directly related materials under FOIA. Petitioners will submit further pleadings when that material is fully or sufficiently obtained and for other good cause. The Motion is not authorized in the first place, as described above. An unauthorized motion may be challenged at any time. Respectfully, Environmentel LLC (formerly known as AMTS Consortium LLC), by [Filed electronically. Signature on file.] Warren Havens President Verde Systems LLC (formerly known as Telesaurus VPC LLC), by [Filed electronically. Signature on file.] Warren Havens President Intelligent Transportation & Monitoring Wireless LLC, by [Filed electronically. Signature on file.] Warren Havens President Telesaurus Holdings GB LLC, by [Filed electronically. Signature on file.] Warren Havens President Skybridge Spectrum Foundation, by [Filed electronically. Signature on file.] Warren Havens President Warren Havens, an Individual [Filed electronically. Signature on file.] Warren Havens Each of Petitioners: 2509 Stuart Street (new office) Berkeley, CA 94705 Ph: 510-841-2220 Fx: 510-740-3412 Date: December 7, 2010 Declaration I, Warren Havens, as President of Petitioners, hereby declare under penalty of perjury that the foregoing Motion to Dismiss, or in the Alternative, Opposition to Motion for Conditional Grant was prepared pursuant to my direction and control and that all the factual statements and representations contained herein are true and correct. /s/ Warren Havens [Submitted Electronically. Signature on File.] ____________________________________ Warren Havens December 7, 2010 Certificate of Service I, Warren C. Havens, certify that I have, on this 8th day of December 2010, caused to be served, by placing into the USPS mail system with first-class postage affixed, unless otherwise noted, a copy of the foregoing Motion to Dismiss, or in the Alternative, Opposition to Motion for Conditional Grant unless otherwise noted, to the following:7/ Jeff Tobias, Mobility Divison, WTB Federal Communications Commission Via email to: jeff.tobias@fcc.gov (The motion?s text only) Lloyd Coward, WTB Federal Communications Commission Via email to: Lloyd.coward@fcc.gov (The motion?s text only) Gary Schonman, Special Counsel & Brian Carter Investigations and Hearings Division Enforcement Bureau Federal Communications Commission Via email to: gary.schonman@fcc.gov and brian.carter@fcc.gov (The motion?s text only) Hillary S. DeNigro, Chief Investigations & Hearings Division Enforcement Bureau Federal Communications Commission Via email to: Hillary.denigro@fcc.gov (The motion?s text only) Dennis Brown (legal counsel for MCLM and Mobex) 8124 Cooke Court, Suite 201 Manassas, VA 20109-7406 Fletcher Heald & Hildreth (Legal counsel to SCRRA) Paul J Feldman 1300 N. 17th St. 11th Fl. Arlington, VA 22209 7 On December 7, 2010, Petitioners filed via ULS under File No. 0004153701 and served a copy of the Motion to Dismiss, or in the Alternative Opposition to Motion for Conditional Grant, along with Exhibits A and B, which were filed via ULS under all the File Nos. captioned above and in the WT Docket 10-83. Today, December 8, 2010, Petitioners are filing the D-Motion and all of its Exhibits A, B, and 3-9 via ULS under the File Nos. captioned above and in the WT Docket 10-83 and serving a copy as noted in this Certificate of Service. The mailed copy being placed into a USPS drop-box today may not be processed by the USPS until the next business day. Southern California Regional Rail Authority ATTN Darrell Maxey 700 S. Flower St. Suite 2600 Los Angeles, CA 90017 Edwin F. Kemp President PTC-220, LLC 1400 Douglas Street, STOP 0640 Omaha, NE 68179 (The motion?s text only) Southern California Regional Rail Authority Board of Directors 700 S. Flower Street, 26th Floor Los Angeles, CA 90017-4101 (The motion?s text only) Russell Fox (legal counsel for MariTel, Inc.) Mintz Levin 701 Pennsylvania Ave., N.W. Washington, D.C. 20004 (The motion?s text only) Jason Smith MariTel, Inc. 4635 Church Rd., Suite 100 Cumming, GA 30028 (The motion?s text only) Joseph D. Hersey, Jr. U.S. National Committee Technical Advisor and, Technical Advisory Group Administrator United States Coast Guard Commandant (CG-622) Spectrum Management Division 2100 2nd Street, S.W. Washington, DC 20593-0001 Via email only to: joe.hersey@uscg.mil (The motion?s text only) /s/ [Filed Electronically. Signature on File] ___________________________________ Warren Havens Exhibit A: Pages 1-14 of the 51 pages from the file "Records Response to Request No 5" attached to the November 12, 2010 email from Perry Tseko of SCRRA to Skybridge Spectrum Foundation in response to SSF?s pending CPRA Request. See notes and comments on the below pages that are self-explanatory and support Petitioners? arguments in the Petition and First Opp. Exhibit B Partial List of Documents Not Yet Provided by SCRRA Date Document File Name and Date Received Page Document(s) Not Yet Provided by SCRRA and Certain Notes by Petitioners 9-9-09 and 1-4-10 SCRRA Board Reports BrdRptMCLM received 5-3-10 1 "The Board may direct staff to seek alternate sources of RF spectrum. Investigation to date has not located any such alternative source." Petitioners did not find in the documents received from SCRRA to date any 'investigation' at all, including any that concluded there were no alternative sources of RF spectrum or other spectrum options. 9/4/09 Email from SCRRA Consultant Alan Polivka to SCRRA Chief Engineer Darrell Maxey Records Response to Request No 4 received 11-12-10 1 It appears there were communications between SCRRA and John Reardon regarding a "reasonable explanation" of Petitioners' petitions filed against MCLM and its AMTS licenses. Petitioners did not find in the documents provided by SCRRA any record of any memo, summary, email, or other document summarizing or restating this "reasonable explanation" or evidence that it was provided to the SCRRA Board or Management. Further, Petitioners did not find in the documents provided by SCRRA any record of any due diligence or analysis regarding Petitioners' petitions against and claims to MCLM's AMTS auction licenses, even though SCRRA communications indicate SCRRA staff and due diligence experts were fully aware of these. 9/26/09 Attachment to Email from SCRRA Consultant Polivka to SCRRA, Systra, XORail Records Response to Request No 4 received 11-12-10 43 "PTC Spectrum Background Paper.doc" Not Yet Provided by SCRRA to Petitioners 8/21/09 Attachment to Email from SCRRA Consultant Polivka to Eisenberg, Reardon Records Response to Request No 4 received 11-12-10 57-58 "Guys, Can you give the attached maps ?" Petitioners have not yet received the "attached maps" from SCRRA 12/12/09 Attachments to Email from Kurt Drummond of XORail to SCRRA Consultant Alan Polivka Records Response to Request No 4 received 11-12-10 99 "217_8 to 217_9 sample.bmp" and "Required MCLM Disclosures re Lessees and Incumbents_r1.doc" Petitioners have not yet received these Attachments from SCRRA 12/12/09 Attachment to Email from SCRRA Consultant Alan Polivka to Kurt Drummond of XORail Records Response to Request No 4 received 11-12-10 99-100 "Kurt, Attached is a list of the rest of the AMTS A-block channels ?" Petitioners have not yet received this Attachment from SCRRA. 12/12/09 Attachment to Email from MCLM's John Reardon to SCRRA Consultant Alan Polivka Records Response to Request No 4 received 11-12-10 100 "Dear Alan, Here is a list of channels ?" Petitioners have not yet received this Attachment from SCRRA. 12/12/09 Attachment to Email from Tim Smith of Critical RF to MCLM's John Reardon Records Response to Request No 4 received 11-12-10 101 "Here are the channels ?" Petitioners have not yet received this Attachment from SCRRA. Nov-09 Fair Market Valuation done by Spectrum Bridge Records Response to Request No 4 received 11-12-10 128 "The subject A-block, site specific coverage areas are shown below ?" Map provided to date is blacked out and not viewable. Petitioners have not yet received a viewable map from SCRRA. Between 11- 19-09 and 12-21-09 Emails between Union Pacific and SCRRA Records Response to Request No 5 received 11-12-10 p 1-3 Content of Email on 11-19-09 and Emails on and after 12-21-09 between Union Pacific and SCRRA suggests there were further communications between Union Pacific and SCRRA. Petitioners have not yet recived a copy of these additional communications between 11-19-09 and 12-21-09 from SCRRA. HOME SERVICES ABOUT CLIENTS PAPERS AND PATENTS LINKS Experimental Radio Applications at the FCC This summarizes a selection of applications for the Experimental Radio Service received by the FCC during July 2010. These are related to high-frequency data, military communications, environmental data collection, synthetic aperture radar, WiMAX, sensor networks, interference-resistant communications, LTE, rail transportation, air traffic control, white space networks, and RFID. Harris filed an application (with supporting exhibits) for experimental license to operate on various frequencies between 3 and 15 MHz to test an experimental high-frequency wideband waveform that is intended to operate at either 12 kHz bandwidth or 24 kHz bandwidth to allow faster data transfer via high-frequency communications. Harris also filed an application (with supporting exhibit) for experimental license to operate on 4.94-4.99 GHz in support of development of US Army!s Warfighter Information Network: Tactical (WIN-T) and Future Combat Systems (FCS) programs. Equipment is to consist of the HNRe2 Highband Network Radio, manufactured by Harris. Harris says the HNRe2 is comprised of four elements: 1) the Baseband Processing Unit, 2) the Highband RF Unit (HRFU), 3) an Inertial Navigation Unit (INU), and a GPS device. The HRFU further consists of an upconverter, a High-Powered Amplifier (HPA), a Switched Beam Antenna (SBA), a Low-Noise Amplifier (LNA), and a downconverter). The test network will consist of five fixed nodes and one mobile node. The FCC has asked Harris to justify extended testing in a band that is primarily allocated for non-government public safety use. Canon U.S.A. filed an application (with supporting exhibits) for special temporary authority to operate wireless devices in support of a private technology and product exhibition from September 1, 2010 through September 3, 2010 at the Jacob K. Javits Convention Center in New York, NY. Canon is planning to import many wireless devices from Japan to be used with displays during the exhibition. These devices are not FCC compliant and not expected to be FCC compliant until after the exhibition. Frequencies requested include 315.0-315.7 MHz, 2.40-2.50 GHz, 5.18-5.67 GHz, and 61.6-62.5 GHz. ABOUT STEVEN Steve Crowley helps companies and organizations achieve successful outcomes in R&D activities, strategy planning and execution, business transactions, patent portfolio management, technology policy, and other matters related to next-generation communications technologies. CONNECT CONTACT E-Mail info@stevencrowley.com Telephone +1-202-670-5040 Address Steven J. Crowley, P.E. 1200 G Street, N.W. Suite 800 Washington, D.C. 20005 STEVE ON TWITTER Vibration-powered generator uses inverse magnetostriction effect to replace button batteries http://bit.ly/dW5TBr 52 mins ago Twitter @stevenjcrowley RSS subscribe Linkedin profile Frequencies requested include 315.0-315.7 MHz, 2.40-2.50 GHz, 5.18-5.67 GHz, and 61.6-62.5 GHz. This application was granted on August 11. The Washington State Department of Ecology filed an application (and supporting exhibits) for experimental license to operate 150 Design Analysis model H-222 GEOS satellite radios to transmit stream flow data. Operation is to be on 401.710-401.998 MHz. BAE Systems filed an application (with supporting exhibit) for special temporary authority to operate an antenna test range in Merrimack, New Hampshire in support of the manufacture of military systems. Many frequencies are requested from 1 MHz to 2587 MHz. The application was granted on July 29. Broad Comm filed an application for special temporary authority to operate in support of an ?emergency project by the Massachusetts Institute of Technology Center for Ocean Engineering (MIT) related to the Gulf of Mexico oil spill. ? Part of the project requires collecting continuous video data from an aircraft that will fly over the Gulf. The video feed needs to be relayed to nearby receiving stations either on land or on vessels near the aircraft. The operation may require the aircraft to fly out over the Gulf to a maximum distance of 300 miles (483 km) from the New Orleans, LA area at altitudes up to 3,000 feet.? The application is inconsistent with regard to the specific frequencies requested. At one point it says three frequencies are being requested: 2,210, 2,220 and 2,230 MHz. At another point it says 2253.3 MHz. The application was granted on August 11. Olson Instruments filed an application for special temporary authority to test an IBIS sensor unit during static and dynamic bridge testing. Operation is to be on 17.101-17.299 GHz. This application was granted on August 11. Lockheed Martin filed an application (with supporting exhibits) for special temporary authority to operate synthetic aperture radar (SAR) in the portions of the Gulf of Mexico affected by the oil spill. The SAR data collected will be used to classify oil debris in support of FEMA operations. Operation is at 16.9 GHz. DRS ICAS filed an application (with supporting exhibits) for special temporary authority to operate in support of the manufacture of military systems. The company has requested confidential treatment of details, but appears to be testing the DRS X46-V SATCOM terminal and 4.8 meter ground station in support of development of X-band mobile satellite communications for Operation Enduring Freedom. Operation is to be on 8326-8332 MHz. Reindert A. Smit, apparently an amateur radio operator, filed an application (with supporting exhibits) for special temporary authority to experiment with ROS digital communications modem software, whose purpose is to optimize high-frequency, moon bounce, and meteor-scatter digital RT @CiscoSPMobility Mobile video: Just another app within the network or a bandwidth hog? http://csc0.ly/6019uxfz 7 hrs ago And the TV Spectrum NPRM is now out also. Texts for all three spectrum items at http://www.fcc.gov/ 12 hrs ago More updates... CATEGORIES 3GPP 3GPP2 4G Ad-hoc Networks Antennas Aviation Business Cognitive Radio DTV Experimental Femtocells GPS High Frequency IMT-Advanced Infrastructure Interference Jamming Land Mobile Location LTE M2M Military Millimeter Modulation/Demodulation Network Protocols Patents Public Safety Radar Radiolocation Regulatory RFID Satellite Smart Grid Space Communications Spectrum Standardization Telemetry Terminals Ultra-wideband Unlicensed Video White Space Wi-Fi WiMAX Wireless BLOGROLL ABI Research AetherCzar Akihabara News All Things Digital Asiajin AT&T Labs Blogband communications. Operation is to be on several frequencies between 1.838 MHz and 14.416 MHz. Approval was granted on August 10. Northrop Grumman filed an application (with supporting exhibit) for special temporary authority to test a radar system that is to demonstrate the ability to track line-of-sight (LOS) terrain obstructions, target detection, and perimeter intrusion. The radar operates using a slotted waveguide array. Operation is to be on 9380-9440 MHz. This application was granted on July 31. Raytheon Missile Systems filed an application (with supporting exhibit) for experimental license to operate in support of development of interference-resistant command and control radio transmissions. Operation is to be on 430-440 MHz and 902-928 MHz. Raytheon Network Centric Systems filed an application (with supporting exhibit) to test the Nett- Warrior Communications System. This system will be integrated into other Raytheon systems. Operation is to be on 30.025-74.600 MHz. CapRock Government Solutions filed an application (with supporting exhibits) for special temporary authority to test an antenna along with modulation and encryption techniques. Operation is to be on 8280-8300 MHz. The Alameda County [California] Sheriff!s Office filed an application (with supporting exhibit) for experimental license to operate on 763-768 MHz and 793-798 MHz to develop and evaluate broadband Long-term Evolution (LTE) equipment. Alcatel-Lucent filed an application (with supporting exhibit) for experimental license to test LTE at several cell sites in the Chicago area. The purpose of the testing is to verify LTE performance in a mobile environment and to optimize system settings under various environments. Key performance indicators to be verified include attach success rate, paging success rate, and handover success. Operation is to be on several frequencies between 698 and 793 MHz. This application was approved on August 7. The Aerospace Corporation filed an application (with supporting exhibits) for experimental license to test synthetic aperture radar (SAR) on 92.05-99.95 GHz. As the applicant explains, in SAR radars, ?the transmitter has a component of motion in a direction perpendicular to the beam, and the reflected signals are formed into an ?image? of the scatterers when resolved into groups of scatterers in a two- dimensional map based on time-of-arrival (range coordinate) and Doppler frequency shift (azimuth coordinate).? The applicant notes that, in SAR, weather and vibration can mask man-made effects. Part of the research includes mitigating image degradation due to weather and vibration so man-made effects are more apparent. This application was approved on August 7. The Union Pacific Railroad Company filed an application (with supporting exhibits) for experimental license to conduct propagation testing on 220.725-220.750 MHz. The applicant explains that ?the US rail industry is subject to a federal mandate to implement Positive Train Control (PTC) technology by the end of 2015. The industry is in the midst of a comprehensive development effort to realize this technology. A central component of PTC is wireless communications. The industry has identified 217- 222 MHz as the band of operation for PTC, and some 220-222 spectrum licenses have already been acquired by an industry group. A concerted effort is underway to develop a radio specifically for this application, and we expect to have an authorized radio in early to mid 2011. However, as part of our deployment planning, we need to characterize the performance and propagation of modulated 220 MHz signals by doing field tests this year.? The Graduate School of Oceanography, University of Rhode Island, filed an application (with supporting exhibits) for experimental license to operate high-frequency Coastal Ocean Dynamics Applications Radar (CODAR) to map surface ocean currents. Operation was to be on several frequencies between 24.615 and 26.475 MHz. The FCC rejected the application, saying that CODAR is currently being reviewed for its potential as a service requiring a frequency allocation. Until that determination is made, there will be no more experimental authorizations. Bob Frankston Brian Krebs Broadband Law Advisor Broadcast Law Blog Brough Turner Bruce Schneier Cecilia Kang Cisco Mobility Cisco Policy Cognitive Radio Technologies CommLawBlog Connected Planet CTIA CyberTelecom Daily Wireless David Reed Dean Bubley Defense Industry Daily Derek Lowe DigInfo Digital Society Don Tapscott DSL Reports Ericsson Labs Freaklabs GigaOM Google Mobile GPS World Hackers on a Plane HighTechForum ITIF Jay Rosen KoreaCrunch Larry Downes Marc Cuban Marginal Revolution MedGadget Michael Marcus Mobile in Japan MuniWireless National Defense NTT DOCOMO NYC Resistor Public Knowledge Qualcomm Rob Pegoraro Rockwell Collins filed an application (with supporting exhibits) for experimental license to conduct experiments to test waveforms for high speed data over high-frequencies. Testing is to include characterization of performance and actual wideband channel propagation characteristics. Rockwell Collins says it is a member of the Technical Advisory Committee for MIL-STD-188-110C and MIL- STD-188-141C standards revisions and new standard definitions, and the experimental authorization will enable verification of performance and inter-operability metrics in the standards. Operation is to be on many frequencies between 2.398 and 29.720 MHz. Rockwell Collins also filed an application (with supporting exhibits) for experimental license to test a prototype transmitter (as part of a transceiver) for the Automatic Dependent Surveillance-Broadcast (ADS-B) system, a surveillance technique for air traffic control and similar uses. The company intends to conduct mobile ground testing in and around the Rockwell Collins! facilities in Cedar Rapids, Iowa. Operation is to be on several frequencies between 977 and 1096 MHz. SpectrumBridge filed an application (with supporting exhibits) for experimental license to test the usefulness of white space spectrum for use in telemedicine applications ? indoor telemetry, medical records exchange, M2M applications, and enhanced wireless broadband access for doctors, patients, and visitors residing within a hospital campus. Testing is to be done in association with Hocking Valley Community Hospital in Logan, Ohio. The requested frequency band is 470-698 MHz. Western DataCom filed an application (with supporting exhibits) for special temporary authority to conduct a test of extending cellular telephone coverage on the waters of Lake Erie. Operation is to be on 2353.5-2370.0 MHz. The base station would operate from a tethered aerostat (helium balloon system) at 1000-1400 feet above ground. Keurig, Inc. filed an application for special temporary authority to test a coffee brewing system that uses RFID technology to adjust brewing parameters in accordance with the beverage being prepared. Operation is to be on 902-928 MHz. This application was granted on August 7. Columbia University filed an application (with supporting exhibits) to operate WiMAX equipment on 2535-2540 MHz in support of the GENI project. The application was approved on August 11. Posted by Steven J. Crowley to Amateur Radio, Antennas, Aviation, Experimental, GPS, High Frequency, Infrastructure, Interference, LTE, M2M, Military, Millimeter, Modulation/Demodulation, Public Safety, RFID, Radar, Satellite, Sensors, Telemetry, White Space, WiMAX, Wireless @ 6:52 pm, 08/14/10 LEAVE A COMMENT NAME (REQUIRED) MAIL (WILL NOT BE PUBLISHED) (REQUIRED) WEBSITE Sascha Meinrath Scott Bradner Spectral Holes Sumitomo Electric Surprisingly Free Susan Crawford TechCrunch Japan (in Japanese) Technology Liberation Front Teclosion Ted Leonsis Tokyo HackerSpace USPTO WCAI Wireless Developer Network Wireless Watch Japan SUBMIT COMMENT All information copyright Steven J. Crowley, 2009 © | Legal notice and disclaimer ????????????????????????? ? ?????????????????????????????????????????????????????????????????????????????????????????????????????????? ????????????????????????????????????????????????????????????????????????????????????????????????????????? ?????????????????????????????????????????????????????????????????????????? ??????????????????????????????????????????????????????????????????????????????????????????????????? ??????????????????????????????????????????????????????????????????????????????????????????????????? ?????????????????? ??????????????????????????????????????????????????????????????????????????????????????????????????????????? ??????????????????????????????????????????????????????????????????????????????????????????????????? ???????????????????????????????????????????????????????????????????????????????????????????????????? ???????? ?????????????????????????????????????????????????????????????????????????????????????????????????? ?????????????????????????????????????????????????????????????????????????????????????????????????????????? ????????????????????????????????????????????????????????????????????????????????????????????????????? ??????????????????????????????????????????????????????? ?????????????????????????????????????????????????????? ??????????????????????????????????????????????????????????????????????????????????????????????????????? ????????????????????????????????????????????????????????????????????????????????????????????????? ?????????????????????????????????????????????????????????????????????????????????????????????????????????? ????????????????????????????????????????????????????????????????????????????????????????? ?????????????????????????????????????????????????????????????????????????????????????????????????????????? ???????????????????????????????????????? 65'-0" 10'-0" 30.00in. 30.00in. 36.00in. Existing ground ring Upper detail31 32 2 27 17 28 1 11 7 12 8 42 13 5 9 or 10 25 Lower Detail 1113 12 27 41 15 Existing ground ring 29 13 44 14 30 28 42 16 25 5 35 26 17 37 43 7 50 49 4746 48 51 52 Hogan Lovells US LLP is a limited liability partnership registered in the District of Columbia. Hogan Lovells refers to the international legal practice comprising Hogan Lovells US LLP, Hogan Lovells International LLP, Hogan Lovells Worldwide Group (a Swiss Verein), and their affiliated businesses with offices in: Abu Dhabi Alicante Amsterdam Baltimore Beijing Berlin Boulder Brussels Caracas Chicago Colorado Springs Denver Dubai Dusseldorf Frankfurt Hamburg Hanoi Ho Chi Minh City Hong Kong Houston London Los Angeles Madrid Miami Milan Moscow Munich New York Northern Virginia Paris Philadelphia Prague Rome San Francisco Shanghai Silicon Valley Singapore Tokyo Warsaw Washington DC Associated offices: Budapest Jeddah Riyadh Zagreb Hogan Lovells US LLP Columbia Square 555 Thirteenth Street, NW Washington, DC 20004 T +1 202 637 5600 F +1 202 637 5910 www.hoganlovells.com August 31, 2010 VIA ELECTRONIC DELIVERY Marlene H. Dortch, Secretary Federal Communications Commission 445 12th Street, SW Washington, DC 20554 Re: PTC-220, LLC?s Submission of Positive Train Control Implementation Plans WT Docket No. 08-256 Dear Ms. Dortch: PTC-220, LLC (?PTC-220?) hereby submits the Positive Train Control Implementation Plans (?PTCIPs?) of each its four members: CSX Transportation, Inc., Union Pacific Railroad Company, Norfolk Southern Railway Company, and BNSF Railway Company. These PTCIPs, prepared pursuant to 49 C.F.R. § 236.1009(a) and § 236.1011, have been approved by the Federal Railroad Administration (?FRA?).1 The PTCIPs are being submitted as required by the Wireless Telecommunications Bureau?s order of June 25, 2009 issued in the above-referenced docket.2 The attached PTCIP documents have been redacted to protect certain Sensitive Security Information (?SSI?),3 as well as other information constituting confidential commercial and/or financial information.4 Unredacted versions of the PTCIPs are being submitted by hand delivery to Wireless Telecommunications Bureau staff along with a request for confidential treatment pursuant to Section 0.459 of the Commission?s rules. 1 The final FRA approval was obtained on August 24, 2010. 2 Request of PTC-220, LLC for Waivers of Certain 220 MHz Rules, Memorandum Opinion and Order, DA 09-1425, 24 FCC Rcd 8537 ¶ 15 (WTB 2009). 3 See 49 C.F.R. § 15.1 et seq. 4 See 47 C.F.R. § 0.457(d)(2). Marlene H. Dortch - 2 - August 31, 2010 Please contact the undersigned with any questions. Respectfully Submitted, /s/ Michele C. Farquhar Michele C. Farquhar Counsel to PTC-220, LLC Partner michele.farquhar@hoganlovells.com D 1+ 202 637 5663 Enclosures cc: Roger Noel Lloyd Coward Linda Chang Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 BNSF Railway Electronic Train Management System PTC Implementation Plan (PTCIP) Submitted in fulfillment of 49 CFR Part 236, Subpart I, § 236.1011 Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - ii - Revision History Version Date Changed By Summary 1.0 04/14/2010 BNSF Railway Document released to the FRA 1.1 04/20/2010 BNSF Railway Moved SSI PHMSA Routing Exceptions to Appendix J.1 1.2 05/26/2010 BNSF Railway Incorporated edits as a result of the FRA?s review of  PTCIP V1.1 1.3 06/10/2010 BNSF Railway Incorporated edits as a result of the conditions set forth in the FRA?s conditional approval of BNSF?s  PTCIP v1.2. 1.4 07/02/2010 BNSF Railway Incorporated edits as a result of the FRA comments received on July 2, 2010. RA/LJII'AY Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - iii - Table of Contents 1  Introduction ....................................................................................................... - 1 -  1.1  Overview ........................................................................................................................... - 1 -  1.1.1  History ........................................................................................................................... - 1 -  1.1.2  Capital Resource Diversion and Operational Impacts .................................................. - 2 -  1.1.3  Approach to PTC Implementation in Southern California ........................................... - 4 -  1.1.4  Organizational Relationships ........................................................................................ - 4 -  1.1.5  Request for Amendment of a PTCIP [§ 236.1009(a)(2)(ii)] ......................................... - 6 -  1.2  Goals and Objectives ........................................................................................................ - 7 -  1.2.1  Performance .................................................................................................................. - 7 -  1.2.2  Quality ........................................................................................................................... - 7 -  1.2.3  Technical ....................................................................................................................... - 8 -  1.2.4  Coverage ....................................................................................................................... - 8 -  1.3  Success Criteria ................................................................................................................. - 8 -  1.3.1  Long-term Goal Metrics ............................................................................................... - 9 -  1.3.2  Intermediate Goal Metrics .......................................................................................... - 11 -  1.4  Applicability ................................................................................................................... - 13 -  1.5  Document Overview ....................................................................................................... - 13 -  1.6  Acronyms and Definitions .............................................................................................. - 14 -  2  Applicable Documents .................................................................................... - 19 -  3  Designating T rack as Main L ine or Non-Main L ine [§ 236.1011(a)(8)] ... - 20 -  3.1  Non-Mainline Subdivisions ............................................................................................ - 21 -  4  Technology [§ 236.1011(a)(l)] ......................................................................... - 22 -  5  Compliance [§ 236.1011(a)(2)] ....................................................................... - 26 -  5.1  Risks to Meeting Required PTC Installation Date.......................................................... - 26 -  6  Interoperability [§ 236.1011(a)(3)] ................................................................ - 33 -  6.1  Railroad Agreement Provisions Relevant to Interoperability [§ 236.1011(a)(3)(i)] ...... - 33 -  6.2  Technology Applicable to Interoperability [§ 236.1011(a)(3)(ii)] ................................. - 35 -  6.3  Obstacles to Interoperability [§ 236.1011(a)(3)(iii)] ...................................................... - 36 -  RA/LJII'AY Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - iv - 7  Installation Risk Analysis [§ 236.1011(a)(4)] ................................................ - 37 -  8  Deployment Sequence & Schedule [§ 236.1011(a)(5)] ................................. - 38 -  9  Rolling Stock [§ 236.1011(a)(6)] ..................................................................... - 39 -  9.1  Rolling Stock to be Equipped [§ 236.1011(a)(6)(i)] ....................................................... - 39 -  9.2  Schedule [§ 236.1011(a)(6)(ii)] ...................................................................................... - 39 -  9.3  Tenant Railroads [§ 236.1011(a)(6)(iv)(A) and (B)] ...................................................... - 40 -  10  Wayside Devices [§ 236.1011(a)(7)] ............................................................ - 41 -  10.1  WIU Technology ............................................................................................................ - 42 -  10.2  Number of Wayside Devices per Subdivision ................................................................ - 43 -  10.3  Subdivisions with ATS Removal .................................................................................... - 44 -  10.4  Subdivisions with CAB Signal Device Removal ........................................................... - 44 -  11  Exceptions to Risk-Based Prioritization [§ 236.1011(a)(9)] .................... - 45 -  11.1  PHMSA Routing Exceptions .......................................................................................... - 46 -  12  Strategy for Full PT C System Deployment [§ 236.1011(b)] .................... - 47 -  13  Main L ine T rack Exclusion Addendum [§ 236.1019] .............................. - 48 -  13.1  MTEA General ............................................................................................................... - 48 -  13.2  MTEA Request ? Topeka Subdivision ........................................................................... - 49 -  13.3  MTEA Request ? Raton Subdivision .............................................................................. - 50 -  13.4  MTEA Request ? Glorieta Subdivision .......................................................................... - 51 -  RA/LJII'AY Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - v - List of Appendices The PTCIP Appendices contain confidential information that constitutes trade secrets and other proprietary information that is exempt from the mandatory disclosure requirements of the Freedom of Information Act (5 U.S.C. § 552) (FOIA). The whole Appendix section as identified by ?<Confidential>? below has been designated as confidential as required by 49 C.F.R. § 209.11(d) so  as to exempt the entire section from all disclosure requirements under FOIA. Appendix A Short L ine Letters of Understanding A.1 Acadiana Railway Company < SSI > A.2 Alabama & Gulf Coast Railway < SSI > A.3 Apache Railway Company < SSI > A.4 Appanoose County Community Railroad < SSI > A.5 Arizona & California Railroad < SSI > A.6 Arizona Central Railroad Inc < SSI > A.7 Arkansas & Missouri Railroad < SSI > A.8 Ballard Terminal Railroad Co < SSI > A.9 Bighorn Divide & Wyoming Railroad Inc < SSI > A.10 Birmingham Southern Railroad Co < SSI > A.11 Blackwell Northern Gateway Railroad < SSI > A.12 Burlington Junction Railway < SSI > A.13 Cascade & Columbia River Railroad < SSI > A.14 Central California Traction < SSI > A.15 Central Illinois Railway < SSI > A.16 Central Montana Rail Inc < SSI > A.17 Central Washington Railroad < SSI > A.18 Cimarron Valley Railroad < SSI > A.19 City of Prineville Railroad < SSI > A.20 Colorado & Wyoming Railway Company < SSI > A.21 Columbia Basin Railroad Co < SSI > A.22 Crab Orchard & Egyptian Railroad < SSI > A.23 Dakota & Iowa Railroad Co < SSI > RA/LJII'AY Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - vi - A.24 Dakota Missouri Valley & Western Railroad < SSI > A.25 Dakota Southern Railroad < SSI > A.26 Dallas Garland & Northeastern Railroad Inc < SSI > A.27 Delta Valley & Southern Railway Company < SSI > A.28 Denver Rock Island Railroad < SSI > A.29 Eastern Washington Gateway Railroad < SSI > A.30 Ellis & Eastern Company < SSI > A.31 Fort Worth & Western Railroad Co < SSI > A.32 Galveston Railroad LP < SSI > A.33 Garden City Western Railway < SSI > A.34 Grainbelt Corporation < SSI > A.35 Great Western Railway of Colorado LLC < SSI > A.36 Gulf Colorado and San Saba Railway Corp < SSI > A.37 Hutchinson & Northern Railway < SSI > A.38 Illinois Railway < SSI > A.39 Illinois Western Railroad < SSI > A.40 Kansas & Oklahoma Railroad < SSI > A.41 Kansas Eastern Railroad < SSI > A.42 KAW River Railroad < SSI > A.43 Keokuk Junction < SSI > A.44 Kiamichi Railroad Company LLC < SSI > A.45 Kyle Railroad Company < SSI > A.46 Louisiana & Delta Railroad < SSI > A.47 Manufacturer's Junction Railway Company < SSI > A.48 Meeker Southern Railroad < SSI > A.49 Minnesota Commercial Railway Company < SSI > A.50 Minnesota Northern Railroad < SSI > A.51 Minnesota Prairie Line < SSI > A.52 Minnesota Southern Railway < SSI > A.53 Mission Mountain Railroad < SSI > RA/LJII'AY Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - vii - A.54 Mississippi & Tennessee Railroad < SSI > A.55 Mississippi Central Railroad Company < SSI > A.56 Mississippian Railway Cooperative < SSI > A.57 Missouri & Northern Arkansas Railroad Company Inc. < SSI > A.58 Missouri & Valley Park Railroad < SSI > A.59 Modesto & Empire Traction Company < SSI > A.60 Montana Rail Link < SSI > A.61 Mount Vernon Terminal Railway < SSI > A.62 Nebraska Kansas & Colorado Railway < SSI > A.63 Nebraska Northeastern Railroad < SSI > A.64 Northern Lines Railway < SSI > A.65 Northern Plains Railroad < SSI > A.66 Northwestern Oklahoma Railroad Company < SSI > A.67 Omaha Lincoln & Beatrice Railway Company < SSI > A.68 Otter Tail Valley Railroad < SSI > A.69 Pacific Sun Railroad < SSI > A.70 Panhandle Northern Railroad < SSI > A.71 Peninsula Terminal Railroad Co < SSI > A.72 Portland & Western Railroad Inc < SSI > A.73 Portland Terminal Railroad < SSI > A.74 Puget Sound & Pacific Railroad Company < SSI > A.75 Red River Valley & Western Railroad < SSI > A.76 Richmond Pacific Railroad < SSI > A.77 Riverport Railroad LLC < SSI > A.78 RJ Corman Tennessee Terminal RR < SSI > A.79 Rock & Rail < SSI > A.80 San Joaquin Valley Railroad Co < SSI > A.81 Sand Springs Railway Company < SSI > A.82 Semo Port Railroad Inc < SSI > A.83 Sidney & Lowe Railroad Inc < SSI > RA/LJII'AY Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - viii - A.84 Sierra Railroad < SSI > A.85 Sisseton Milbank Railroad < SSI > A.86 South Kansas & Oklahoma Railroad Inc < SSI > A.87 South Plains Lamesa Railroad LTD < SSI > A.88 Southwestern Railroad < SSI > A.89 Stillwater Central Railroad < SSI > A.90 Stockton Terminal & Eastern < SSI > A.91 Tacoma Rail < SSI > A.92 Tazewell & Peoria Railroad Inc < SSI > A.93 Texas & Oklahoma Railroad < SSI > A.94 Texas City Terminal Railway Company < SSI > A.95 Texas North Western Railroad < SSI > A.96 Texas Northeastern Railroad < SSI > A.97 Texas Pacifico Transportation Company < SSI > A.98 Texas Rockcrusher Railway < SSI > A.99 Timber Rock Railroad < SSI > A.100 Toledo Peoria & Western Railway < SSI > A.101 Transit America LLC < SSI > A.102 Tulsa-Sapulpa Union Railway Company < SSI > A.103 Twin Cities & Western Railroad Company < SSI > A.104 V & S Railway < SSI > A.105 Washington and Idaho Railway < SSI > A.106 West Texas & Lubbock Railroad < SSI > A.107 Wichita Tillman & Jackson Railway Company Inc < SSI > A.108 Wisconsin & Southern Railroad < SSI > A.109 Yellowstone Valley Railroad < SSI > Appendix B Passenger Letters of Understanding B.1 Altamont Corridor Express < SSI > B.2 Commuter Rail Division of the Regional Transportation Authority (METRA) < SSI > RA/LJII'AY Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - ix - B.3 National Railroad Passenger Corporation (AMTRAK) < SSI > B.4 North County Transit District < SSI > B.5 Northstar Commuter Rail < SSI > B.6 Sound Transit < SSI > B.7 Southern California Regional Rail Authority < SSI > B.8 Trinity Railway Express < SSI > Appendix C C lass I Letters of Understanding C.1 Canadian National Railway Company < SSI > C.2 Canadian Pacific Railway Company < SSI > C.3 The Kansas City Southern Railway Company < SSI > C.4 ITC Memorandum of Understanding < SSI > Appendix D Implementation Plan D.1 Implementation Limits <SSI> D.2 Implementation Metrics <SSI> Appendix E PT C Project Charter Template E.1 PTC Project Charter Template <SSI> Appendix F Risk Analysis F.1 Risk Analysis by Subdivision <SSI> Appendix G Rolling Stock Installation G.1 Rolling Stock Installation <SSI> Appendix H Non-Mainline Subdivisions H.1 Non-Mainline Subdivisions <SSI> Appendix I Risk Factor Measurement Thresholds and Risk Ratings I.1 Risk Factor Measurement Thresholds and Risk Ratings <SSI> Appendix J PH MSA Routing Exceptions J.1 PHMSA Routing Exceptions <SSI> RA/LJII'AY Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - x - Appendix K Controlling Locomotives Equipped Per Sub K.1 Controlling Locomotives Equipped Per Sub <SSI> RA/LJII'AY Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - xi - Table of Figures Figure 1 - Program Approach ........................................................................................................... - 5 -  Figure 2 - Program Governance ........................................................................................................ - 6 -  Figure 3 - Topeka Subdivision ........................................................................................................ - 49 -  Figure 4 - Raton Subdivision .......................................................................................................... - 50 -  Figure 5 - Glorieta Subdivision....................................................................................................... - 51 -  Table of Tables Table 1 - Risks to BNSF's Completion and Delivery of PTC Installation by Dec 31, 2015 .......... - 32 -  Table 2 - Number of Wayside Devices per Subdivision ................................................................. - 44 -  RA/LJII'AY Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 1 - 1 Introduction 1.1 Overview The BNSF Railway (BNSF) submits this Positive Train Control Implementation Plan (PTCIP) pursuant to 49 CFR 236 Subpart I (§ 236 Subpart I). In this PTCIP, BNSF sets forth: 1. The method, locations, and sequential order in which BNSF plans to deploy its Positive Train Control (PTC) system. 2. The method by which the PTC system meets the required functionality. 3. The definition of BNSF?s PTC system?s safety as a non-vital overlay per the § 236 Subpart I criteria. 4. For each BNSF subdivision where PTC will be equipped, all main line track segments, method of operation, and the maximum authorized speed(s). 5. The installation risk prioritization methodology used. 6. The plan for equipping BNSF and tenant railroad locomotives to utilize PTC. 7. BNSF?s strategy for meeting the requirement set forth in 49 CFR Section 236.1011(b)(1). 8. Accompanying appendices as appropriate to clarify information. 1.1.1 History BNSF submits this PTCIP pursuant to the mandates to install PTC on certain portions of its system set forth by Congress in section 104 of the Railway Safety Improvement Act of 2008 (RSIA08), Pub.L. 110-432, 122 Stat. 4854 (Oct. 16, 2008) (codified at 49 U.S.C. Sec. 20157, et seq.) and the implementation rule issued by the Federal Railroad Administration (FRA) set forth at 49 CFR Subpart 236.0 et seq. that cumulatively requires PTC deployment on a large portion of the BNSF system. Prior to these actions of Congress and the FRA, BNSF had been proactively developing and implementing a PTC system ? the Electronic Train Management System (ETMS). BNSF developed a form of PTC, the Electronic Train Management System (ETMS) on its own initiative and submitted the system for initial FRA approval in 2003. FRA first reviewed and granted a waiver for BNSF to test ETMS on a certain part of its system in 2004. BNSF received conditional approval to deploy ETMS on certain parts of its system in 2006. BNSF planned to deploy ETMS on its system as conditions warranted, but in any circumstance only planned to deploy ETMS where justified by financial, operational, and safety reasons. BNSF considered ETMS one of a menu of options for enhancing safety; deployment would be a tool with other technology, physical enhancements, capital projects, and general maintenance programs to enhance overall system safety. Even before the enactment of the RSIA08, with its statutory mandate for wide-scale deployment of PTC by the end of 2015, BNSF began working with other railroad stakeholders to deploy ETMS. RA/LJII'AY Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 2 - Importantly, ETMS was developed and designed as a safety overlay, meaning that where it was to be deployed, BNSF would install the ETMS system over, or in addition to, existing methods of operation. BNSF always intended that should ETMS fail or not be deployed on a segment, rail operations would continue and default to the current pre-ETMS operational practices (which FRA has for years found to provide an appropriate level of safety). The ETMS system was designed to include only one locomotive cab display and have no restrictions on the engineer's functions. In the form submitted to the FRA for approval, ETMS was not designed, by itself, to create operational benefits or capacity improvements for BNSF; rather, it was designed only to protect safety in existing operations. The RSIA08 required that a fully-operational PTC system be deployed on thousands of miles of railroad lines with full interoperability and functionality, regardless of the operational or cost considerations that would have guided BNSF?s voluntary deployment of ETMS. In implementing the RSIA08, FRA by rule has interpreted the RSIA08 PTC deployment provisions as requiring installation of PTC on a significantly larger amount of rail lines than would have been necessary by other interpretations of the RSIA08. As is discussed below, BNSF believes that the FRA?s expansive interpretation will result in significant unintended consequences and may have the ultimate effect of reducing, rather than increasing, rail safety. BNSF therefore believes that the FRA should implement the RSIA08 in a manner that requires PTC to be installed on lines that carry passenger trains and Toxic Inhalation Hazard (TIH) / Poison by Inhalation Hazard (PIH) freight traffic and use its reserved authority to relieve the requirements to install PTC on certain routes; for example, on lines that will no longer carry TIH/PIH traffic after BNSF applies the recently promulgated Pipeline and Hazardous Materials Safety Administration's (PHMSA) routing analysis to select the safest and most secure route (see 49 CFR 172.820). 1.1.2 Capital Resource Diversion and Operational Impacts BNSF is concerned that deploying PTC in the scale and scope mandated by the FRA would have unintended consequences on freight railroad capital spending, on system operations, and potentially on overall system safety.  By the FRA?s own calculations in the rule implementing  the PTC provisions of the RSIA08, installation of PTC will require the expenditure of $22 for every $1 of benefit (safety or otherwise). Furthermore, using FRA?s publicly-available numbers shows that the cost benefit ratio for BNSF rises to 34 to 1 for PTC installation on lines of road where TIH/PIH shipments are not expected to move after the Congressionally-mandated implementation date. BNSF believes that these cost-benefit ratios understate the true cost of PTC deployment. BNSF also believes that the FRA has not fully considered that the costs associated with unwarranted PTC deployment will be ultimately borne by freight shippers, which could have the effect of diverting traffic to the highways, a mode that is decidedly less safe and inconsistent with good public policy. RA/LJII'AY Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 3 - Each year BNSF makes significant investments to keep its physical plant in the best operating condition for safe and secure freight operations. In fact, the BNSF physical plant is in the best condition in its modern history as a result of BNSF?s continued high level of capital investments  even during this recent period of reduced volumes. BNSF is concerned that financing this unprecedented PTC expense may have the effect of forcing BNSF to divert scarce capital resources from the baseline maintenance of the railroad as well as potentially jeopardize other investments that could have significantly more benefit for society including capacity expansion projects that could attract more freight to move by rail, the purchase of cleaner-burning new locomotives, further development of hybrid technology, and numerous other capital, maintenance, and safety projects. Large capital reallocation on the scale of PTC should not be done without a full understanding of whether such capital reprogramming will inevitably lead to unintended consequences. In addition to the substantial expenditure of capital resources required to support this mandate, BNSF is concerned about several significant and unintended negative operational impacts that flow from this regulation. First, if a locomotive fails to initialize at its initial terminal, BNSF will be required to identify an alternate locomotive that is appropriately equipped to place in the lead position. To ensure system performance, BNSF will need to maintain additional locomotives as a contingency for potential equipment failures. BNSF believes that the unprecedented step of keeping this safety net in place will require additional capital and reduced efficiency in our locomotive utilization. Second, and perhaps of greater concern, is the possibility of operational impacts caused by the en route failure of locomotive equipment. Under the regulation, equipment failures will have impacts to system traffic beyond what BNSF anticipated in development of ETMS; for example, the restrictions placed on movement speed if a locomotive loses communications capability en route. In deployment prior to this regulation, BNSF has successfully managed these situations through current operating rules and practices to provide for the safe movement of ETMS- equipped trains with en route failures. The FRA regulation requires that these trains be held to restricted speed or to medium speed. As PTC is deployed on some of BNSF?s more heavily- trafficked mainline, the impact from slowing one train to restricted speed has the potential of a ripple effect through our system which will impact our ability to meet customer expectations for transportation by rail and reduce our system capacity, impacting both freight and passenger traffic on the system. BNSF believes that these restrictions represent additional unexpected negative impacts on our system velocity and efficiency that must be recognized when calculating the true cost of this mandate and its impacts on our business model. In order to mitigate these concerns, BNSF believes that FRA should use its discretionary authority to waive the requirements to install PTC on certain routes; for example, on lines that will no longer carry TIH/PIH traffic after BNSF applies the recently promulgated Pipeline and Hazardous Materials Safety Administration (PHMSA) routing analysis to select the safest and most secure route. BNSF understands that a separate waiver request will need to be submitted to address this issue. With respect to TIH/PIH traffic, BNSF believes that through a combination of re-routing this traffic to maximize loads on PTC equipped lines consistent with PHMSA routing requirements and using operational protocols over other lines carrying small amounts of RA/LJII'AY Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 4 - TIH/PIH traffic by the implementation date of December 31, 2015, the overall safety of the freight rail system would be improved, rather than compromised. By BNSF?s own internal estimates, were the FRA to adopt this paradigm, then BNSF?s  deployment of PTC would be reduced by almost one-third while freeing substantial capital for other types of safety and capacity improvements. 1.1.3 Approach to PTC Implementation in Southern California BNSF has made a commitment to certain public entities in the state of California to install the wayside infrastructure portion of a PTC system on certain rail lines that share passenger and freight service in the Los Angeles Basin region of Southern California by December 31, 2012. Although this means that BNSF will have the wayside physical infrastructure in place along the lines by that date, BNSF anticipates that its locomotive fleet will not be fully PTC-equipped until December 31, 2015, and therefore, that PTC will not be fully operational for freight operations on freight rail lines in the Los Angeles Basin earlier than such date. 1.1.4 Organizational Relationships 1.1.4.1 Program Office The Program Office (PO) provides operational oversight of the program and is the definitive resource for project management direction and guidance. The PO does not directly manage projects. A hierarchical view of the relationship between the PO and the Project Managers can be seen in F igure 1 - Program Approach. Specific responsibilities of the PO include: Providing oversight and monitoring of projects/activities within the program Enforcing priorities and approving scope for the program Providing an escalation point for issues, risks, and resources Fostering quick decision making and issue resolution Monitoring/tracking budget 1.1.4.2 Project Managers Project Managers manage their teams? delivery of items and tasks as outlined in the project  charter (see Appendix E - PTC Project Charter Template for an example). They report status to the Program Manager (PM) and facilitate communication, resolve intra-team issues, and report team progress. ? ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 5 - Figure 1 - Program Approach 1.1.4.3 Program ?Working? Steering Committee The Program Steering Committee provides program oversight and serves as an escalation point to resolve issues not resolvable at the program level. F igure 2 - Program Governance shows the Program Escalation Path. The Steering Committee is comprised of stakeholders from internal organizations within BNSF that are required to make the implementation of PTC a successful program. The responsibilities of the Program Steering Committee include, but are not limited to: Monitoring and reviewing the program at regular Program Steering Committee meetings Providing assistance/guidance to the program when required Controlling program scope as emergent issues force changes to be considered, ensuring that scope aligns with program objectives of implementing PTC Resolving program conflicts and disputes and reconciling differences of opinion and approach Providing formal acceptance of program deliverables ? ? ? ? ? Program Office ProgramAVP I ProgramDir Ia -. Audit ITC Commitlee PTC Labor Relations BUdget Goy'tAffairsJReg Signal Training Communications Passenger Telecom Legal Sourcing Org Change Mgt Comms Sys Intgr Mechanical Implementation Project Managers Program CommsSys& IManager(PM) ITCPM's I Signal PM Telecom PM II ImplPM II BkOftIGIS PM II LocoIMech IPM Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 6 - 1.1.4.4 Executive Steering Committee At the highest level, the Executive Steering Committee oversees the program and acts as the decision-maker of last resort, and provides focus, oversight, and strategic guidance and vision to the program. The Executive Steering Committee is comprised of executive level stakeholders from internal organizations within BNSF that are required to make the implementation of PTC a successful program. The responsibilities of the Executive Steering Committee include, but are not limited to: Ensuring that the PTC program is consistent with BNSF?s goals and objectives Providing advice and evaluating mission critical issues Providing strategic input on program objectives Figure 2 - Program Governance 1.1.5 Request for Amendment of a PTCIP [§ 236.1009(a)(2)(ii)] This subsection describes how the railroad will make and file a Request for Amendment (RFA) of its PTCIP in accordance with § 236.1021. ? ? ? Executive steering Committee Program "Working" Steering Committee Functional Area AVP's and VP's Program Office D Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 7 - When a routing change affecting annual Million Gross Tons (MGT), TIH/PIH traffic levels, or other operational change as called out under § 236.1009(a)(2)(ii) prompts an RFA of the PTCIP to be drawn up as a part of its review and approval process, BNSF will take the following steps: 1. The RFA will be drawn up for internal review. Once an initial draft is published, the review/approval cycle will begin. 2. The Program Office and Program Steering Committee will be responsible for reviewing the RFA to ensure that all items described in § 236.1021(d) are present when applicable. All review comments of the draft will be documented in an internal review log. 3. After the reviewers have had at least one week to review the draft RFA, the process of addressing and displacing comments from the review log will begin. 4. Once all comments from the review log have been addressed and displaced, the review log and updated draft RFA will be re-distributed to the Program Office and Program Steering Committee for a final review. 5. If no new comments are added, the RFA and updated PTCIP will be finalized and submitted to FRA via two methods: a. Three hard copies of each will be sent to the FRA (full version, redacted version, and a delta version that highlights any redacted sections) b. Three soft copies of each will be placed on the FRA?s SharePoint site Document version control will be provided by using an internal BNSF SharePoint site. 1.2 Goals and Objectives The primary goal of implementing BNSF?s PTC solution on its network, as required by the RSIA08, is to prevent train-to-train collisions, overspeed derailments, incursions into established work zone limits, and the movement of a train through a switch left in the wrong position. BNSF will have its PTC safety overlay system (ETMS) installed and interoperable by December 31, 2015. Further goals and objectives are discussed below. 1.2.1 Performance The PTC system?s deployment will adhere to the PTC System Certification requirements detailed in § 236.1015. 1.2.2 Quality As defined in § 236.1001, an acceptable level of safety will be maintained in the development, functionality, architecture, installation, implementation, inspection, testing, operation, maintenance, repair, and modification of the PTC system. RA/LJII'AY Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 8 - To ensure that an acceptable level of safety is achieved, BNSF will follow the methodologies and activities outlined in its ETMS Product Safety Plan (PSP) V3.0 submittal of February 18, 2010 (approval pending). As outlined in § 236.1015(b)(2), BNSF will also ensure that all vendors from whom PTC technologies are to be acquired have an acceptable quality assurance program for both design and manufacturing processes. 1.2.3 Technical The PTC system will provide for interoperability between BNSF and all of its tenant railroads. Technical, semantic, and organizational interoperability will be achieved to enhance the ability of BNSF and its tenants to operate together safely. Interoperability between BNSF and its tenants will be achieved though product testing, industry partnership, use of common technology, and standard implementation. BNSF will work closely with its tenants throughout the PTC deployment process to ensure that all aspects of interoperability are fully addressed. This partnership will be ongoing as the tenant railroads proceed to operate on the equipped portions of BNSF?s network. 1.2.4 Coverage Pending the outcome of BNSF?s waiver request, as described in Section 1.1.2 - Capital Resource Diversion and Operational Impacts, and 220 MHz radio availability, BNSF will have the following coverage goals: BNSF will have ETMS installed, operational, and interoperable on 118 (60%) of its 198 subdivisions by December 31, 2015. BNSF will have ETMS installed, operational, and interoperable on 18,445 (82%) of its 22,386 owned route miles by December 31, 2015. Of the 18,445 route miles to be equipped, 5,972 miles (27%) contain passenger traffic. Of the 18,445 route miles to be equipped, 18,445 miles (100%) contain TIH/PIH traffic. 1.3 Success Criteria This section of the PTCIP calls out the metrics that will be applied to gauge the success of long- term and intermediate implementation goals. Based on the request by BNSF for the FRA to use its discretion to waive the requirements to install PTC on certain routes, these metrics are given under pre-waiver conditions. For clarification, when referred to in this section, long-term goals refer to BNSF?s implementation milestones from a system point of view. Intermediate goals refer to BNSF?s implementation milestones from a subdivision point of view. ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 9 - 1.3.1 Long-term Goal Metrics To gauge long-term goals, BNSF will use the following metrics for system PTC implementation and locomotive installation. A definition of long-term goals for PTC Safety Plan (PTCSP) submittal and PTC System Certification are also included. The remaining metrics will be on a subdivision-to-subdivision basis and are described in Section 1.3.2 - Intermediate Goal Metrics. . 1.3.1.1 System PTC Implementation A subdivision will be considered complete when PTC System Certification is received by BNSF as detailed in § 236.1015(a). Pending the outcome of BNSF?s waiver request, as  described in Section 1.1.2 - Capital Resource Diversion and Operational Impacts, and 220 MHz radio availability, BNSF will have the following system implementation goals: 2011 - 1 of 118 subdivisions have completed PTC implementation - 0.8% 2012 - 31 of 118 subdivisions have completed PTC implementation - 26.3% 2013 - 55 of 118 subdivisions have completed PTC implementation - 46.6% 2014 - 80 of 118 subdivisions have completed PTC implementation - 67.8% 2015 - 118 of 118 subdivisions have completed PTC implementation - 100% As called out in § 236.1009 (a)(2)(ii), BNSF will file an RFA if any subdivision is added, removed, or modified. 1.3.1.2 Locomotive Installation Since BNSF does not assign its locomotives per subdivision, it is appropriate to consider the equipping of rolling stock as a long-term goal. BNSF will equip 2,000 of its locomotives with PTC. Details of BNSF?s plan for the progressive equipping of rolling stock, as required by §236.1006(b)(1),(2), on PTC territory, can be found in Appendix K .1 ? Controlling Locomotive Equipped Per Sub. Pending the outcome of BNSF?s waiver request, as described in Section 1.1.2 - Capital Resource Diversion and Operational Impacts, and 220 MHz radio availability, BNSF will have the following locomotive installation goals: 2011 - 319 of 2,000 locomotives have completed PTC implementation - 15.9% o 3 of 319 PTC equipped locomotives will be operating on PTC equipped territory ? 0.9% 2012 - 619 of 2,000 locomotives have completed PTC implementation - 31% ? ? ? ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 10 - o 256 of 619 PTC equipped locomotives will be operating on PTC equipped territory ? 41.4% 2013 ? 1,019 of 2,000 locomotives have completed PTC implementation - 51% o 640 of 1,019 PTC equipped locomotives will be operating on PTC equipped territory ? 62.8% 2014 ? 1,575 of 2,000 locomotives have completed PTC implementation - 78.8% o 1,180 of 1,575 PTC equipped locomotives will be operating on PTC equipped territory ? 74.9% 2015 ? 2,000 of 2,000 locomotives have completed PTC implementation - 100% o 2,000 of 2,000 PTC equipped locomotives will be operating on PTC equipped territory ? 100% BNSF?s General Director of Locomotive Maintenance & Repair and appropriate Manager Mechanicals are responsible for achieving the progressive implementation and deployment of PTC-equipped rolling stock. On an average day, BNSF runs 1300 trains system-wide. BNSF?s proposed implementation plan of 118 subdivisions composes approximately 80% of those trains. This correlates to an average of 1040 trains on PTC territory. Given BNSF?s locomotive installation goal of 2000 PTC equipped locomotives, this leaves BNSF 960 PTC equipped locomotive, per day, for staging, maintenance, and repairs. The locomotive onboard installation is made more expensive and further complicated by FRA?s inclusion of a requirement for a second screen in the locomotive cab. BNSF has operated, with FRA?s approval and without a mishap, thousands of ETMS-equipped trains without such a screen thus establishing the lack of need for this requirement.  FRA?s belief that  railroads may find some future business benefit, possibly to enhance operations or handle mandatory directives, should be handled when and if such applications become a reality. BNSF believes that the second screen requirement is yet another added expense to the PTC deployment costs with no corresponding safety benefit. BNSF is also concerned that this requirement may represent an attempt to unnecessarily affect labor management relations and collective bargaining agreements. 1.3.1.3 Amended PTCSP Submitted As set forth in § 236.1015, BNSF will submit an amended PTCSP in order to address incremental changes required for interoperability as described in the Request for Expedited ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 11 - Certification (REC) submitted on April 13, 2010. This long-term goal will be considered complete once the amended PTCSP has been submitted to the FRA. 1.3.1.4 Request for Expedited Certification Submitted BNSF has, in accordance with § 236.1031(a), submitted a Request for Expedited Certification (REC) letter to the FRA on April 13, 2010. This letter referenced BNSF?s ETMS PSP V3.0 submitted on February 18, 2010, and included the information required under §236.1031(a)(1). 1.3.1.5 PTC System Certification Received § 236.1015(a) states that the ?receipt of a PTC System Certification affirms that the PTC  system has been reviewed and approved by the FRA in accordance with, and meets the requirements of, this part.?  Once BNSF receives the PTC System Certification, the  configuration will be considered operational. 1.3.2 Intermediate Goal Metrics Intermediate goals will refer to those milestones that can best be used on a subdivision-to- subdivision basis. When all of these intermediate goals have been completed, a subdivision will be considered cut over to PTC operations. 1.3.2.1 Infrastructure Installation Completed Infrastructure installation for a subdivision will be completed when the following have been installed and tested for functionality: 100% of the communication system 100% of the track infrastructure 100% of the waysides ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 12 - 1.3.2.2 Geographic Information System (GIS) Validated Each subdivision has two intermediate goals that are a result of Geographic Information System (GIS) data. GIS data will be considered validated for a subdivision when the following are completed: Track survey completed Track database validated and verified 1.3.2.3 Field Testing Completed The completed field testing will conform with § 236.1015(d)(10). This testing will be made up of the following: Host railroad PTC operation Interoperable PTC functionality 1.3.2.4 Training Plan Implementation As an intermediate goal, the training plan will be implemented to assure 100% of BNSF employees are trained prior to performing PTC service. Field and office maintenance personnel, as described in § 236.1041(a)(1), for this subdivision have completed training in accordance with §§ 236.1039 through 236.1045. Dispatchers, as described in § 236.1041(a)(2), for this subdivision have completed training in accordance with §§ 236.1039 through 236.1045. Persons who operate trains or serve as a train or engine crew, as described in § 236.1041(a)(3), for this subdivision have completed training in accordance with §§ 236.1039 through 236.1045. Roadway workers, as described in § 236.1041(a)(4), for this subdivision have completed training in accordance with §§ 236.1039 through 236.1045. Direct supervisors, as described in § 236.1041(a)(5), for this subdivision have completed training in accordance with §§ 236.1039 through 236.1045. ? ? ? ? ? ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 13 - 1.4 Applicability This section provides the pertinent information for the railroad's rail network for the purpose of PTC implementation. Designation of non-main line subdivisions can be found in detail in Section 3.1 - Non-Mainline Subdivisions. Non-main line subdivisions are defined as those subdivisions that do not meet the parameters described in § 236.1003 and § 236.1005(b)(1)(i and ii). All subdivisions that meet the parameters in § 236.1005(b)(1)(i and ii) are considered main line for PTC installation as defined in § 236.1003, and, along with associated traffic densities and risk analysis, can be found in Appendix D - PTC Implementation Plan and Appendix F - Risk Analysis by Subdivision. For the purpose of risk analysis, baseline densities were set to calendar year 2008 numbers. 1.5 Document Overview This section provides an overview of the organization of the PTCIP, which BNSF has developed as required by 49 U.S.C. § 20157 and § 236.1005. Section 1 describes the general objectives, applicability, and scope of the document. Section 2 lists applicable documents referenced in this PTCIP. Section 3 identifies which track segments the railroad designates as main line and non-main line track, as required by § 236.101l(a)(8). Section 4 describes the functional requirements that the PTC system meets as required by § 236.1011(a)(l). Section 5 describes how BNSF will comply with § 236.1009(c) as required by § 236.1011(a)(2). Section 6 defines how BNSF will provide for interoperability between itself and all tenant railroads as required by § 236.1011(a)(3). Section 7 describes how the PTC system will be implemented to address areas of greater risk to the public and railroad employees before areas of lesser risk by evaluating multiple risk factors as required by § 236.101 l(a)(4). Section 8 defines the sequence, schedule, and decision basis for the line segments to be equipped, including the risk factors by line segment, as required by § 236.101 l(a)(5). Section 9 identifies the rolling stock that will be equipped with PTC technology, as required by § 236.1011(a)(6), and defines a schedule for same. ? ? ? ? ? ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 14 - Section 10 identifies the number of wayside devices required for each subdivision and the schedule to complete the installations by December 31, 2015, as required by § 236.1011(a)(7). Section 11 identifies and describes BNSF?s basis for determining that the risk-based prioritization in Section 7 above is not practical as required by § 236.101l(a)(9). Section 12 contains the strategy for full system-wide deployment of BNSF?s PTC system beyond those line segments required to be equipped under § 236 Subpart I, including the criteria that will be applied in identifying those additional lines. Section 13 identifies the three track segments for which BNSF is filing a Main Line Track Exclusion Addendum (MTEA) as required by §236.1019(c)(3). 1.6 Acronyms and Definitions This section will include definitions of all terms, abbreviations, and acronyms required to properly interpret the PTCIP. The following is a list of abbreviations and acronyms used in the PTCIP. A C R O N Y M D E F INI T I O N AAR American Association of Railroads ABS Automatic Block Signal ATS Automatic Train Stop BNSF BNSF Railway Company CFR Code of Federal Regulations CTC Centralized Traffic Control ETMS Electronic Train Management System FRA Federal Railroad Administration GIS Geographic Information System HMI Human Machine Interface ID Identification ITC Interoperable Train Control MGT Million Gross Tons MHz Megahertz MPH Miles per Hour MTEA Main Line Track Exclusion Addendum ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 15 - A C R O N Y M D E F INI T I O N NCS Network Control Systems NPI Notice of Product Intent PMHSA Pipeline and Hazardous Materials Safety Administration PIH Poison by Inhalation Hazard PM Program Manager PO Program Office PSP Product Safety Plan PTC Positive Train Control PTCDP PTC Development Plan PTCIP PTC Implementation Plan PTCSP PTC Safety Plan REC Request for Expedited Certification RFA Request for Amendment RSIA08 Rail Safety Improvement Act of 2008 TBC To Be Configured TIH Toxic Inhalation Hazard Wabtec Westinghouse Air Brake Technologies Corporation WIU Wayside Interface Unit WRE Wabtec Railway Electronics The following is a list of terms and definitions used in the PTCIP. A BS Automatic Block Signal system, a series of consecutive blocks governed by block signals, cab signals, or both, actuated by a train or engine or by certain conditions affecting the use of a block. Class 1 Railroad A railroad which, in the last year for which revenues were reported, exceeded the threshold established under regulations of the Surface Transportation Board (49 CFR part 120.1-1 (2008)). C rossing Point of intersection at grade between two tracks belonging to the same or different railroads. RA/LJII'AY Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 16 - C T C Centralized Traffic Control, a block system operated from a dispatching office using block signal indications to authorize train movements. E T MS Electronic Train Management System, used to refer to the railroad safety-overlay system developed jointly by BNSF and Wabtec for a pilot implementation on the Beardstown subdivision in Illinois. G IS Geographic Information System, a collection of computer hardware, software, and geographic data for capturing, storing, updating, manipulating, analyzing, and displaying all forms of geographically referenced information. Host Railroad The railroad that has effective operating control over a segment of track. Interoperability ETMS capability allowing trains equipped with the same or similar systems to operate on different railroads interchangeably and automatically without hindrance, delay, or additional on-board equipment, including uninterrupted movements over property boundaries. Locomotive Engineer A qualified person who is currently certified pursuit to 49 CFR Part 240. Main L ine Except as excepted pursuant to § 236.1019 or where all trains are limited to restricted speed, a segment or route of railroad tracks, including controlled sidings: 1) Of a Class I railroad, as documented in current timetables filed by the Class I railroad with the FRA under § 217.7, over which 5,000,000 or more gross tons of railroad traffic is transported annually; or 2) Used for regularly scheduled intercity or commuter passenger service, as defined in 49 U.S.C. § 24012, or both. Methods of Operation Track Warrant Control (TWC) with non-signal and Automatic Block Signal (ABS) applications, Centralized Traffic Control (CTC), or other operation types that generate mandatory directives. M T E A Main Line Track Exclusion Addendum, the document further described in § 236.1019. RA/LJII'AY Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 17 - N CS BNSF's Network Control Systems, the group responsible for the operation and maintenance of BNSF's NOC networks. Non-Signaled Ter ritory Track without signals, over which train movements are governed by timetable, track warrants, or operating rules; aka dark territory. NPI Notice of Product Intent as further described in § 236.1013. Overlay A system that does not constitute any part of the method of operation, but maintains safe system operation should any one of the safety-critical functions be omitted or not performed correctly. PT C Positive Train Control, as further described in § 236.1005. PT C DP PTC Development Plan, as further described in § 236.1013. PT C IP PTC Implementation Plan, as required under 49 U.S.C. § 20157 and further described in § 236.1011. PT CSP PTC Safety Plan as further described in § 236.1015. PT C Railroad Each Class I railroad and each entity providing regularly scheduled intercity or commuter rail passenger transportation required to implement and operate a PTC system. PT C System Certification Certification as required under 49 U.S.C. § 20157 and further described in § 226.1009 and § 236.1015. R F A Request for Amendment, a request for an amendment of a plan or system made by a PTC- equipped railroad in accordance with § 236.1021. RA/LJII'AY Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 18 - Safety C ritical Applies to any function or system, the correct performance of which is essential to the safety of personnel and/or equipment, or the incorrect performance of which could cause a hazardous condition or allow a hazardous condition that was intended to be prevented by the function or system to exist. Tenant Railroad A railroad, other than a Host Railroad, operating on track upon which a PTC system is required. T rack Database Database containing locations and attributes of track over which trains are subject to location tracking and enforcement. T W C Track Warrant Control, a method of authorizing train movements or protecting track forces on a main track within specified limits in a territory so designated in the timetable. Validation The process of determining that a system is appropriate for its purpose. Verification The process of determining that a system or module meets its designed specification. Wayside Interface Unit An electronic component that interfaces ETMS to a field (wayside) device. RA/LJII'AY Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 19 - 2 Applicable Documents This section provides a complete list of all documents and other sources referenced in this PTCIP. 49 CFR Part 236 Subpart I - Final Rule, January 15, 2010 49 CFR Part 236 Subpart H, March 5, 2005 BNSF?s Electronic Train Management System Product Safety Plan 3.0, February 12, 2010 BNSF's Request for Expedited Certification (REC), April 13, 2010 BNSF Subdivision Timetables Railway Safety Improvement Act of 2008 (RSIA08), Pub.L. 110-432, 122 Stat. 4854 (Oct. 16, 2008) (codified at 49 U.S.C. Sec. 20157, et seq.) ? ? ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 20 - 3 Designating Track as Main Line or Non-Main Line [§ 236.1011(a)(8)] This section provides the track segments the railroad identifies as main line and non-main line track. BNSF?s PTCIP includes Main Line Track Exclusion Addendums (MTEAs), as defined by § 236.1019 in Section 3 - Designating Track as Main Line or Non-Main Line [§ 236.1011(a)(8)]. BNSF?s territory is subdivided into 198 subdivisions. Boundaries for each subdivision are defined in their appropriate timetable. The limits of PTC installation on a particular subdivision are called out in the Limits column in Appendix D - Implementation Plan. The parameters described in § 236.1003 and § 236.1005(b)(1)(i and ii) were used to designate track as main line or non-main line. In § 236.1005(b)(1)(i and ii), the rail lines required to be equipped are defined as follows: ?§ 236.1005 Requirements for Positive Train Control systems   (b) PTC system installation.   (1) Lines required to be equipped.  Except as otherwise provided in this subpart, each Class  I railroad and each railroad providing or hosting intercity or commuter passenger service  shall progressively equip its lines as provided in its approved PTCIP such that, on and after  December 31, 2015, a PTC system certified under § 236.1015 is installed and operated by  the host railroad on each:  (i) Main line over which is transported any quantity of material poisonous by  inhalation (PIH), including anhydrous ammonia, as defined in §§ 171.8, 173.115 and  173.132 of this title;  (ii) Main line used for regularly provided intercity or commuter passenger service,  except as provided in § 236.1019??  Based on the above rule, each track segment was evaluated according to the following four conditions: 1. BNSF is the host railroad defined in § 236.1003 as follows, ?Host railroad means a railroad that has effective operating control over a segment of track.?, and 2. The subdivision meets the definition for main line track as provided in § 236.1003 such that: A. No restriction exists requiring all trains to operate at restricted speed within the boundaries of the subdivision, and; I. More than 5 million gross tons of railroad traffic were transported within the boundaries of the subdivision during calendar year 2008; or RA/LJII'AY Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 21 - II. The subdivision was used for regularly scheduled intercity or commuter rail passenger service. If the above conditions #1 and #2 were determined to exist for a subdivision, and if either one (or both) conditions #3 or #4 below were also determined to be true, the subdivision was categorized as main line, requiring the implementation of PTC. 3. Any quantity of TIH/PIH material was transported on the subdivision during calendar year 2008, and/or 4. The subdivision was used for regularly scheduled intercity or commuter passenger service during calendar year 2008. After evaluating each subdivision according to these four conditions: 80 subdivisions were determined to be not main line 118 subdivisions were determined to be main line and require the implementation of PTC under the regulation o 93 subdivisions as required under the regulation to have PTC installed on applicable tracks over their entirety o 25 subdivisions as required under the regulation to have PTC installed over partial subdivision limits ? 3 subdivisions as required under the regulation to have PTC installed on two non-consecutive track segments each Appendix D - PTC Implementation Plan and Appendix F - Risk Analysis by Subdivision list the 118 subdivisions designated as main line. Traffic densities and risk analysis information are provided in detail in these sections. 3.1 Non-Mainline Subdivisions Appendix H .1 ? Non-Mainline Subdivisions contains a detailed list of the 80 subdivisions designated as non-main line and specifies the conditions met by each track segment in making this designation. ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 22 - 4 Technology [§ 236.1011(a)(l)] § 236.1011(a)(1) requires that the PTCIP describe the functional requirements the proposed PTC system must meet. In lieu of a PTC Development Plan (PTCDP), BNSF will submit an REC to address interoperable functionality of ETMS. This REC (along with BNSF?s previously-submitted PSP of February 18, 2010) describes how ETMS satisfies the mandated requirements for PTC systems as outlined in § 236.1005. On April 13, 2010, the REC prepared by BNSF was submitted to the FRA for review and approval. This REC sought to gain approval of ETMS I and II configurations under Subpart I. BNSF?s REC describes development of the ETMS interoperable PTC system developed in compliance with requirements and standards defined through the Interoperable Train Control (ITC) industry effort. ETMS is a locomotive-centric train control system designed to be overlaid on existing methods of operation and provide a high level of railroad safety through enforcement of a train?s authorized operating limits, including protection against train-to-train collisions, derailments due to overspeed, unauthorized incursions into work zones, and operation through main track switches in improper position. ETMS is designed to support different railroads and their individual methods of operations and is intended to be implemented across a broad spectrum of railroads without modification. This design approach supports interoperability across railroads as ETMS- equipped locomotives apply consistent warning and enforcement rules, regardless of track ownership.  An overview of ETMS, its primary functions, PTC system architecture, and a high-level description of the functionality of the PTC system, subsystems, and interfaces are found in BNSF?s PSP  submittal dated February 18, 2010. Specifically, these areas are addressed in the following sections: Part I I - System Description & A rchitecture, which provides a complete description of the ETMS system, including a list of all product components and their physical relationships in the subsystem or system as required by § 236.1013(a)(1) through (3). 12.1 Locomotive Segment 12.2 Office Segment 12.3 Communications Segment 12.4 Wayside Segment 13.0 Functional Overview 14.0 Concept of Operations 15.0 Railroad Operational Applicability 16.0 Back-up Modes RA/LJII'AY Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 23 - Part I I I - System Safety Process and Analyses, which describes how ETMS architecture satisfies safety requirements as required by § 236.1013(a)(4). 17.0 System Safety Process 18.0 Preliminary Hazard Assessment 19.0 Hazard Log 20.0 Fault Tree Analysis 21.0 Failure Mode and Effect Analysis 22.0 Supporting Analyses 23.0 Safety Requirements 24.0 Safety Assurance Concepts 25.0 Base Case The Concept of Operations as required by § 236.1013(a)(3) is covered in Section 14.0 - Concept of Operations of BNSF?s PSP submittal. The detailed Concept of Operations document is provided as Appendix G .1 - Concept of Operations of that PSP submittal. While the entire Concept of Operations provides a thorough understanding of the system?s ability to meet the requirements, for  the purpose of this document, each requirement will be addressed with a reference within the ETMS Concept of Operations as follows: § 236.1005 Requirements for Positive T rain Control systems. (a) PTC system requirements. Each PTC system required to be installed under this subpart will: (1) Reliably and functionally prevent: (i) Train-to-train collisions?including collisions between trains operating over rail-to- rail at-grade crossings ? Section 3.3.2 Wayside Segment Section 3.4.2 T rain Movements Section 3.4.3 T rain-to-T rain Proximity A lerts Section 3.4.4 Speed Restrictions Section 3.4.5 Speed Enforcements Section 3.4.6 Switch Enforcements Rail-to-rail crossings at grade that have one or more PTC routes intersecting with one or more routes without a PTC system must have an interlocking signal arrangement (developed in accordance with 49 CFR 236 Subparts A through G) in place and a PTC-enforced stop on all PTC routes. FRA has also determined that the level of risk varies based upon the speeds at which the trains operate through such crossings, as well as the presence, or lack, of PTC-equipped lines leading into the crossing. Accordingly, if the maximum speed on at least one of the intersecting tracks is more than 40 miles per hour, then the routes without a PTC system must also have either some type of positive stop enforcement or a split-point derail on each approach to the ? ? ? ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 24 - crossing (incorporated into the signal system), and a permanent maximum speed limit of 20 miles per hour. (ii) Overspeed derailments, including derailments related to railroad civil engineering speed restrictions, slow orders, and excessive speeds over switches and through turnouts; Section 3.3.2 Wayside Segment Section 3.4.2 T rain Movements Section 3.4.4 Speed Restrictions Section 3.4.5 Speed Enforcements (iii) Incursions into established work zone limits without first receiving appropriate authority and verification from the dispatcher or roadway worker in charge, as applicable and in accordance with 49 CFR part 214. Section 3.4.2 T rain Movements Section 3.4.4 Speed Restrictions (iv) The movement of a train through a main line switch in the improper position as further described in § 235.1005(e). Section 3.3.2 Wayside Segment Section 3.4.2 T rain Movements Section 3.4.6 Switch Enforcement (2) Include safety-critical integration of all authorities and indications of a wayside? or other similar appliance, method, device, or system of equivalent safety, in a manner by which the PTC system will provide associated warning and enforcement to the extent and except as described and justified in the FRA-approved PTCDP or PTCSP, as applicable; Section 3.3.2 Wayside Segment Section 3.4.2 T rain Movements Section 3.4.3 T rain-to-T rain Proximity A lerts Section 3.4.4 Speed Restrictions Section 3.4.5 Speed Enforcements Section 3.4.6 Switch Enforcements (4) Provide an appropriate warning or enforcement when: (i) A derail or switch protecting access to the main line required by § 236.1007 or otherwise provided for in the applicable PTCSP is not in its derailing or protecting position, respectively; Section 3.4.2.1.4 Entry to Signaled Ter ritory between Signals Section 3.4.6 Switch Enforcement (ii) A mandatory directive is issued associated with a highway-rail grade crossing warning system malfunction as required by § 234.105, § 234.106, or § 234.107; Section 3.4.4.4 C rossing and Speed Tags ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 25 - (iii) An after-arrival mandatory directive has been issued and the train or trains to be waited on has not yet passed the location of the receiving train; Section 3.4.2 T rain Movements (iv) Any movable bridge within the route ahead is not in a position to allow permissive indication for a train movement pursuant to § 236.312; and Section 3.3.2 Wayside Segment All movable bridges on BNSF?s territory are protected by vital signals. These signals provide the necessary aspect to effectively protect a misaligned movable bridge for PTC-equipped locomotives. BNSF will provide more detail on this functionality in its amended PTCSP. (v) A hazard detector integrated into the PTC system that is required by paragraph (c) of this section, or otherwise provided for in the applicable PTCSP, detects an unsafe condition or transmits an alarm; and Section 3.3.2 Wayside Segment All hazard detectors as described in § 236.1005(c) on BNSF?s territory are protected by vital signals. These signals provide the necessary aspect to effectively protect a hazard for PTC-equipped locomotives. BNSF will provide more detail on this functionality in its amended PTCSP. (5) Limit the speed of passenger and freight trains to 59 miles per hour and 49 miles per hour, respectively, in areas without broken rail detection or equivalent safeguards. Section 3.4.4 Speed Restrictions Section 3.4.5 Speed Enforcements ? ? ? ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 26 - 5 Compliance [§ 236.1011(a)(2)] This section describes how BNSF intends to comply with § 236.1009(d), which requires BNSF to apply for and receive PTC System Certification from the FRA. PTC System Certification must be received before deploying a PTC system in revenue service on a railroad. This section describes any identified or potential risks or other items that could create or suggest increased difficulty in the successful completion and delivery of the PTC system installation on or prior to the required date. It also identifies any contingency plans that have been formulated to deal with the risks. Risks are created when assumptions are not met. As risks are identified, consequences associated with risks are also identified. To achieve FRA certification, BNSF will: File an REC as described in § 236.1031(a)(1) along with the information required to consider it an approved PTCDP. Supply deliverables similar to what it has submitted in two previous PSPs to support a petition for certification of the PTC system. File an abbreviated PTCSP for interoperable ETMS. This PTCSP will reference BNSF?s  previous PSPs where appropriate. 5.1 Risks to Meeting Required PTC Installation Date BNSF has implemented a risk management process to identify, mitigate, and monitor risks that could create or suggest increased difficulty in the successful completion and delivery of the PTC system installation on or prior to the required date. This risk management process: Identifies risks to meeting the goals and objectives of BNSF's PTC deployment Predicts consequences associated with risks Implements risk mitigation strategies Monitors risk status Establishes contingency plans Table 1 - Risks to BNSF 's Completion and Delivery of PTC Installation by Dec 31, 2015 below lists each identified risk to BNSF's completion and delivery of PTC installation on or prior to December 31, 2015, its associated goal/objective category, the predicted consequences of the risk should it occur, BNSF's mitigation/containment strategy, and contingency plans. ? ? ? ? ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 27 - Risk ID Objective/Goal Category Risk Descr iption Predicted Consequences Risk Mitigation Contingency Plan 1 Performance: Enhance system safety, with particular focus on the prevention of train-to-train collisions, overspeed derailments, incursions into established work zone limits, and movement of trains through improperly- positioned switches. PTC system does not enhance system safety: Does not prevent train- to-train collisions Does not prevent overspeed derailments Does not prevent incursions into established work zone limits Does not prevent movement of trains through improperly positioned switches Creates additional safety hazards that reduce system safety An acceptable level of safety is not maintained in the development, functionality, architecture, installation, implementation, inspection, testing, operation, maintenance, repair, and modification of the PTC technologies to be deployed. PTC system cannot be deployed without modification of system behavior. PTC system cannot be deployed without re- assessment of achieved safety levels. Deployed PTC system can not obtain FRA Certification Schedule delay Follow system development methodology that captures PTC system requirements and provides traceability of those requirements throughout the system life cycle. Rigorous safety program at all levels of system development. Methodologies and activities as required by § 236.1015 will be followed in the PTCSP. Existing method of operation can be maintained during/after PTC installation until acceptable safety levels have been achieved and FRA Certification has been granted. ? ? ? ? ? ? ? ? ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 28 - Risk ID Objective/Goal Category Risk Descr iption Predicted Consequences Risk Mitigation Contingency Plan 2 Coverage: Enhancements to system safety will be achieved as a PTC safety overlay system is progressively deployed across all portions of the BNSF network for which PTC deployment is required by § 236.1005(b). PTC system progressive installation is delayed because of PTC equipment availability Availability of trained installers Ineffective coordination of installation plans result in interference between installation crews where infrastructure is complex and/or working space is limited Installation procedures become protracted Acts of nature PTC system will not be installed across all portions of the BNSF network for which PTC deployment is required by § 236.1005(b) Full benefit of safety enhancements will not be realized by required date BNSF may incur civil penalties Develop detailed plans for equipping rolling stock, wayside, and office with required PTC equipment. Develop detailed training and personnel plans. Work closely with vendors and other railroads in close geographic proximity to minimize risk associated with installation procedures and scheduling. Establish schedule performance metrics to measure PTC deployment progress. Monitor metrics to identify any potential schedule delays. Take action to avert potential schedule delays. Existing method of operation can be maintained during/after PTC installation until acceptable safety levels have been achieved and FRA Certification has been granted. ? ? ? ? ? ? ? ? ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 29 - Risk ID Objective/Goal Category Risk Descr iption Predicted Consequences Risk Mitigation Contingency Plan 3 Coverage: All required portions of the network to be fully equipped, operational, and interoperable with all tenant railroads by December 31, 2015. All required portions of the network are not fully equipped, operational, and interoperable with all tenant roads by December 31, 2015. Unable to maintain equipage schedule Delay in initiating PTC operations Difficulty and/or delay in establishing required interoperability agreements with tenant railroads. Difficulty and/or delay in achieving required levels of technical interoperability PTC system will not be installed across all portions of the BNSF network for which PTC deployment is required by § 236.1005(b) Full benefit of safety enhancements will not be realized by required date BNSF may incur civil penalties See Risk Mitigation Strategy for risk #2 above. Establish clear understanding of technical requirements and schedule for interoperability with each tenant road. Establish performance metrics to measure tenant progress toward equipping rolling stock with interoperable PTC equipment. Existing method of operation can be maintained during/after PTC installation until acceptable safety levels have been achieved and FRA Certification has been granted. ? ? ? ? ? ? ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 30 - Risk ID Objective/Goal Category Risk Descr iption Predicted Consequences Risk Mitigation Contingency Plan 4 Performance & Quality: PTC deployment will meet the PTC System Certification performance requirements in § 236.1015. The methodologies and activities required by § 236.1015 are not applied consistently for the PTCSP Gaps in the V&V process are uncovered that impact the validity of testing results; or, at worst, the design of the system PTC may not function as required to meet performance requirements PTC system may not enhance safety levels PTC system cannot be deployed without modification of system behavior PTC system can not be deployed without re- assessment of achieved safety levels Deployed PTC system can not obtain FRA Certification Schedule delay The methodologies and activities as required by § 236.1015 will be followed for the PTCSP. BNSF will ensure that all vendors from whom PTC technologies are to be acquired will have an acceptable quality assurance program for both design and manufacturing processes. Testing and documentation process audits are conducted periodically with vendors. Existing method of operation can be maintained during/after PTC installation until acceptable safety levels have been achieved and FRA Certification has been granted. ? ? ? ? ? ? ? ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 31 - Risk ID Objective/Goal Category Risk Descr iption Predicted Consequences Risk Mitigation Contingency Plan 5 Technical: Interoperability between BNSF and its tenants will be achieved. Interoperability between BNSF and its tenants is not achieved. Unsuccessful in deploying interoperable radio and messaging technology Semantic incompatibility between railroads PTC system will not be installed across all portions of the BNSF network for which PTC deployment is required by § 236.1005(b) Full benefit of safety enhancements will not be realized by required date BNSF may incur civil penalties Establish organizational structure to facilitate communication and coordination between host and tenant roads. BNSF participates in industry organizations to establish PTC system standards to achieve interoperability by working collaboratively on requirements definition, system/ component design, and product testing to deploy interoperable, common technology. Testing will ensure that implementations conform to industry standards. Interoperability testing will be conducted. Existing method of operation can be maintained during/after PTC installation until acceptable safety levels have been achieved and FRA Certification has been granted. ? ? ? ? ? ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 32 - Risk ID Objective/Goal Category Risk Descr iption Predicted Consequences Risk Mitigation Contingency Plan 6 Performance, Coverage, Quality & Technical: BNSF will maintain acceptable levels of operation on subdivisions operating under PTC. BNSF incurs unacceptable train delays resulting from PTC operation. PTC implementation and/or system design introduces inefficiencies: o Wireless communication related delays o Inefficient train operation resulting from braking algorithm Reduction in efficiency resulting from running unequipped trains through PTC equipped territory because: o Locomotives operating with PTC equipment installed but with equipment outages o Trains not PTC equipped. Reduction in efficiency of personnel o Ineffective human factors design for PTC equipment o Ineffective and/or insufficient training of personnel Railroad incurs unacceptable train delays as a result of PTC PTC deployment is delayed until productivity issues are resolved Reliability program initiated to monitor, report, and improve reliability of equipment. Identify and reach agreement with additional potential tenants for equipping PTC equipment. Monitor effectiveness of training ? quality improvement program in place. System development effort focusing on high technical risk areas to identify and mitigate potential system design and implementation related contributions to decreased productivity. Existing method of operation can be maintained during/after PTC installation until acceptable levels of operation have been achieved. Table 1 - Risks to BNSF's Completion and Delivery of PTC Installation by Dec 31, 2015 ? ? ? ? ? ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 33 - 6 Interoperability [§ 236.1011(a)(3)] This section describes how the PTC system will provide for interoperability between BNSF and all tenant railroads on the lines required to be equipped with a PTC system per § 236 Subpart I. 6.1 Railroad Agreement Provisions Relevant to Interoperability [§ 236.1011(a)(3)(i)] An Interoperable Train Control (ITC) collaboration agreement was executed by and amongst several railroads wishing to achieve PTC system interoperability. The development of an interoperable train control system would enable locomotives of one participant to transition at track speed to the control of another participant. The collaboration agreement includes a list of interoperability requirements mutually agreed-upon by the parties: Definition and adoption of uniform interface standards Definition, adoption, and implementation of American Association of Railroads (AAR) standard communication protocols Definition, adoption, and implementation of common office-locomotive communication protocols and message formats Definition, adoption, and implementation of a common Human Machine Interface (HMI), allowing an engineer from any of the participant?s roads to utilize the system on any  participant?s locomotives on territory for which the engineer is qualified Adoption of a coordinated plan for configuration management of the interoperable PTC on- board executable software Agreement on use of radio spectrum in the 220MHz band for communications between the locomotive and wayside and the locomotive and back office Agreement to acquire, develop, and deploy all of the technical capabilities required to permit the use of shared communications infrastructure Definition and adoption of standards allowing each participant?s locomotive engineer, at the  start of a trip, to initialize the interoperable on-board system with the back offices of participants? PTC systems that may be traversed during the trip to support all interoperability scenarios that will be encountered on the line-of-road with respective locomotive fleets and run-through operations The ITC collaboration agreement chartered the formation of various technical working committees, each dedicated to some technical aspect of PTC interoperability. Participation in the technical working committees was expanded beyond the chartering roads to include any railroad planning to implement an interoperable PTC system and wishing to participate. ? ? ? ? ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 34 - BNSF has additionally exchanged a Letter of Understanding with each of its passenger and freight tenant carriers who will operate PTC on its track. The letter establishes agreement between BNSF and its tenants in the following areas: Implementation of PTC technical solutions which meet the requirements of interoperability as defined in § 236.1003(b) Participation in a PTC testing program to verify functionality and interoperability Exchange of technical information needed to implement PTC in accordance with applicable FRA requirements BNSF has executed the Letter of Understanding and is coordinating implementation of an interoperable PTC system in accordance with the interoperability requirements stated in the ITC collaboration agreement with the tenant railroads shown in Appendix A - Short Line Letters of Understanding, Appendix B - Passenger Letters of Understanding, and Appendix C - Class I Letters of Understanding. BNSF will continue to communicate with its tenant roads to get a signed Letter of Understanding (LOU) and will amend its PTCIP with LOUs received after April 16, 2010. Additionally, BNSF is currently working with the tenant railroads identified in Appendix A - Short Line Letters of Understanding, Appendix B - Passenger Letters of Understanding, and Appendix C - Class I Letters of Understanding to identify any potential impacts on existing service agreements. BNSF will achieve interoperable PTC operations with its tenant and host railroads that operate PTC systems via one of three technical methods: Native Interoperability BNSF and its interoperability partner install and operate either the Electronic Train Management System (ETMS) or V-ETMS on their respective locomotives, office, and wayside. ETMS provides full functionality for any equipped locomotive, regardless of ownership, with any correspondingly-equipped office or wayside. Interoperability is achieved through native operation of ETMS/V-ETMS without the need for data, function, or HMI translation. Interoperable communications are achieved through adoption of common communications and message protocols and application behavior specifications described in ITC interoperability requirements. ETMS/V-ETMS encompasses the methods of operation and rules of both BNSF and its interoperability partners and accommodates any differences in the data provided by back office systems. ETMS and its operations are fully described in the ETMS PSP, submitted to FRA on February 18, 2010. As BNSF works with its tenant roads, this section will be updated in future PTCIP amendments with all tenants that we identify to operate in this manner. Railroads with which BNSF will conduct interoperable PTC operations in this manner are as follows: o Altamont Corridor Express o Commuter Rail Division of the Regional Transportation Authority (Metra) ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 35 - o Fort Worth & Western Railroad Co. o Minnesota Commercial Railway Company o National Railroad Passenger Corporation (Amtrak) o Nebraska Northeastern Railroad o North County Transit District o Northstar Commuter Rail o Red River Valley & Western Railroad o Sound Transit o Southern California Regional Rail Authority o Texas North Western Railroad o Texas Rockcrusher Railway o Trinity Railway Express Onboard Functional Interoperability BNSF and its interoperability partners install and operate different systems on their respective locomotives, office, and wayside. However, the locomotive on-board system of each is able to interoperate with the office and wayside infrastructure deployed on the other?s  property. BNSF will continue to evaluate its options as to whether or not it will conduct interoperable PTC operations in this manner. Unequipped Operation BNSF will continue to evaluate its options as to whether or not it will allow any unequipped operation on its PTC equipped subdivisions. 6.2 Technology Applicable to Interoperability [§ 236.1011(a)(3)(ii)] BNSF and its interoperability partners utilize methods in three areas to obtain and maintain interoperability of its PTC system(s): Technical interoperability is achieved through the common use of documented interface definitions. These definitions include one or more radio protocols (220MHz) and hardware interfaces to radio equipment, a common standard messaging protocol (ITC messaging), and standard data element and application message format and content definitions (ETMS/V- ETMS interface control documents). Use of, and compliance with, these common interface definitions ensures the ability to exchange data messages between interoperable system components. Semantic interoperability is achieved through the common use of documented system behavioral specifications. In the current ITC architecture, standard application-level specifications define the behavior of the interoperable office, locomotive, and wayside ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 36 - segments. Use of, and compliance with, these common behavioral specifications ensure each interoperable system segment properly interprets and acts upon exchanged data messages. O rganizational interoperability is achieved primarily through industry-wide forums, such as committees chartered by ITC and AAR. Technical teams operating under both the ITC and AAR charters are tasked with developing and maintaining the common technical standards in the areas of technical and semantic interoperability described above. These teams have worked to establish a baseline level of interoperability required for industry-wide PTC implementation. The teams will work in perpetuity to provide configuration management and ensure that interoperability is maintained as the interoperable PTC system(s) are enhanced. ITC and AAR teams also work to establish organizational interoperability in the areas of interchange and infrastructure sharing. 6.3 Obstacles to Interoperability [§ 236.1011(a)(3)(iii)] As a hosting railroad, BNSF foresees no obstacles to achieving full interoperability with any tenant railroads that operate lead PTC-equipped locomotives certified as conforming to the specifications established by the ITC consortium, and that also exchange the requisite information for operating a train as established by the ITC consortium. As a tenant railroad, BNSF also foresees no obstacles to achieving full interoperability with any and all hosting railroads that operate a PTC-equipped wayside certified as conforming to the specifications established by the ITC consortium, and that also exchange the requisite information for operating a train as established by the ITC consortium. BNSF intends to subject its PTC back office, wayside infrastructure, and locomotive equipment for certification or install equipment already type-certified for interoperability as appropriate. ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 37 - 7 Installation Risk Analysis [§ 236.1011(a)(4)] This section describes how the PTC system will be implemented to address areas of greater risk to the public and railroad employees before areas of lesser risk. Exceptions to the risk-based implementation methodology are included in Section 11 Exceptions to Risk-Based Prioritization [§ 236.1011(a)(9)]. A detailed risk analysis for each subdivision can be found in Appendix F - Risk Analysis per Subdivision. This appendix is intended to: Describe the rail network, its subdivisions, and the limits to be equipped Identify the significant risk factors on each subdivision, including: o Risk Factors o Measurement Values o Risk Assignments o Risk Values o Overall Risk Rating Prioritize the installation of PTC for each subdivision ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 38 - 8 Deployment Sequence & Schedule [§ 236.1011(a)(5)] This section defines the sequence, planned schedule, and decision basis for subdivisions to be equipped. Appendix D - Implementation Plan shows, in detail, the deployment sequence, segment traffic characteristics, segment operational characteristics, route attributes, and Total Risk Rating. Subdivisions that deviate from risk-based prioritization will be discussed in Section 11 - Exceptions to Risk-Based Prioritization [§ 236.1011(a)(9)]. BNSF is not planning any modifications at this time due to PTC. RA/LJII'AY Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 39 - 9 Rolling Stock [§ 236.1011(a)(6)] In accordance with § 236.1011(a)(6), this section contains the following information related to BNSF?s rolling stock that will be equipped with PTC: Type of rolling stock that will be equipped with PTC Schedule to equip the rolling stock by December 31, 2015 9.1 Rolling Stock to be Equipped [§ 236.1011(a)(6)(i)] BNSF will be equipping 2,000 of its 6,480 locomotive fleet with PTC. This schedule will be continuously evaluated by BNSF during its implementation. Any changes to the rolling stock installation will be addressed in a formal RFA and updated PTCIP as outlined in Section 1.1.5 Request for Amendment of a PTCIP [§ 236.1009(a)(2)(ii)] . The rolling stock that BNSF plans to equip with PTC falls into four categories: New locomotives delivered with PTC installed Freight locomotives (Intermodal and Merchandise service) Coal locomotives Intermediate locomotives (Road Switch and Local service) Each category of PTC locomotives is made up of several models of General Electric and Electric Motive Diesel engines. 9.2 Schedule [§ 236.1011(a)(6)(ii)] Appendix G .1 ? Rolling Stock Installation shows BNSF?s installation schedule for its rolling stock. It is currently planned that field installation of PTC on-board systems will be carried out at six locations, depending on service type and schedule: Alliance, Nebraska Argentine (Kansas City), Missouri Barstow, California Chicago, Illinois Havre, Montana Topeka, Kansas Two to six field retrofit installations will be scheduled per week at an estimated 40-60 man-hours per installation with a 24-48 hour cycle time. ? ? ? ? ? ? ? ? ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 40 - 9.3 Tenant Railroads [§ 236.1011(a)(6)(iv)(A) and (B)] Along with the Letter of Understanding, as explained in Section 6.1 Railroad Agreement Provisions Relevant to Interoperability [§ 236.1011(a)(3)(i)] , a PTCIP Notice and Intent to Coordinate Tenant Interoperability Letter was also sent to each tenant railroad that BNSF will require to equip PTC on the portion of their fleet that runs on PTC territory. This letter requests a list of all of the tenant railroad?s rolling stock to be PTC-equipped and the schedule to equip that rolling stock in accordance with § 236.1011(a)(6)(iv)(A) and (B) of the PTC Final Rule. These letters are provided for reference in Appendix A - Short Line Letters of Understanding, Appendix B - Passenger Letters of Understanding, and Appendix C - Class I Letters of Understanding for each tenant railroad. BNSF continues to work with its tenant partners to receive the requested information. As new responses are received, BNSF will file RFA?s that include the new letters. RA/LJII'AY Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 41 - 10 Wayside Devices [§ 236.1011(a)(7)] Wayside PTC devices consist of those signaling appliances located in the field whose status impacts PTC operations, along with any Wayside Interface Units (WIUs) used to monitor and report their status. Applicable appliances include: Interlockings Switch point monitors Track/route integrity detectors Other field devices Wayside signals Track circuits Hazard detectors To see the number of wayside devices by subdivision, see Table 2 - Number of Wayside Devices per Subdivision. The installation schedule to complete wayside equipment installation by December 31, 2015 can be found in Appendix D .1 ? Implementation Limits, under the Year column. As called out in § 236.1009 (a)(2)(ii), BNSF will file an RFA if any subdivision is added, removed, or modified. Wayside components exist in both signaled, and non-signaled territory. The PTC locomotive utilizes the status of wayside devices in the train route during calculation of its safe operating profile. Where installed, a WIU directly monitors the status of one or more wayside devices and relays the information via the communications network to the PTC locomotive and/or office. A wayside device may also be integrated with a track circuit or signal control circuit. In such cases, the status of the device is combined with the status indicated for the track circuit or signal. The PTC locomotive may concurrently process device status provided in any of these configurations. The industry ITC consortium has developed an open standard for WIU interfaces and functions, and several suppliers have developed products to meet that standard. Wayside device status will be provided in the following manner: W IU?connected - In this configuration, a WIU is connected to a wayside device that indicates its status to the PTC locomotive or Office via the Communications network. The WIU indicates device status at frequent intervals in order to satisfy the data freshness requirements of the PTC locomotive train control application. WIUs may also be configured to continuously indicate, or in order to conserve battery power at the WIU location and/or communications bandwidth, only begin to indicate upon receipt of a ?wake-up? from the  locomotive. Typical implementation of WIUs in the Wayside include monitoring of signals and power switches in Centralized Traffic Control (CTC) territory; monitoring signals and siding switches in Automatic Block Signal (ABS) territory; and monitoring hand-operated switches, approach and interlocking signals, and hazard detectors in non-signaled territory. ? ? ? ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 42 - Where other signaling appliances or hazard detectors are integrated with a signal system, their status is implicitly reflected in the status of signals provided to PTC and may not be indicated separately. For subdivisions where intermittent Automatic Train Stop (ATS) inductors (see Section 10.3- Subdivisions with ATS Removal) are located, these units will be removed when PTC is placed in service on the subdivision per § 235.7(a)(5). BNSF is applying for approval of discontinuance of waivered CAB signals (all freight trains are waivered, CAB signals do not include passenger enforcement) covering 36 road miles in connection with a request for approval of the Request for Expedited Certification (REC) and/or Positive Train Control Safety Plan (PTCSP) per § 236.0(e). In subdivisions where CAB Signal devices (See Section 10.4 - Subdivisions with CAB Signal Device Removal) are in use, these units will be removed when PTC is placed in service on the subdivision. As per normal operation, BNSF will submit and receive approval for a Block Signal Application prior to the discontinuance of this CAB signal system. 10.1 WIU Technology WIU technology, deployed as part of PTC, consists of signal-grade components and may be deployed in two configurations methods: In the first configuration, the WIU function is added to the chassis of an existing signaling processor. Hardware and/or software upgrades are deployed, often without requiring disarrangement of the signaling processor, its connected equipment, or pre-existing application software. In the second configuration, a complete WIU hardware and software component is collocated with an existing signaling processor and separately interfaced to the appliances it monitors or controls, such as lamp circuits, switch circuit controllers, or other outputs. In either configuration, the WIU also provides an interface to the communications network, where it indicates the status of any monitored devices. ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 43 - 10.2 Number of Wayside Devices per Subdivision Subdivision Total ABERDEEN 19 AFTON 37 AKRON 75 ANGORA 66 APPLETON 74 ARKANSAS CITY 88 AURORA 163 AVARD 77 BAKERSFIELD 65 BARSTOW 67 BEARDSTOWN 127 BELLINGHAM 59 BIG HORN 110 BIRMINGHAM 117 BLACK HILLS 68 BOISE CITY 77 BROOKFIELD 202 BRUSH 48 BUTTE 63 CAJON 59 CANYON 22 CASPER 119 CHEROKEE 94 CHICAGO 24 CHILLICOTHE 118 CLOVIS 113 COLUMBIA RIVER 97 CONROE 103 CREEK 76 CRESTON 72 CUBA 97 DALHART 61 DEVILS LAKE 121 DFW 47 DICKINSON 103 Subdivision Total DOUGLASS 13 EL PASO 173 EMPORIA 153 FALLBRIDGE 107 FORSYTH 112 FRONT RANGE 69 FT SCOTT 89 FT WORTH 134 GALLUP 160 GALVESTON 104 GATEWAY 54 GLASGOW 131 GRAND FORKS 62 GREAT FALLS 34 HANNIBAL 89 HASTINGS 119 HEREFORD 57 HETTINGER 33 HI LINE 114 HILLSBORO 89 HOUSTON 65 JAMESTOWN 92 K O 135 KOOTENAI RIVER 126 LA JUNTA 327 LAFAYETTE 103 LAKESIDE 70 LAMPASAS 240 LAUREL 60 MADILL 61 MARCELINE 93 MARSHALL 88 MENDOTA 114 MIDWAY 10 MILK RIVER 81 Subdivision Total MOBRIDGE 88 MOJAVE 44 MOORHEAD 30 MORRIS 82 MYKAWA 12 NAPIER 22 NEEDLES 71 NOYES 40 OMAHA 27 OREGON TRUNK 178 OTTUMWA 111 PANHANDLE 163 PEORIA 15 PHOENIX 70 PIKES PEAK 62 PLAINVIEW 70 PROSPER 45 PUEBLO 33 RAVENNA 80 RED RIVER VALLEY 83 RED ROCK 239 RIVER 107 SAN BERNARDINO 56 SAND HILLS 125 SCENIC 83 SEATTLE 127 SELIGMAN 164 SILSBEE 8 SIOUX CITY 60 SLATON 187 SPANISH PEAKS 36 SPOKANE 8 ST CROIX 86 ST JOSEPH 114 ST PAUL 21 RA/LJII'AY Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 44 - Subdivision Total STAMPEDE 43 STAPLES 144 STOCKTON 179 STRONG CITY 17 SWEETGRASS 7 Subdivision Total THAYER NORTH 59 THAYER SOUTH 88 TWIN PEAKS 58 VALLEY 22 WAYZATA 42 Subdivision Total WICHITA FALLS 68 YAKIMA VALLEY 86 ZAP LINE 34 Table 2 - Number of Wayside Devices per Subdivision 10.3 Subdivisions with ATS Removal The following lists all subdivisions that have ATS inductors: Boise City Cajon Emporia Gallup La Junta Marceline Needles Seligman 10.4 Subdivisions with CAB Signal Device Removal The following lists all subdivisions that have CAB signal devices: Chicago ? ? ? ? ? ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 45 - 11 Exceptions to Risk-Based Prioritization [§ 236.1011(a)(9)] This section identifies and describes the railroad's basis for determining that the risk-based prioritization in § 236.1011(a)(4) is not practical as it may be associated with any subdivision. Prior to the ruling of Subpart I, BNSF conducted a voluntary risk rating analysis of its subdivisions to determine its implementation schedule. BNSF selected the first ten subdivisions, listed below, to implement due to the results of this risk rating and the amount of passenger traffic present. Material procurement and construction work is already under way for these areas. Bakersfield Bellingham Emporia Fallbridge Mendota San Bernardino Scenic Seattle Stockton Currently five subdivisions, listed below, are already operational with the 44 MHz legacy ETMS system. Since these subdivisions are already operational with PTC, BNSF has tentatively planned to retrofit these locations with the 220 MHz interoperable solution in 2012 once they have assurance of radio availability. Beardstown Fort Worth Hettinger Red Rock Wichita Falls BNSF, in this PTCIP, is filing for exclusion of track segments without TIH/PIH or passenger traffic. While FRA is considering such requests and developing the criteria for safety considerations, BNSF has placed the track segments with outstanding exclusion requests towards the back of its implementation plan. BNSF will continue to evaluate this plan as it moves forward. The following subdivisions fall under this consideration: Aberdeen Afton Big Horn Black Hills Boise City Canyon Creek Cuba DFW Jamestown Lampasas Laurel Napier Pueblo River Sand Hills Silsbee Slaton Spanish Peeks St. Croix Stampede Twin Peaks Yakima Valley ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 46 - Pending the outcome of BNSF?s filing for exclusion, BNSF has moved the subdivisions listed below that would have their PTC installation limits changed towards the back of its implementation plan. As with the subdivisions mentioned above, ongoing evaluations will continue for each subdivision in regards to their PTC installation limits. Aurora Brookfield Butte Casper Chillicothe Conroe Devils Lake Front Range Galveston Great Falls Houston La Junta Madill Mobridge Morris Phoenix Ravenna Red River 11.1 PHMSA Routing Exceptions As required by the PHMSA Routing Rule covering bulk movements of TIH and certain explosive and radioactive shipments (49 CFR § 172.820), BNSF has completed an analysis of the historic and current routing of these commodities. In performing this analysis, BNSF took into account 27 factors identified by the Department of Transportation as affecting the safety and security of covered shipments and additional factors identified by BNSF. The results of this analysis are relevant to BNSF?s PTC Implementation Plan as they change the territories across which toxic  inhalant shipments are routed. Appendix J.1 - PHMSA Routing Exceptions lists territories across which toxic inhalants will no longer be routed by BNSF as a result of BNSF?s routing analysis. ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 47 - 12 Strategy for Full PTC System Deployment [§ 236.1011(b)] BNSF will evaluate whether to add additional track segments pursuant to the risk reduction program contemplated by section 105 of the RSIA08 once regulations are adopted. Without a complete and final regulatory framework, it is impossible to know exactly what criteria to apply in making risk reduction prioritizations or in determining whether PTC is an appropriate method of risk reduction. BNSF will evaluate any safety enhancements that may be needed in combination with economic considerations. As FRA?s economic analysis has shown, PTC is a very costly system, and the  benefit of its installation is greatly outweighed by the costs. BNSF believes that PTC is not a "one size fits all" safety solution and anticipates that, given the breadth of FRA?s PTC expectations under  this section and the expense of PTC, there will be few or no other lines where PTC will be the appropriate risk reduction choice. RA/LJII'AY Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 48 - 13 Main Line Track Exclusion Addendum [§ 236.1019] 13.1 MTEA General The following sections provide a Mainline Track Exclusion Addendum (MTEA) for each segment of BNSF mainline track for which exclusion of PTC installation is requested due to extenuating circumstances as provided by the § 236 Subpart I. BNSF?s MTEAs are filed per the following MTEA rule citation: Rule § 236.1019(c)(3) ? Limited Operations Exception; not more than four passenger trains per day are operated on a segment of track of a Class 1 freight railroad on which less than 15 million gross tons of freight traffic is transported annually. Each MTEA request is detailed separately in the following sections. All have been reviewed in detail with the National Railroad Passenger Corporation (Amtrak) and all are submitted with their full concurrence and agreement. Each MTEA submission provides a summary track description and layout, a narrative description of normal train operations, and a reference to the applicable section of 49 CFR 236.1019 under which the MTEA is requested. MTEA?s are being requested by BNSF for each of the following track segments: 1. Topeka Subdivision ? Holliday (MP 0.0) to N.R. Jct (MP 111.0) 2. Raton Subdivision ? La Junta (MP 554.9) to Las Vegas (MP 770.1) 3. Glorieta Subdivision ? Las Vegas (MP 770.1) to Lamy (MP 835.2) and Isleta (MP 12.6) to Dalies (MP 27.4) ? Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 49 - 13.2 MTEA Request ? Topeka Subdivision BNSF is seeking an MTEA for the Topeka subdivision under the Limited Operations Exception explained in §236.1019(c)(3) for the segments of track between Holliday (MP 0.0) and N.R. Jct (MP 111.0). The Topeka subdivision contains no TIH/PIH traffic and runs two passenger trains each way per day between Holliday and Topeka (MP 50.5W). Figure 3 - Topeka Subdivision Topeka Subdivision 20 30 II I II 40 SO 40 I Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 50 - 13.3 MTEA Request ? Raton Subdivision BNSF is seeking an MTEA on the Raton subdivision under the Limited Operations Exception explained in § 236.1019(c)(3) for the segments of track between La Junta (MP 554.9) and Las Vegas (MP 770.1). The Raton subdivision runs two passenger trains each way per day between La Junta and Las Vegas. There is no TIH/PIH traffic on the Raton subdivision. Figure 4 - Raton Subdivision Raton Subdivision ?.. --- Electronic Train Management System PTC Implementation Plan v 1.4 July 2, 2010 - 51 - 13.4 MTEA Request ? Glorieta Subdivision BNSF is seeking an MTEA on the Glorieta subdivision under the Limited Operations Exception explained in § 236.1019(c)(3) for the segments of track between Las Vegas (MP 770.1) and Lamy (MP 835.2) and Isleta (MP 12.6) to Dalies (MP 27.4) The Glorieta subdivision runs two passenger trains each way per day between Las Vegas and Lamy and between Isleta and Dalies. There is no TIH/PIH traffic on the Glorieta subdivision. Figure 5 - Glorieta Subdivision Glorieta Subdivision Scale: miles o 5 10 20 30 11'1 'I I' I '. o 510 20 30 40 50 kilometefs BNSF Railway Company '0I 50 I ," National Railroad Passenger Corporation (Amtrak) PTC Implementation Plan Revised July 16, 2010 Revision2.0 Submitted in fulfillment of 49 CFR Part 236, Subpart I, § 236.1011 i Revision History AmtrakPTCIP.doc Date Revision Description Author 4/12/10 0.1 Release for internal comments E. K. Holt 4/16/10 1.0 Release to FRA E. K. Holt 7/16/10 2.0 Revised per FRA comments of 6/18/10 PTCIP, Appendix A and Appendix B revised E. K. Holt PTC Implementation Plan 1 Table of Contents 1.0 Introduction................................................................................................................... 5 1.1 Amtrak Background.................................................................................................. 5 1.2 Overview of Amtrak Operations......................................................................... 6 1.2.1 Northeast Corridor ...................................................................................... 7 1.2.2 Northeast Corridor Feeder Lines ................................................................ 8 1.2.2.1 Keystone Corridor (Harrisburg Line) ......................................................... 8 1.2.2.2 Empire Connection ..................................................................................... 8 1.2.2.3 Springfield Line .......................................................................................... 9 1.2.3 The Michigan Line.......................................................................................... 9 1.2.4 Chicago Terminal........................................................................................ 9 1.2.5 New Orleans Union Passenger Terminal.................................................. 10 1.3 Organizational Relationships ........................................................................ 10 1.4 Request for Amendment of a PTCIP § 236.1009(a)(2)(ii) ........................... 11 1.5 Goals and Objectives .............................................................................................. 11 1.5.1 Functional Description of ACSES/ATC System on the NEC ......................... 12 1.5.2 Functional Description of ITCS System on Amtrak?s Michigan Line ............ 13 1.5.3 Functional Description of V-ETMS System.................................................... 14 1.6 Success Criteria....................................................................................................... 15 1.7 Applicability ........................................................................................................... 16 1.8 Document Overview ............................................................................................... 16 1.9 Acronyms and Definitions ...................................................................................... 17 2.0 Applicable Documents................................................................................................ 20 3.0 Technology [§ 236.1011(a)(1)]................................................................................... 21 3.1 ACSES and ATC on the Northeast Corridor .......................................................... 21 3.1.1 ACSES Overview ............................................................................................ 21 3.1.2 ACSES Functions and Architecture................................................................. 22 3.1.3 ACSES Onboard Equipment............................................................................ 24 3.1.3.1 ACSES Onboard Computer .......................................................................... 24 3.1.3.2 ADU.............................................................................................................. 24 3.1.3.3 Transponder Reader and Antenna................................................................. 24 3.1.3.4 MCP .............................................................................................................. 24 3.1.4 Main ACSES Wayside Equipment .................................................................. 25 3.1.4.1 Transponders................................................................................................. 25 3.1.4.2 Encoders or Wayside Interface Units (WIU)................................................ 26 3.1.4.3 Safety TSR Server......................................................................................... 27 3.1.4.4 Network Servers............................................................................................ 28 3.1.4.5 BCPs ............................................................................................................. 28 3.1.4.6 Wayside Communications Controllers ......................................................... 28 3.1.5 ACSES Train Types......................................................................................... 29 3.1.6 ACSES Data Communication System Concepts ............................................. 29 3.1.7 Infrastructure Data ........................................................................................... 30 3.1.8 ACSES Safety.................................................................................................. 31 3.2 ITCS on Amtrak?s Michigan Line .................................................................... 32 PTC Implementation Plan 2 3.2.1 General Description .................................................................................. 32 3.2.2 ITCS Components..................................................................................... 34 3.2.2.1 On Board Computer (OBC) ...................................................................... 34 3.2.2.2 GPS Receiver Interface Module (GPSRIM)............................................. 34 3.2.2.3 Compact Locomotive Display (CLD)....................................................... 34 3.2.2.4 Train to Wayside Communications Network (TWC)............................... 35 3.2.2.5 Wayside Interface Unit (WIU).................................................................. 35 3.2.2.6 Wayside Interface Unit ? Server (WIU-Server) ....................................... 35 3.2.2.7 Terminal Server ........................................................................................ 36 3.2.2.8 Wayside Local Area Network (WLAN) ................................................... 36 3.2.2.9 Office to Wayside Link............................................................................. 36 3.3 Amtrak?s Implementation of V-ETMS................................................................... 36 3.3.1 Application of V-ETMS on Amtrak ................................................................ 40 4.0 Compliance [§ 236.1011(a)(2)] ............................................................................ 42 4.1 ACSES/ATC System on the Northeast Corridor .................................................... 42 4.2 ITCS System on Amtrak?s Michigan Line ............................................................. 42 4.3 Amtrak?s Implementation of V-ETMS................................................................... 42 4.3.1 Utilization of Existing Type Approval and/or PTCDP.................................... 43 4.3.2 Certifying the Validity of Type Approval ....................................................... 43 4.3.3 Handling of Unique Aspects of the PTCDP and Type Approval .................... 43 4.3.4 Deliverables ..................................................................................................... 44 4.4 Project Risk Assessment ......................................................................................... 44 4.4.1 Risks to PTC Implementation.......................................................................... 45 5.0 Interoperability [§ 236.1011(a)(3)]....................................................................... 47 5.1 Northeast Corridor and Feeder Lines...................................................................... 47 5.1.1 Agreement Provisions Relevant to Interoperability [§236.1011(a)(3)(i)] ....... 47 5.1.2 Technology Applicable to Interoperability [§236.1011(a)(3)(ii)] ............ 49 5.1.3 Obstacles to Interoperability [§236.1011(a)(3)(iii)] ........................................ 49 5.2 Amtrak?s Michigan Line......................................................................................... 50 5.2.1 Agreement Provisions Relevant to Interoperability [§236.1011(a)(3)(i)] ....... 50 5.2.2 Technology Applicable to Interoperability [§236.1011(a)(3)(ii)] ................... 50 5.2.3 Obstacles to Interoperability [§236.1011(a)(3)(iii)] ........................................ 50 5.3 V-ETMS Territory ............................................................................................ 50 5.3.1 Agreement Provisions Relevant to Interoperability [§236.1011(a)(3)(i)] ....... 50 5.3.2Technology Applicable to Interoperability [§236.1011(a)(3)(ii)] .................... 51 5.3.3 Obstacles to Interoperability [§236.1011(a)(3)(iii)] ........................................ 51 6 Installation Risk Analysis [§236.1011(a)(4)] ........................................................... 52 6.1 General Overview ................................................................................................... 52 7 Deployment Sequence and Schedule [§236.1011(a)(4)(5)]...................................... 54 7.1 General.................................................................................................................... 54 7.2 Northeast Corridor (NEC)................................................................................. 54 7.2.1 Material Procurement....................................................................................... 54 7.2.2 Design .............................................................................................................. 54 7.2.3 Transponder Installation .................................................................................. 55 7.2.4 Installation of Radio Houses and Antenna Poles............................................. 55 7.2.5 Installation of Encoders (WIUs) and Data Radios........................................... 56 PTC Implementation Plan 3 7.2.6 Testing and Commissioning ............................................................................ 56 7.2.7 Installation of V-ETMS on the NEC ............................................................... 57 7.3 Michigan Line......................................................................................................... 58 7.4 Chicago and New Orleans ...................................................................................... 58 8 Rolling Stock [§236.1011(a)(6) ................................................................................ 60 8.1 General.................................................................................................................... 60 8.2 Rolling Stock to be Equipped [§236.1011(a)(6)(i)]................................................ 60 8.3 Schedule [§236.1011(a)(6)(ii)] ......................................................................... 61 8.4 Tenant Railroads [§236.1011(a)(iii)(A) and (B)] ............................................. 62 8.4.1 Tenants Operating on the NEC........................................................................ 62 8.4.2 Tenants Operating on the Michigan Line ........................................................ 63 8.4.3 Tenants Operating in Chicago Union Terminal............................................... 64 8.4.4 Tenants Operating in New Orleans Union Passenger Terminal ...................... 64 9 Wayside Devices [§236.1011(a)(7)]......................................................................... 65 9.1 General.................................................................................................................... 65 9.2 Northeast Corridor ? ACSES Installation............................................................... 65 9.2.1 Northeast Corridor ? VETMS Overlay in ACSES Territory........................... 65 9.3 Michigan Line ? ITCS Installation ......................................................................... 65 9.4 Chicago Terminal ? V-ETMS................................................................................. 66 9.5 New Orleans Union Passenger Terminal ? V-ETMS....................................... 66 9.6 CP Virginia to ?A? Interlocking ? Washing Union Terminal ? V-EMTS ....... 67 10 Designating Track as Main Line or Non-Main Line [§236.1011(a)(8)]............... 68 10.1 General.................................................................................................................. 68 10.2 Main Line Track ................................................................................................... 68 10.3 Non-Main Line Track ....................................................................................... 69 11 Exceptions to Risk-Based Prioritization [§236.1011(a)(9)] ................................. 71 12 Alternative Arrangements for Rail-to-Rail At-Grade Crossings [§236.1011(a)(10)]............................................................................................................ 72 12.1 At-Grade Crossing in Michigan City, IN.............................................................. 72 12.2 At-Grade Crossing at CP 21st Street in Chicago Union Terminal ........................ 72 13 Main Line Track Exclusion Addendum [§236.1019] ........................................... 73 13.1 General.................................................................................................................. 73 13.2 Washington Union Terminal (WUT).................................................................... 74 13.3 Penn Station New York (PSNY)........................................................................... 78 13.4 Boston South Station............................................................................................. 79 13.5 Springfield Passenger Terminal............................................................................ 80 13.6 Harrisburg, PA Passenger Terminal ..................................................................... 82 13.7 Chicago Union Terminal....................................................................................... 84 13.8 New Orleans Union Passenger Terminal (NOUPT)............................................. 85 14.0 Appendices................................................................................................................ 86 14.1 Appendix A ? Agreements and Letters between Amtrak and its Tenant Railroads ....................................................................................................................................... 86 14.2 Appendix B ? Agreements and Letters between Amtrak and its Host Railroads. 86 14.3 Appendix C ? Track Charts and Timetable Information for NEC Line 1 and 7 - New York to Philadelphia............................................................................................. 86 PTC Implementation Plan 4 14.4 Appendix D ? Track Charts and Timetable Information for NEC Line 2 ? Philadelphia to Washington .......................................................................................... 86 14.5 Appendix E ? Track Charts and Timetable Information for NEC Line 4 ? Philadelphia to Harrisburg ............................................................................................ 86 14.6 Appendix F ? Track Charts and Timetable Information for NEC Line 5 ? Mill River to Springfield....................................................................................................... 86 14.7 Appendix G ? Track Charts and Timetable Information for NEC Line 6 ? JO to Shell .............................................................................................................................. 86 14.8 Appendix H ? Track Charts and Timetable Information for NEC Line 8 ? Empire Connection .................................................................................................................... 86 14.9 Appendix I ? Track Charts and Timetable Information for CP Virginia to Washington Union Terminal......................................................................................... 86 14.10 Appendix J ? Track Charts and Timetable Information for Michigan Line ....... 86 14.11 Appendix K ? Track Charts and Timetable Information for Chicago Union Station ........................................................................................................................... 86 14.12 Appendix L ? Track Charts and Timetable Information for New Orleans Union Passenger Terminal....................................................................................................... 86 14.13 Appendix M ? Track Charts in Support of MTEA Requests (Section 13)......... 86 14.14 Appendix N ? Risk Analysis............................................................................... 86 PTC Implementation Plan 5 1.0 Introduction 1.1 Amtrak Background Passenger train service was the dominant mode for long distance travel in the United States until the 1950s when jet airplane travel and the Interstate Highway System set the stage for a rapid modal shift that led passengers away from rail and into competing travel modes. This led to further erosion of passenger service profits for the major railroads and the level of service deteriorated nationwide. As it became increasingly apparent that the passenger train was headed for extinction, its supporters, among them labor and the National Association of Railroad Passengers, undertook a campaign to reverse the trend, lobbying members of Congress and appearing at ICC hearings to argue against service cuts. With the collapse of the Penn Central Railroad into bankruptcy Congress passed the Rail Passenger Service Act in 1970. This law created Amtrak and assigned it the responsibility for the operation of the national intercity passenger rail system. The law directed the DOT to determine which of the existing routes would be included in that system, and stipulated that the company would be run as a for-profit corporation. The law also provided for the inauguration of routes outside the prescribed system with financial support from state governments, the so- called ?403(b) trains.? The DOT?s designated network retained about half of the passenger rail services that existed at the start of 1971. Most of these routes remain today. Because the national system was smaller than the system it replaced, several states approached Amtrak with requests for service, and the first 403(b) trains were quickly instituted; some were expansions to service, others were completely new services inaugurated with state support. The 1970 bankruptcy of Penn Central was the biggest in the history of the U.S. up to that time, and in succeeding years the company deferred maintenance and allowed the tracks, right-of-way and signal systems to deteriorate. The company sold two Northeast Corridor (NEC) segments to the states in the early 1970s. Just as Penn Central?s collapse had spurred the creation of Amtrak, Penn Central?s financial difficulties provided it an opportunity. In 1976 the remainder of the NEC along with feeder lines to Harrisburg, PA and Springfield, MA were conveyed to Amtrak. Following the formation of Conrail at the same time a portion of its Michigan line was also conveyed to Amtrak. Following Amtrak?s takeover of the NEC, Congress appropriated funding for the Northeast Corridor Improvement Program (NECIP) which brought massive improvements to the infrastructure and raised the speed of passenger train operation to 125 mph between New York and Washington. In 1992 the Northeast High Speed Rail Improvement Program (NHRIP) was launched to improve the New Haven to Boston portion of the NEC. This project included electrification of that portion of the railroad along with massive improvements in track and signal systems including the introduction of North America?s first Positive Train Control (PTC) system and the introduction of Amtrak?s Acela high speed train sets which operate at speeds up to 150 mph. PTC Implementation Plan 6 1.2 Overview of Amtrak Operations Amtrak operates a nationwide rail network, serving more than 500 destinations in 46 states and 3 Canadian provinces on 21,000 miles of routes. It is the nation?s only high speed intercity passenger rail provider, operating nearly 60% of its trains at speeds in excess of 90 mph. Seventy percent of the miles traveled by Amtrak trains are on tracks owned by other railroads. Known as host railroads, they range from the Class I freight carriers to state and local government agencies and small businesses. Amtrak pays these host railroads for use of their track and other resources required for Amtrak service. The six largest host railroads for Amtrak trains are: o BNSF Railway, 6.75 million train miles o Union Pacific Railroad, 6.16 million train miles o CSX Transportation, 5.92 million train miles o Norfolk Southern Railway, 2.35 million train miles o Canadian National Railway, 1.43 million train miles o Metro North Railroad, 1.35 million train miles During FY 2009, (Oct. 2008 ? Sept. 2009), Amtrak carried more than 27.1 million passengers, the second largest annual total in Amtrak?s history. More than 74,000 passengers ride approximately 300 Amtrak trains per day. More than 925,000 passengers each day depend on commuter rail services that use Amtrak-owned infrastructure. This includes Amtrak?s Northeast Corridor which is the busiest railroad in North America, with more than 2,600 trains operating over some portion of the Washington ? Boston route each day. More than a quarter of a million riders use the NEC on every weekday, generating more than 4.4 million daily passenger miles. Amtrak trains carried 9,946,027 passengers on portions of the NEC between Boston and Washington in FY 2009. Amtrak trains carried over one million passengers on each of three other corridors during the same time interval. The Pacific Surfliner Service (San Diego-Los Angeles-San Luis Obispo) had 2,592,996 passengers. The Capitol Corridor Service (San Jose-Oakland-Sacramento-Auburn) had 1,599,625 passengers and the Keystone Corridor Service (Harrisburg-Philadelphia-New York) had 1,215,785 passengers. Five other corridors had ridership in excess of one half million passengers: o San Joaquin Service (Oakland-Sacramento-Bakersfield): 929,172 o Empire Service (New York-Albany-Niagara Falls): 925,746 o Amtrak Cascades Service (Eugene-Portland-Seattle-Vancouver, B.C.): 740,154 o Hiawatha Service (Chicago-Milwaukee): 738,231 o Lincoln Service (Chicago-St. Louis): 506,235 PTC Implementation Plan 7 Amtrak?s busiest station is Penn Station in New York City. The station is used by Amtrak, New Jersey Transit and The Long Island Rail Road. Weekday train movements in and out of Penn Station total 1292 with 934 of these being revenue trains. Chicago Union Station is Amtrak?s second busiest station serving Amtrak and Metra trains. There are 58 scheduled daily Amtrak trains operating into and out of Chicago and 285 scheduled daily Metra trains. 1.2.1 Northeast Corridor Amtrak owns and operates the NEC from Washington, DC to New Rochelle, New York with the exception of Harold interlocking in Queens which is owned by The Long Island Rail Road. Amtrak trains operate over Metro-North Railroad from New Rochelle to New Haven, CT. Amtrak ownership resumes from New Haven to the Rhode Island/Massachusetts State line. Amtrak maintains a long term lease on the portion of the NEC from the Massachusetts State line into Boston?s South Station. The entire route from Washington to Boston is electrified. Amtrak?s Acela trains operate at top speeds of 135 mph between Washington and New York and 150 mph between New Haven and Boston. Amtrak regional trains operate at top speeds of 125 mph between Washington and Boston. Commuter train operating speeds are typically 80 to 100 mph and the top speed for freight train operation is 50 mph. The entire NEC is cab signaled with a requirement for all carriers to have both cab signal and speed control equipment on-board. All carriers operating between New Haven and Boston are also required to be ACSES equipped making it the only place in North America where all trains operate with full PTC capability. Two segments of the line between New York and Washington are also ACSES equipped to allow Acela Express trains to operate up to 135 mph. The NEC handles both commuter and freight traffic in addition to Amtrak service. Following are the commuter railroads using portions of the NEC: o Virginia Railway Express operates 30 commuter trains to and form Washington Union Terminal o MARC operates 48 daily commuter trains between Washington and Baltimore and 11 daily trains between Baltimore and Perryville, MD o Septa operates 19 daily trains between Newark, DE and Wilmington, DE and 55 daily trains between Wilmington and Philadelphia o Septa operates another 59 daily trains between Philadelphia and Trenton, NJ o New Jersey Transit operates 26 daily Atlantic City trains between Philadelphia?s 30th Street Station and Shore interlocking, Northeast of Philadelphia o New Jersey Transit operates 404 daily trains over various segments of the NEC between Trenton and New York o The Long Island Rail Road operates 562 trains through the East River Tunnels in and out of Penn Station New York PTC Implementation Plan 8 o CDOT-Shore Line East operates 36 trains between New Haven and New London, CT. o MBTA operates 112 daily commuter trains over the segment between Providence, RI and Boston, MA. Freight operation on the NEC is heaviest between Perryville, MD and Baltimore but there is freight activity over most of the line. The following freight railroads operate over the NEC: o Norfolk Southern has trackage rights between Washington, DC and Newark, NJ o CSX has trackage rights between Washington, DC and Newark, NJ and over portions of the segment in the State of Massachusetts o Canadian Pacific Railroad has trackage rights between Landover, MD and Perryville, MD o Conrail Shared Assets has trackage rights between Philadelphia and Newark, NJ o P&W has trackage rights between New Haven and the Rhode Island/Massachusetts State Line. Amtrak plans to complete its implementation of ACSES on the NEC to meet the requirements of 49 CFR Part 236, Subpart I. ACSES is a vital overlay system which combined with ATC (cab signaling and speed control) meets the requirements of a PTC system. 1.2.2 Northeast Corridor Feeder Lines The Northeast Corridor feeder Lines are all signaled with cab signal systems and all trains operate with cab signals and speed control. All of these feeder lines will be equipped with ACSES. 1.2.2.1 Keystone Corridor (Harrisburg Line) The Keystone Corridor is a 104 mile route between Philadelphia and Harrisburg, PA. The line is electrified with top passenger speeds of 110 mph and freight speed of 50 mph. Amtrak operates 28 daily intercity passenger trains and SEPTA operates 84 daily commuter trains between Philadelphia and Paoli with 42 of these operating on to Thorndale, PA. SEPTA also operates 20 trains to and from their Cynwyd line for a short distance in the Philadelphia area. Norfolk Southern operates approximately 10 daily local freight trains on the line. 1.2.2.2 Empire Connection The Empire Connection is a 10 mile long double track connection from Penn Station New York to Metro North?s Hudson Line. The line was acquired in 1990 to allow Amtrak?s Empire Service to operate into Penn Station rather than Metro North?s Grand Central Terminal. It runs from Penn Station through a single track tunnel and up the West side of Manhattan to the Harlem River crossing the river at Spuyten Duyvil Bridge and joining Metro North at CP12 on the Hudson Line. PTC Implementation Plan 9 The connection is not electrified and is used by 24 daily Amtrak trains powered by dual mode locomotives (diesel and third rail electric power within Penn Station). There is no freight on the line. 1.2.2.3 Springfield Line This line runs between Mill River interlocking in New Haven, CT and Springfield MA. It is a 60 mile long single track line with passing sidings. It is not electrified. Amtrak operates 12 daily passenger trains on the line and there is some local freight. Most of the freight is handled by Connecticut Southern Railroad and Springfield Terminal Railroad. CSX has trackage rights over a short distance on the south end of the line. 1.2.3 The Michigan Line The Michigan Line is a 97 mile long single track line with passing sidings. It runs between Porter, IN and Kalamazoo, MI. About 60 miles of the line is equipped with ITCS, a vital overlay communications based PTC system. Amtrak currently has a contract with General Electric Transportation Systems (GETS) to complete the ITCS coverage over the entire 97 miles. Amtrak currently operates 8 daily passenger trains at a top speed of 95 mph under a waiver from FRA. Amtrak is seeking certification of ITCS and has asked FRA to allow passenger speeds of 110 mph. It is expected that once trip times are improved, passenger patronage will increase on this line. There is some freight on the Michigan Line with Norfolk Southern (NS) operating an average of 3 local freights per day. NS has a limited number of locomotives that are ITCS equipped and all freight trains operate under ITCS control. 1.2.4 Chicago Terminal Both Amtrak and Metra operate passenger service to and from Chicago Union Station. Amtrak operates 58 daily trains and Metra operates 285 daily commuter trains. The speed in the passenger terminal is 15 mph and Amtrak is requesting an MTEA for this portion of the terminal. On the Southern approach to the passenger terminal between Polk Street and 21st Street Interlocking, passenger speed is 30 mph and freight speed is 10 mph. There are approximately 12 freight trains operating on this portion of the terminal between 21st Street and 16th Street (BNSF Jct.). The freight carriers are Norfolk Southern, BNSF and Union Pacific. The terminal is signaled and is under CTC control. Amtrak intends to install a Vital Electronic Train Management System (V-ETMS) between Polk Street and 21st Street. V- ETMS is a vital overlay PTC system and will be interoperable with the system being installed by Metra and the freight railroads using the terminal. PTC Implementation Plan 10 1.2.5 New Orleans Union Passenger Terminal Amtrak trains operate in and out of the New Orleans Union Passenger Terminal through connections to CN at Southport Jct. and NS at East City Jct. The tracks leading from these connections toward the passenger station are signaled and under CTC control. The speed for passenger trains is 30 mph to CP Clara Street and then 10 mph from there into the station area. Amtrak is requesting an MTEA for the portion of the terminal between CP Clara Street and the Passenger Station and for the Wye tracks. There is very little freight operation in the terminal. There is an occasional delivery to the Times Picayune. Amtak intends to install V-ETMS on the tracks from CP Clara Street to Southport Jct. and East City Jct. This system will be interoperable with both CN and NS which plan to install a similar system. 1.3 Organizational Relationships Amtrak has designated the Deputy Chief Engineer Communications and Signals as the person responsible for PTC implementation. A dedicated organization has been formed to manage Amtrak?s PTC projects with a Senior Director PTC reporting to the Deputy Chief Engineer. This group will be responsible for expanding the ACSES system over the entire NEC including its feeder lines. The group will also manage the completion of ITCS installation on the Michigan Line and will be responsible to install V-ETMS in Chicago and New Orleans. The group will also work with the freight carriers operating on the NEC to install a V-ETMS overlay that will allow freight trains to operate on portions of the NEC without having to be equipped with an ACSES on-board system. The PTC group will also be responsible for managing a project to equip all of Amtrak?s locomotives operating outside the NEC with PTC on-board equipment that will interoperate with all its host railroads. The group will also be responsible for coordination of testing with the host railroads. The PTC group will continue to support and maintain the PTC systems installed on Amtrak property and rolling stock after the PTC implementation is completed. An organization chart for the PTC group is shown below. Consultants will be used to supplement Amtrak personnel as required for the project. Mechanical and Transportation support personnel will used when needed. PTC Implementation Plan 11 PTC Project Organization Chart 1.4 Request for Amendment of a PTCIP § 236.1009(a)(2)(ii) This PTCIP will be placed under configuration control and any changes to the plan will be made in accordance with Amtrak?s PTC Configuration Control Plan based on Amtrak?s Software Management Control Plan for Processor-Based Signal & Train Control Systems, which has been approved by FRA. Any discontinuances will be filed in accordance with 49 CFR Part 235 and § 236.1021 after approval of Amtrak?s Chief Operating Officer and any affected tenant railroads. 1.5 Goals and Objectives Amtrak?s PTC systems will be fully compliant with 49 CFR part 236 inclusive of all subparts including FRA approved exclusions permitted under Subpart I for terminals and limited operation territory. Amtrak will be completing the installation of ACSES on the Northeast Corridor and its feeder lines in compliance with the requirements of § 236.1015. Our goal is to receive expedited certification and to complete this installation by December 31, 2012. We will be working with the tenant railroads that also intend to install ACSES on their railroads with the objective of achieving seamless interoperability. For interoperability with freight carriers operating on the NEC, Amtrak intends to install a V-ETMS overlay that will allow freight trains and some commuter trains to operate on the NEC without ACSES equipment. These trains will be required to be equipped with on-board cab signal equipment and an on-board V-ETMS system. Amtrak will complete the installation of ITCS on the Michigan Line in 2011 in full compliance of the requirements of § 236.1015. Our goal is to receive expedited certification of that system and to increase the speed of passenger trains to 110 mph. PTC Implementation Plan 12 This has been a goal of the State of Michigan and Amtrak since the beginning of the ITCS project. Most Amtrak trains outside the Northeast Corridor operate over other host railroads with the exception of the Michigan Line, Chicago Union Terminal and New Orleans Union Passenger Terminal. To access these terminals, Amtrak must operate over those host railroads most of which will be installing an Interoperable Train Control (ITC) system often referred to as ETMS or V-ETMS. Amtrak intends to install V-ETMS on all its mainline tracks outside the NEC and Michigan Line (with the exception of MTEA areas) and to equip its diesel locomotive fleet with V-ETMS on-board PTC equipment. The goal is to achieve interoperability with all our host railroads. 1.5.1 Functional Description of ACSES/ATC System on the NEC Amtrak will utilize ACSES and ATC to satisfy PTC requirements on the NEC (except for those areas where an MTEA is requested and granted). The table below shows how the two systems will satisfy the functional requirements of PTC. PTC Functional Requirements CSS/ATC ACSES Comments Train-to-train collision protection X X ACSES provided Positive Stop at Home Signals Overspeed protection X X MAS X Permanent civil speed restrictions X Temporary speed restrictions X Crossover speed restrictions X X ACSES provides with ATC failure Work zone intrusion protection X Vital blocking will be utilized for out of service track Protection of mainline switches X Highway crossing failure enforcement X Will enforce restricted speed to a failed crossing. ACSES was installed on the NEC beginning in 2000 in compliance with an FRA Final Order of Particular Applicability [FRA Docket No. 87-2, Notice No. 7]. ACSES is a vital overlay transponder based system which provides: ! Positive stop enforcement at interlocking home signals ! Enforcement of permanent civil speed restrictions ! Enforcement of temporary speed restrictions via a data radio network and a TSR safety server The ATC system enforces all speeds associated with the signal system for the prevention of train to train collisions and enforces restricted speed approaching any misaligned mainline switch. PTC Implementation Plan 13 Vital field blocking is used on the NEC to protect tracks taken out of service by work crews. The blocks prevent signals from being displayed to route trains into the out of service tracks. ACSES provides stop signal enforcement to prevent a train from passing a stop signal protecting an out of service track. ACSES can also be used to enforce speed restrictions approaching work zones, for example, it can be used to enforce a speed restriction on a track adjacent to an out of service track where work crews are performing their duties. ACSES will be used to enforce mandatory directives issued associated with a highway- rail grade crossing warning system malfunction as required by §§ 234.105, 234.106 or 236.107. 1.5.2 Functional Description of ITCS System on Amtrak?s Michigan Line Amtrak will utilize its Incremental Train Control System (ITCS) to satisfy PTC requirements on the Michigan Line. ITCS is a vital overlay communications based PTC system. The table below shows how ITCS and the existing wayside signal system will satisfy the functional requirements of PTC. PTC Functional Requirements CTS/ABS ITCS Comments Train-to-train collision protection X X ITCS enforces speeds associated with signal aspects and enforces a positive stop at home signals Overspeed protection X MAS X Permanent civil speed restrictions X Temporary speed restrictions X Crossover speed restrictions X Work zone intrusion protection X Protection of mainline switches X Highway crossing failure enforcement X Amtrak installed ITCS on the Michigan Line in the 1990?s and currently operates under FRA waiver at 95 mph using this system. The system is a vital communication based overlay system much like the system being proposed by the Class I railroads. It uses GPS tracking for train location and speed determination. Wayside interface units (WIU?s) at each location monitor signal status or highway crossing status. A server processor usually located at a control point gathers information from the WIU?s and then regulates train speeds via a data radio system. All speeds associated with signal PTC Implementation Plan 14 indications are enforced. All civil speed restrictions both permanent and temporary are enforced. All work zone restrictions are enforced by the system. The system has the ability to pre-start highway crossings by determining the location and speed of the approaching train, calculating the arrival time at the crossing and then communicating with the WIU at the crossing to activate the crossing warning system at the desired time interval before the train arrives. If the warning devices do not activate in time, the system will slow the train to the speed the physical track circuit approaches are set for (79 mph). The system will enforce all mandatory directives associated with a highway-rail grade crossing warning system malfunction as required by §§ 234.105, 234.106 or 236.107. 1.5.3 Functional Description of V-ETMS System Amtrak will install the V-ETMS system on its property in the Chicago Union Terminal and New Orleans Union Passenger Terminal and will overlay it on the NEC in the areas where freight or commuter trains will be equipped with V-ETMS but not ACSES (except for those areas where an MTEA is requested and granted). Amtrak will also equip its fleet of diesel locomotives which will operate in V-ETMS territory on host railroads. V- ETMS is a vital overlay PTC system. The table below shows how V-ETMS and the wayside signal system (including the CSS/ATC system) will satisfy the functional requirements of PTC. PTC Functional Requirements CTC/ABS Outside NEC CSS/ATC On NEC V-ETMS Comments Train-to-train collision protection X X X V-ETMS provides Positive stop at home signals Overspeed protection X X MAS X Permanent civil speed restrictions X Temporary speed restrictions X Crossover speed restrictions X X Work zone intrusion protection X Vital blocking will be utilized for out of service track on NEC Protection of mainline switches X X Highway crossing failure enforcement X PTC Implementation Plan 15 V-ETMS is a communication based vital overlay system that uses GPS for positioning. A Back Office Server (BOS) interfaces with the dispatching system to enable the delivery of temporary speed restrictions and other train directives to V-ETMS equipped trains. The BOS also holds a database that describes the railroad in GPS coordinates including grades, curves, speed tables, locations of signals, crossings etc. Communication between the BOS and the train is accomplished with a 220 MHz data radio. Before being dispatched, a train receives its database from the BOS along with any other movement authorities or directives. Before it enters territory equipped with V-ETMS it is queried to verify that it has the correct database version for the territory. As the train proceeds, it determines its position by an on-board GPS receiver. It enforces maximum authorized speed and permanent speed restrictions based on its database received from the BOS. It also enforces temporary speed restrictions and work zone restrictions delivered to it by the BOS. Wayside Interface Units at signal locations provide the train with signal and switch status by way of a data radio. As the train approaches a signal it obtains the signal status from the WIU and then enforces the speed associated with the signal. At interlockings, it also obtains the position switches from the WIU in order to enforce speeds associated with each switch and also to determine which track it is being routed to. A positive stop will be enforced at interlocking home signals. On the Northeast Corridor V-ETMS trains will be equipped with on-board cab signal systems. A WIU will only be required at each interlocking since signal speed enforcement can be determined by the cab signal received through the rails. The WIU at the interlocking will provide the functionality as above. Amtrak will install a BOS in the dispatching centers on the NEC to handle V-ETMS trains. A 220 MHz radio system will be installed to facilitate communication between the V-ETMS trains and the BOS. A WIU at each interlocking will provide the same information (signal and switch status) to a VETMS train (in V-ETMS message format) that it provides to an ACSES train (in ACSES message format). The system will enforce all mandatory directives associated with a highway-rail grade crossing warning system malfunction as required by §§ 234.105, 234.106 or 236.107. 1.6 Success Criteria Success of PTC implementation on Amtrak will be measured by the following: ! FRA approval of the PTC Implementation Plan ! FRA certification of ACSES and ITCS ! Completion of the implementation of ITCS on the Michigan Line by the end of 2011 ! Increase in operating speed on the Michigan Line to 110 mph ! Completion of the implementation of ACSES on the remaining portions of the NEC by December 31, 2012 (three years ahead of the mandate) ! Equipping the locomotive fleet operating in the Los Angeles basin with V-ETMS and receiving FRA approval for operation by December 31, 2012 PTC Implementation Plan 16 ! Completion of PTC implementation in Chicago and New Orleans before 2015 ! Completion of V-ETMS implementation on the NEC before 2015 ! Achieving interoperability of ACSES with tenant railroads on the NEC ! Achieving interoperability of V-ETMS with both host and tenant railroads ! Implementing PTC within the allotted budget 1.7 Applicability PTC will be fully implemented on all of Amtrak mainline tracks (except where an MTEA is requested and approved by FRA). 1.8 Document Overview Following is a description of the sections of this document and the information which will be conveyed in each section: ! Section 1 describes the general objectives, applicability, and scope of the document. ! Section 2 lists applicable documents that are referenced in this PTCIP. ! Section 3 describes the technology that will be deployed as required by § 236.1011(a)(1). ! Section 4 describes how Amtrak intends to comply with § 236.1009(c) as required by § 236.1011(a)(2). ! Section 5 defines how Amtrak will provide for interoperability between Amtrak and all tenant railroads as required by § 236.1011(a)(3). ! Section 6 describes how the PTC system will be implemented to address areas of greater risk to the public and railroad employees before areas of lesser risk, by evaluating multiple risk factors, as required by § 236.1011(a)(4). ! Section 7 defines the sequence, schedule, and decision basis for the line segments to be equipped, including the risk factors by line segment, as required by § 236.1011(a)(5). ! Section 8 contains information related to the rolling stock that will be equipped with the PTC technology, as required by § 236.1011(a)(6). ! Section 9 identifies the number of wayside devices required for each line segment and the schedule to complete the installations by December 31, 2015, as required by § 236.1011(a)(7). PTC Implementation Plan 17 ! Section 10 identifies which track segments Amtrak designates as main line and non-main line track, as required by § 236.1011(a)(8). ! Section 11 identifies and describes Amtrak?s basis for determining that the risk- based prioritization in Section 6 above is not practical as required by § 236.1011(a)(9). ! Section 12 identifies and describes any alternative arrangements for each rail-to- rail at-grade crossing not adhering to the table under § 236.1005(a)(1)(i) as required by § 236.1011(a)(10). ! Section 13 contains the Main Line Track Exclusion Addendum (MTEA) as defined by § 236.1019. ! Section 14 contains Appendices either referenced in this document or that contain supporting information that may aid to understanding of this PTCIP. 1.9 Acronyms and Definitions The following is a list of some abbreviations and acronyms used in this PTCIP: ACSES Advanced Civil Speed Enforcement System ATC Automatic Train Control CFR Code of Federal Regulation CUS Chicago Union Station FRA Federal Railroad Administration ITC Interoperable Train Control ITCS Incremental Train Control System MTEA Main Line Track Exclusion Addendum NEC Northeast Corridor NOUPT New Orleans Union Passenger Terminal PIH Poison by Inhalation Hazard PTC Positive Train Control PTCDP Positive Train Control Development Plan PTCIP Positive Train Control Implementation Plan PTCSP Positive Train Control Safety Plan RFA Request for Amendment TIH Toxic Inhalation Hazard U.S.C. United States Code V-ETMS Vital Electronic Train Management System PTC Implementation Plan 18 The following is a list of definitions of terms used in this document: ACSES A vital overlay transponder based system that combined with Automatic Train Control provides PTC functionality Class I railroad A railroad which in the last year for which revenues were reported exceeded the threshold established under regulations of the Surface Transportation Board (49 CFR part 1201.1- 1(2008)). Host railroad A railroad that has effective operating control over a segment of track. Interoperability The ability of a controlling locomotive to communicate with and respond to the PTC railroad?s positive train control system, including uninterrupted movements over property boundaries. ITC System An interoperable train control system being proposed by the major Class I freight carriers. ITCS A vital overlay communication based PTC system used on Amtrak?s Michigan Line Main line Except as excepted pursuant to § 236.1019 or where all trains are limited to restricted speed, a segment or route of railroad tracks, including controlled sidings: (1) of a Class I railroad, as documented in current timetables filed by the Class I railroad with the FRA under § 217.7, over which 5,000,000 or more gross tons of railroad traffic is transported annually, as reported on the traffic density map required to be filed with the Surface Transportation Board pursuant to § XXX.XX; or (2) used for regularly scheduled intercity or commuter passenger service, as defined in 49 U.S.C. § 24102, or both. Main line track exclusion addendum The document defined by § 236.1019. PTC Positive Train Control as further described in §236.1005. PTCDP PTC Development Plan as further described in §236.1013. PTCIP PTC Implementation Plan as required under 49 U.S.C. §20157 and further described in §236.1011. PTC railroad Each Class I railroad and each entity providing regularly scheduled intercity or commuter rail passenger transportation required to implement and operate a PTC system. PTCSP PTC Safety Plan as further described in §236.1015. PTC System Certification Certification as required under 49 U.S.C. § 20157 and further described in §§ 236.1009 and 236.1015. PTC Implementation Plan 19 Request for Amendment A request for an amendment of a plan or system made by PTC railroad in accordance with § 236.1021. Segment of track Any part of the railroad where a train operates. Tenant railroad A railroad, other than a host railroad, operating on track upon which a PTC system is required. Track segment Segment of track V-ETMS An interoperable train control system being proposed by the major Class I freight carriers. Also referred to as ITC System. PTC Implementation Plan 20 2.0 Applicable Documents Following is a list of documents and information sources referenced in this PTC Implementation Plan: A. Title 49 CFR Part 236, Subpart I ? Positive Train Control Systems B. NORAC Operating Rules ? latest edition C. General Code of Operating Rules ? latest edition D. Order of Particular Applicability [FRA Docket No. 87-2, Notice No. 7] E. Amtrak Northeast Corridor Employee Timetable No. 3 ? Most recent General Order F. Amtrak Michigan Line Timetable No.2 G. Amtrak Chicago Terminal Timetable No. 3 H. Amtrak New Orleans Union Passenger Terminal Timetable No. 3 I. EP-5900 Software Management Control Plan for Processor-Based Signal & Train Control Systems ? latest revision J. SMP 38406 ? Software Management Control Plan for Microprocessor Based Train Control System, Amtrak Mechanical Department ? latest revision PTC Implementation Plan 21 3.0 Technology [§ 236.1011(a)(1)] 3.1 ACSES and ATC on the Northeast Corridor In compliance with an Order of Particular Applicability [FRA Docket No. 87-2, Notice No. 7], Amtrak installed a transponder based system designed to enforce civil speed restrictions, both permanent and temporary, and to enforce a positive stop at interlocking home signals. This system, know as ACSES, was installed and placed in service beginning in 2000 with the startup of Acela service on the Northeast Corridor. The combination of ACSES and the existing ATC system provided the basic requirements of a PTC system. The ATC system enforces all speeds associated with the signal system preventing train-to-train collisions (236.1005(a)(1)(i), and the ACSES system prevents trains from passing stop signals at interlocking home signals. ACSES enforces all permanent civil speed restrictions and temporary restrictions (slow orders) thereby preventing over speed derailments (236.1005)(a)(1)(ii). Amtrak has filed a Request for Expedited Certification (REC) and type approval for the ACSES system. 3.1.1 ACSES Overview ACSES on the Northeast Corridor (NEC) supplements the ATC system by providing additional functions and thus creating an enhanced overall train control system meeting the requirements of PTC. The primary functions of ACSES as applied to the NEC include enforcement of civil/track speeds for fixed locations such as curves, bridges, etc. as well as temporary speed restrictions. These are speed enforcement functions that are beyond the scope of the ATC CAB SIGNAL subsystem. ACSES also enforces Positive Train Stops at interlocking home signals. The ACSES system enforces permanent and temporary speed restrictions and a positive stop at home signal locations. The onboard system uses data obtained from Transponders and via a data radio network to enforce permanent and temporary speed limits. It acts on data received intermittently from Transponder and radio and it is a profile-based system where the onboard system calculates a speed profile for both warning and enforcement. If the warning profile is exceeded the engineer is given an audible alert to reduce the train speed. If the brake profile is exceeded the onboard system initiates a request for application of the train brakes that will be released when the train speed is back under the maximum speed envelope. The ACSES system util izes passive (fixed) Transponders at wayside locations, a Ground Network communications system (Safety TSR Server, Wayside Communications Controllers (WCC), Network Servers & Encoders), Base Communications Packages (BCP) along the Right Of Way (ROW), Mobile PTC Implementation Plan 22 Communications Packages (MCP) onboard, ACSES onboard subsystem and onboard Transponder reader. The data radio system (WCC, BCP and MCP) is used to route interlocking data (route data, civil speed limits, etc.) and temporary speed limit data (start of speed restriction, length of speed restriction, speed limit, etc.) to the onboard ACSES system. The ACSES wayside Transponders are installed in ACSES territories at home signals, distant signals and at other signal, block point, or cut section locations to communicate with the onboard ACSES subsystem. The Transponders provide data to the onboard system, allowing it to determine its location and direction along the track. The Transponders also provide civil (track) speed restriction data for the territory ahead, thereby ensuring that speeds are kept safe for the various types of restrictions not caused by train occupancy (bridges, curves, etc.). ACSES works on a distance to target principle and the Transponder data includes targeting distances (distance from the Transponder to the data validity point), therefore Transponders do not need to be installed at the point at which the system uses the data (i.e. the Transponders are not installed at the speed change limit but in advance of it). The ACSES system consists of two main areas of operation, Interlocking areas and Automatic Block (between interlocking) areas. Within these two areas, the ACSES system provides civil speed and temporary speed and positive stop enforcement (at interlocking areas only). In addition, if the ATC cab signal system is inoperative or cut- out ACSES enforces a maximum cap speed of 79 MPH. The ACSES system works in conjunction with the ATC/cab signal systems used on the Northeast Corridor (NEC). The ATC CAB SIGNAL system continues to ensure ?Safe Train Separation? and ?Signal Speed Enforcement? while the ACSES system essentially acts as an addition to the ATC CAB SIGNAL system to provide other functions. The two systems are functionally independent. Only the operating status (cut-in and operating or cut-out) and data used for the PTS enforcement (e.g. the ACSES request for an ATC CAB SIGNAL enforcement of a PTS is shared between the two systems). 3.1.2 ACSES Functions and Architecture ACSES is a vital overlay system that performs the following main functions: 1. Enforcement of permanent speed restrictions (PSR) (civil/track speeds) for five different train types. 2. Enforcement of temporary speed restrictions (TSR) through data radio network of by use of temporary transponders. 3. Enforcement of a Positive Train Stop (PTS) at interlocking home signals. 4. Override of the PTS (PTSO) by radio if the interlocking signal status allows the train to proceed. PTC Implementation Plan 23 5. Enforcement of a civil speed received by radio based on switch alignment at interlockings. This speed corresponds to the diverging or crossover civil speed (Interlocking PSR). 6. Route Dependent speed enforcement based on exit track selection (route dependent PSR). 7. Utilizing the communications network, upload of the ACSES specific Maintenance Messages to Amtrak NEC Network Servers (ACSES Maintenance Message). The figure below shows a basic block diagram of the ACSES System. CETC TSR Interface TSR Safety Server (2 out of 3) And Network Servers Redundant Communications Network (WCC, MUX, DSU,?) BCP Encoder Or WIU Vital Signal Circuits Dispatching Office Server Equipment Room Wayside Interlocking Location Transponders Figure 3.1.2 ACSES System Diagram PTC Implementation Plan 24 3.1.3 ACSES Onboard Equipment Following is a description of the main elements of the ACSES onboard equipment. A block diagram of the onboard system is shown in Figure 3.1.3. An interface between the ACSES Onboard Computer and the ATC system allows ACSES to determine if the ATC system is cut-in or cut-out. With the ATC system cut out, ACSES caps the upper speed limit to 79 mph and continues to enforce all civil speeds below 79 mph. 3.1.3.1 ACSES Onboard Computer The ACSES Onboard Computer acts upon the data received from the Transponders, Encoders and Safety TSR Server to execute the ACSES functions. The onboard ACSES subsystem uses data obtained from Transponders and via a data radio network to enforce permanent and temporary speed limits. It acts on data received intermittently from Transponder and radio and it is a profile-based system where the onboard ACSES subsystem calculates a speed profile for both warning and enforcement. If the warning curve is exceeded, the engineer is given an audible alert to reduce the train speed. If the brake curve is exceeded, the onboard ACSES subsystem initiates a request for application of the train brakes that can be released when the train speed is back under the maximum speed envelope. 3.1.3.2 ADU The ACSES Display Unit is the main means by which the ACSES system provides information to the train operator. 3.1.3.3 Transponder Reader and Antenna The Onboard Transponder Transmission equipment and passive (fixed) wayside Transponders provide the Civil Speed information and location of Home Signals for Positive Train Stop (in addition to current track, location, direction, radio channel, etc...). 3.1.3.4 MCP The Onboard (Mobile Communication Package) Radio system is used to transmit TSR, Interlocking status, and Maintenance data to/from the train. MCPs are compatible to the ATCS Specification 200. PTC Implementation Plan 25 ACSES On-Board Computer ADU ATC System MCP Train Type Selector Switch Transponder Reader/Antenna Speed Sensor Brake System Interface Audible Alarm Figure 3.1.3 Block Diagram of ACSES On-Board System 3.1.4 Main ACSES Wayside Equipment 3.1.4.1 Transponders Civil speeds, PTS and other data are transmitted to the onboard ACSES subsystem through digital fixed transponders installed between the rails in the ACSES territories. Fixed transponders always transmit the same message, which is contained in a transponder plug (BCB - an EPROM chip inside a protective cover) programmed with the necessary local data. The Transponders are passive devices mounted between the rails at cut sections, home signals and intermediate signals as necessary. The transponders inform the Onboard ACSES subsystem of: ! An upcoming Positive Train Stop (PTS) to enforce ! When and how to contact the encoder to get the signal status and the route ! An upcoming Speed Restriction and the civil speed to enforce ! When and how to request the TSR list from the TSR server ! Its position on the railroad allowing it to enforce the TSRs received over the radio PTC Implementation Plan 26 ! Other miscellaneous functions (begin ACSES territory, end ACSES territory, etc.) The transponder is read when the transponder scanner antenna is directly over the wayside transponder. The Onboard ACSES is responsible for turning the onboard Transponder Transmission Subsystem ON or OFF though the TTS interface and messages. The Onboard ACSES controls this interface. Once powered, the transponder antenna will remotely energize any transponders it passes over. When energized, the transponders continually transmit its 255-bit message received at the antenna. This message is then passed to the Main Processor for interpretation. The data content is 180 bits with the rest devoted to error detection, including a 72-bit CRC used to guarantee message integrity. The 72-bit CRC is used to validate that the message received is not corrupted. The data portion of the transponder message is organized in packages, which are unique messages containing specific information for specific purpose. Each transponder set is encoded with its location. This location includes the railroad territory, chaining, the milepost and the track number. Chaining information is available from ODD numbered transponders while milepost information is available from EVEN numbered transponders. Chaining is required for enforcement of TSRs received via the communication system. Milepost is used for maintenance purpose only. Chaining values and not Milepost values are used for the purpose of enforcing TSRs since the Milepost system on the NEC is non-linear. Transponders are installed in sets ranging from 2 to 4 transponders. The transponder sets are also sometimes referred to as ?Information points? containing up to 720 bits of data (180 bits x 4). The amount of data to transmit to the Onboard ACSES subsystem at a location dictates the number of transponders required for the set. A transponder set contains data for both directions of travel. Each transponder is encoded with its location. This location includes the railroad territory, chaining, the milepost and the track number. A temporary transponder may be encountered within the linking distance of two permanent transponders. Temporary transponders are used to invoke temporary speed restrictions. These temporary transponders are unlinked and do not affect the normal linking of permanent transponders. They may also be installed in the Non-ACSES territories to perform miscellaneous functions. 3.1.4.2 Encoders or Wayside Interface Units (WIU) The Encoders or WIUs interface with the signal logic at interlockings to provide status of the interlocking to the onboard ACSES subsystem (signal status (go/stop), exit track and route, civil speed limit based on switch alignment, etc). Each Encoder contains an application program that is used to define the data PTC Implementation Plan 27 messages to be sent to the trains based on the Encoder input status. Each Encoder is interfaced to the communications network via a serial link to a BCP. Each interlocking, in ACSES territory, is equipped with an Encoder connected to the wayside data radio network. The Encoder monitors the status of the signals and switches in the interlocking. The Transponder data that informs the onboard ACSES subsystem that it is approaching an interlocking home signal also provides the onboard ACSES subsystem with the necessary information (radio channel, Encoder id, signal id, etc.) to address, via the data radio network, the appropriate Encoder. The Encoder responds to this request message with the appropriate data for the home signal being approached. The encoder will send a data message, upon request, to the Onboard ACSES subsystem informing it that the home signal is at STOP or not. The Onboard ACSES subsystem uses this information to release the PTS if the signal is not at Stop. The encoder message also contains other data that includes: ! The track the train will exit the interlocking on. ! The civil speed limit for the selected route. ! C signal status in ?cab signal without wayside signal? territory. ! Distance to the next interlocking (LoMA) if there is not sufficient distance from the exit of the first interlocking to the PTS target of the next interlocking. ! The distance from the point where the train diverges from the entrance track to the point where the train converges on the exit track. ! A list of the tracks the train will cross during its move through the interlocking. This data on the status of the interlocking route is required by other functions of ACSES such as TSR, Interlocking PSR and Route Dependent PSR. The Encoder data will also contain information about an adjacent interlocking home signal if the distance between the home signals is less than safe braking distance (this is called the LoMA or limit of movement authority distance). This data is used to allow the onboard ACSES subsystem to anticipate the next home signal and generate the correct profile to insure that, if necessary, a stop is enforced. 3.1.4.3 Safety TSR Server The wayside ACSES system also features a TSR Server(STS). The TSR Server is responsible to safely manage the TSR data. The TSR information compiled by the NEC dispatchers is converted to digital data and transmitted to the TSR Server. The TSR data includes the location of the TSR (railroad & line, track, start PTC Implementation Plan 28 milepost), the length of the restriction, and the speed limit of the restriction for passenger and freight trains. Only two restriction speeds are provided in a TSR. All passenger trains (train types A, B, C, and D) use the passenger train speed restriction limit and all freight trains (type E) use the freight train speed restriction limit. The STS manages the addition and removal of TSR data. The Transponder data that causes the onboard ACSES subsystem to request Encoder data also causes the onboard ACSES subsystem to request TSR data. This request is routed by the wayside radio system to the TSR Server. The TSR Server responds with all the TSRs for all the tracks, in the train?s direction of travel only, for the area covered by the local radio base station plus the next two radio base stations. The Onboard ACSES subsystem uses this data along with its location, and direction of travel to enforce these restrictions in exactly the same manner as it enforces a PSR. In all cases the onboard ACSES subsystem enforces the lowest speed limit required for each point along the track. The Safety TSR Server (STS) is located at a central location and manages Temporary Speed Restriction data for all ACSES territories. The STS is responsible for maintaining the list of TSRs and providing them to the trains upon request. Amtrak plans to install additional TSR servers so that one server set is allocated to each of the three NEC dispatching centers. 3.1.4.4 Network Servers The Network Servers (NS) are located next to the STS. The Network Servers are responsible for the communication interface between the ATCS specification 200 communications system, the TCP/IP communications link to CETC, and the serial interface to the STS. It acts as a gateway between the STS and the external system interfaces. The Network Servers also receive the ACSES-specific Maintenance Messages intended for Amtrak maintenance personnel. The Network Servers also log all transactions and provide a means for the archiving of this data. 3.1.4.5 BCPs Wayside Base Communication Package Radio system used to transmit TSR, Interlocking, and Maintenance data to/from the train. They are installed in interlocking areas. One BCP can interface with more than one encoder. BCPs are compatible to the ATCS Specification 200. 3.1.4.6 Wayside Communications Controllers The Wayside Communications Controllers (WCC) are redundant communications equipment installed at a central location that control message routing and delivery between equipment. Communications links between the WCCs and the BCPs are fully redundant to increase the availability of the ACSES radio functions. WCCs are compatible to the ATCS Specification 200. PTC Implementation Plan 29 3.1.5 ACSES Train Types There are five different types of train configurations on the NEC that are considered as part of the ACSES implementation. They are defined as follows in the NEC timetable: ! Type A - High Speed Train set with tilting. ! Type B - High Speed Train set without tilt operating or trains meeting AEM-7 w/Amfleet braking curve. ! Type C ? Other passenger trains meeting Amtrak CE-205 braking curve. ! Type D ? Mail and Express trains (no longer being operated). ! Type E ? Freight trains. These train types correspond to different sets of operating speeds of the Amtrak timetable. They also have different braking profiles. Moreover, certain vehicles and locomotives are of multi-purpose usage and can operate as different train types depending on the nature of the train's mission. ACSES provides overspeed protection specific to each NEC train type. The onboard ACSES subsystem is set to one of the five train types when originally configured, or before a run via the Train Type Selector Switch (TTSS) installed in the multi-purpose vehicles, and uses the data from the transponders and radio that corresponds to its train type. It also uses a different braking profile according the train type set for the vehicle. 3.1.6 ACSES Data Communication System Concepts The radio system allows exchange of data between the Onboard ACSES and the wayside equipment for dynamic updates of data. The radio data for the NEC application include: ! Status of interlocking signals and route ! Temporary Speed Restriction data ! Maintenance data ACSES on the NEC was implemented using ATCS 200 900 MHz, which proved to be adequate for the NEC needs. However, the ACSES application is not dependant on the communication system technology, as the data radio and comms system is only a functional message conduit for ACSES application. The integrity of the data transmission is not dependent on ATCS communications PTC Implementation Plan 30 since the ACSES safety- critical application layer was designed independently from the non-vital communication application layers. For example, the application messages are self-protecting and are of the same basic format as the transponder messages, which is a proven format. Additional "checks" are performed onboard to ensure protection from duplicate messages, against data storage and against communication message routing errors in the non-vital communication system. Amtrak intends to use a 220 MHz data radio for future ACSES expansion but this will not change the message format in any way. For radio communications, the Onboard is the master of the system from a train control application standpoint as it initiates all requests for data. It will initiate the requests based on the information provided by the transponders. The wayside TSR Server and Encoders only respond to Onboard requests for data. The NEC data radio transmission system is non-deterministic and, by design, ACSES is capable of accepting responses to radio requests that may be few communications cycles old. Since ACSES received data from transponders and is paired to the ATC system, the requirements for radio communications are not as critical as other communications-based systems, which require radio data to be updated frequently (often continuously) onboard. The concept for the NEC is that ACSES needs to tolerate missed radio messages. The keys are that several opportunities to obtain the data before it is required are provided and, once data is received onboard, it will remain valid for a certain time until it is declared too old to maintain safety, at which point the radio data received is deleted with ACSES reverting to the appropriate safe state. Encoders are installed at every interlocking but ATCS BCP radios are installed at every interlocking ?area?, which may include one or several interlockings located close together. The BCPs are connected to the centrally controlled ATCS Wayside Communications Controllers (WCC) that interfaces to the TSR server. 3.1.7 Infrastructure Data The infrastructure data (civil speeds, PTS target, milepost, chaining, track number, etc.) is loaded directly in the transponder program. Data is also loaded in the Encoder program located at the interlockings. This encoder data includes crossover or diverging speed at interlockings, exit track data, discrete input configuration, etc. The Safety TSR Server (STS) also hosts a database. This database contains the infrastructure information required by the TSR server (track layout, Milepost/Chaining conversion, grade, etc.). The database does not contain civil speed and other permanent speed restriction. The transponder and encoder data is contained in a database (one database per railroad line segment) that is stored on a PC. It is accessed and modified using a specific application named the ACSES Programming Tool (APT) developed by Alstom. The APT is also used to program transponders and encoders. The STS data is also PTC Implementation Plan 31 contained in a database (an excel table) named the Fixed Database and the Fixed Database Tool is the tool used to convert the Excel file to the Motorola S3 format for programming the data on the memory cards of the STS. 3.1.8 ACSES Safety ACSES is comprised of: ! Onboard System (vital) ! Transponders ! Encoders (vital) ! Safety TSR Server (vital) ! Network Servers ! Control Center application for TSR entry ! Centralized maintenance system ! Communications system (ATCS compliant radios and network) The vital ACSES equipment includes the Onboard system, the Encoder and the Safety Server. To perform its functions ACSES also uses safety critical data. Transponder, Encoder and Safety TSR Server application data is safety-critical. In addition, the data message exchanged between the vital equipment, via the comms system, is safety critical. Note that the transponders are not vital components. The vitality of the data transfer is ensured by self-protecting data (with use of large "check words") combined with other consistency checks performed by the vital components on the data received. The same principle is used for the radio transmission. The data design and installation in the field follows a strict process to ensure the data is correct, accurate and ensures safe for operation. The interface between the Safety Server and the non-vital Control Center application for the TSR addition and deletion obeys a rigorous select-check-execute process, but the correctness of the data is still under the responsibly of the dispatcher as ACSES cannot evaluate the correctness of the information entered by the Dispatcher fully on its own. PTC Implementation Plan 32 3.2 ITCS on Amtrak?s Michigan Line 3.2.1 General Description The ITCS is a communication-based signaling system designed as a vital overlay to an existing signal system. It provides enforcement of signal indications, civil speed limits, and temporary slow orders. In addition, it provides advanced start of public crossings and Restricted Speed enforcement over hand-operated switches. ITCS monitors the existing signal system as a basis for determining permissible actions, and uses a radio frequency (RF) data link with a vital communication protocol to send wayside status information to the trains. Enforcement of indications and the speed limit are performed vitally by an onboard computer (OBC). The OBC stores the track information in database files, which includes civil speed limits of the ITCS territory, grade along the tracks, a list of devices and their locations that may need to be communicated to the train, as well as other information. The train's location on the track is determined by the location system utilizing the Global Positioning System (GPS) and axle tachometers. Train?s location is compared to the points in the database file to determine the required actions. The Wayside components monitor signal aspects, switch positions, crossing warning systems, and other equipment as required. This information is relayed to the train OBC over the RF network as a list of device statuses. The OBC interprets the statuses, and enforces all signal indications, speed limits, and other required braking. At crossings, an additional feature allows an OBC on a train traveling at high speed to radio ahead to a crossing for an advance start of the warning system. The OBC must receive an acknowledgment from the crossing, verifying the proper operation of the crossing warning system, before the train can proceed at high speed through the approach circuit. The OBC calculates the most restrictive speed limit based on the inputs from the databases, the wayside devices, the train?s location system, and the train?s speed. The OBC then determines when a reduction in speed is required for an upcoming device or speed limit. If a reduction is needed, the OBC calculates a braking profile for the train, and displays the necessary information for the driver, who must slow the train to an appropriate speed. If the train reaches a point where the brakes must be applied to meet the target speed, the OBC applies a penalty brake. The OBC also monitors the train?s current speed and compares it to the maximum allowed speed. If the train accelerates above the allowed speed limit, the OBC warns the operator. A penalty brake results when a critical speed is exceeded. An office terminal allows the dispatcher to enter Temporary Slow Orders (TSO) into the system. These restrictions are sent to the Wayside Interface Unit (WIU)-Servers, which in turn transmit the information to the OBC as the equipped trains pass through ITCS Territory. PTC Implementation Plan 33 Michigan/Amtrak ITCS System Block Diagram CLD OB C OFFICE SYSTEM WIU Server Intermediate Signal WIU Control Point WIU Hand Operated Switch WIU Public Crossing WIU OBC - On Board Computer WIU - Wayside Interface Unit CLD- Compact Locomotive Display GPS Satellites TD220 Radio TD220 Radio GPS RIMs GPS RIM - Global Positioning System Receiver Interface Module Onboard Train Controls WLAN Existing Relay Logic Signal Indications, Track Circuit Input Signal Indications,Track Circuit Inputs, OS Track Circuits, Normal / Reverse Switch Positions Normal / Reverse Switch Positions GPS Reference Station - Novatel GPS Satellites GPS RIM Reference Station- Motorola O W L OWL - Office / Wayside Link SSR-Spread Spectrum Radio TWC Network On-Board Equipment Speed Sensors SSR S S R S S R S S R S S R Modem To Other WIU Servers To Other WIUs Modem Crossing Warning Device Figure 3.2.1-1 Block Diagram of ITCS Components PTC Implementation Plan 34 Figure 3.2.1-2 ITCS Overview 3.2.2 ITCS Components 3.2.2.1 On Board Computer (OBC) The OBC consists of two logical functions, the Automatic Train Protection (ATP) function, and the Location Processing function. The ATP function performs communication tasks, determines the train's speed and provides vital braking enforcement. The Location Processing function determines the location of the train. 3.2.2.2 GPS Receiver Interface Module (GPSRIM) Two GPSRIM collect data from the GPS satellites, and, using differential correction data originated by the GPS Reference Stations, provide longitude, latitude, and speed data to the Location Processing function of the OBC. 3.2.2.3 Compact Locomotive Display (CLD) The CLD displays information from the OBC to the train driver, provides audible alarms for various warnings, and provides inputs for driver control of the on-board system. An LED-based display provides information to the train driver. This Compact Locomotive Display (CLD) communicates with the OBC via the CAN protocol and an RS-485 port. The CLD also contains several user input switches, and an alarm for audible indication of important events to the locomotive crew. At a minimum, the CLD displays the following information when appropriate: Dispatch Center Temporary Slow Orders and Wayside Status Messages to Train ITCS Server Location WIU Location GPS Satellites Temporary Slow Orders PTC Implementation Plan 35 ! Current speed ! Current speed limit ! Current target speed ! Current Time to Penalty ! Distance to current target ! Current target type ! Train Location, to the nearest 1/10th mile ! The Type of Train 3.2.2.4 Train to Wayside Communications Network (TWC) The TWC Network provides a bi-directional data communications link between the on- board equipment and the wayside equipment. Each OBC and WIU-Server in the ITCS system has an ITCS address. The TD220 radio interprets an ITCS address in order to direct a received message to the intended device. The TD220 radio is considered part of the TWC network. An interface between the TD220 and the NovAtel (Wayside only) provides a one pulse per second output and time measurement to synchronize the TD220 radio for Time-Division-Multiplexing (TDM) operation. The on-board TD220 radio does not require GPS data for timing. The TWC must provide a reliable link for the OBC and WIU-Server beyond the boundary of the WIU-Server?s WLAN. The exact distance from the WIU-Server depends on the speed limits in the area and the boundary of the WIU-Server?s region. 3.2.2.5 Wayside Interface Unit (WIU) The WIU interfaces to new or existing equipment along the track. It may provide vital inputs, outputs, or both, and has the capability of running application logic equations. The WIU communicates with the WIU-Server over the WLAN. 3.2.2.6 Wayside Interface Unit ? Server (WIU-Server) In addition to performing the basic WIU functions, a WIU-Server provides an interface to the TWC network, and is the master device on a WLAN. The WIU-Server also contains an interface to the Office Terminals through the Office to Wayside Link. At each server are two GPS reference stations. The GPS antenna position for each reference station is surveyed for accuracy to within one foot. The reference stations provide the differential corrections to the GPSRIM pairs located on the trains while the trains are within the server?s region. Each reference station provides correction data for one half of each train?s GPSRIM pair. One of the reference stations also provides UTC time to the WIU-Server for time tagging log information and a highly accurate time base PTC Implementation Plan 36 to the TD220 radio for synchronizing its time-division-multiplexed (TDM) transmissions over the TWC. 3.2.2.7 Terminal Server The Terminal Server is a special type of server that exists at certain locations, typically near a terminal, to aid the OBC in performing its Departure Test and to transmit the entire set of ITCS Databases to the OBC. 3.2.2.8 Wayside Local Area Network (WLAN) The WIUs and WIU-Server communicate over a Spread Spectrum Radio (SSR) link and exchange messages containing the status of the wayside equipment as monitored by the WIU and the information necessary for ITCS control of the crossing warning systems. 3.2.2.9 Office to Wayside Link The Office to Wayside Link provides a bi-directional data communications link between the Office Terminal and the WIU-Servers. 3.3 Amtrak?s Implementation of V-ETMS 49 CFR §236.1011(a)(1) requires that the PTCIP describe the functional requirements that the proposed PTC system must meet. As required by 49 CFR 236, Subpart I, §236.1013, the PTCDP describes how V-ETMS® satisfies the mandated requirements for PTC systems as outlined in §236.1005. Amtrak will be using the PTC Development Plan (?PTCDP?) prepared by Wabtec Railway Electronics (?WRE?), CSX Transportation (?CSXT?), Norfolk Southern Railway, and Union Pacific Railroad (?UPRR?) which was submitted to the FRA on March 24, 2010 (FRA Docket 2010-0028) for review and approval. The PTCDP was jointly submitted for FRA Type Approval as set forth under 49 CFR Part 236, Subpart I §236.1009(b) and included documentation as required by §236.1013. The Vital Electronic Train Management System (V-ETMS®) Development Plan describes development of the WRE Vital Electronic Train Management System (V- ETMS), an interoperable PTC system developed in compliance with requirements and standards defined through the Interoperable Train Control (?ITC?) industry effort (Amtrak participated in ITC committee meetings). V-ETMS is a locomotive-centric, vital train control system designed to be overlaid on existing methods of operation and provide a high level of railroad safety through enforcement of a train?s authorized operating limits, including protection against train-to train collisions, derailments due to overspeed, unauthorized incursion into work zones, and operation through main track switches in improper position. The V-ETMS system is designed to support different railroads and their individual methods of operations and is intended to be implemented across a broad spectrum of railroads without modification. This design approach supports interoperability across railroads as V-ETMS equipped locomotives apply consistent warning and enforcement rules regardless of track ownership. PTC Implementation Plan 37 An overview of the V-ETMS system, its primary functions, the architecture of the PTC system(s) being deployed, and a high level description of the functionality of the PTC system, subsystems, and interfaces are all found in the PTCDP. Specifically, these areas are addressed in the following sections: ! Section 3, V-ETMS Description, which provides a complete description of the V-ETMS system including a list of all product components and their physical relationships in the subsystem or system, as required by 49 CFR 236 Subpart I §236.1013(a)(1). 3.1 LOCOMOTIVE SEGMENT 3.2 OFFICE SEGMENT 3.3 WAYSIDE SEGMENT 3.4 COMMUNICATIONS SEGMENT 3.5 DATA FLOW 3.6 V-ETMS PRIMARY FUNCTIONS Section 4, PTC Architecture, which describes how V-ETMS architecture satisfies safety requirements as required by 49 CFR 236 Subpart I §236.1013(a)(4). 4 PTC Architecture 4.1 LOCOMOTIVE SEGMENT 4.1.1 V-ETMS Train Management Computer 4.1.2 Computer Display Unit 4.1.3 GPS Receiver 4.1.4 Locomotive Event Recorder 4.1.5 Train Control Application 4.1.6 Business Applications 4.2 OFFICE SEGMENT 4.2.1 V-ETMS Office Segment 4.2.2 Office Server Platform 4.2.3 Office Segment External Interfaces 4.3 WAYSIDE SEGMENT 4.3.1 WIU Technology 4.4 COMMUNICATIONS SEGMENT 4.4.1 The Messaging System 4.4.2 Wireless Networks The Concept of Operations as required by §236.1013(a)(3) is covered in Section 7 of the PTCDP. This portion of the PTCDP addresses each of the PTC functional requirements as called out in the Subpart. While the entire Concept of Operations provides a thorough understanding of the system?s ability to meet the requirements, for the purpose of this document, each requirement will be addressed with a reference within the Vital Electronic Train Management System (V-ETMS®) Development Plan, Section 7, Concept of Operations as follows: § 236.1005 Requirements for Positive Train Control systems. PTC Implementation Plan 38 (a) PTC system requirements. Each PTC system required to be installed under this subpart shall: (1) Reliably and functionally prevent: (i) Train-to-train collisions?including collisions between trains operating over rail-to-rail at-grade crossings ? ! Section 5.4.1 Movement Authority Provided by Mandatory Directive ! Section 5.4.2 Wayside Signals ! Section 5.4.3 Cab Signals ! Section 5.4.4 Reverse Movement ! Section 5.4.5 Switching Mode ! Section 5.4.6 Entry to V-ETMS Territory ! Section 5.4.7 Exit from V-ETMS Territory ! Section 5.4.8 Yard Limits ! Section 5.11 Warning and Enforcement ! Section 5.11.2 Predictive Warning and Enforcement ! Section 5.11.3 Restrictive Speed Enforcement ! Rail-to-rail crossings-at-grade that have one or more PTC routes intersecting with one or more routes without a PTC system must have an interlocking signal arrangement in place developed in accordance with subparts A through G of part 236 and a PTC enforced stop on all PTC routes. FRA has also determined that the level of risk varies based upon the speeds at which the trains operate through such crossings, as well as the presence, or lack, of PTC equipped lines leading into the crossing. Accordingly, if the maximum speed on at least one of the intersecting tracks is more than 40 miles per hour, then the routes without a PTC system must also have either some type of positive stop enforcement or a split-point derail on each approach to the crossing and incorporated into the signal system, and a permanent maximum speed limit of 20 miles per hour. (ii) Overspeed derailments, including derailments related to railroad civil engineering speed restrictions, slow orders, and excessive speeds over switches and through turnouts; ! Section 5.4.8 Yard Limits ! Section 5.5 Speed Limits and Restrictions ! Section 5.5.1 Permanent Speed Restrictions ! Section 5.5.2 Temporary Speed Restrictions ! Section 5.5.3 Track Authority Speed Restrictions ! Section 5.5.4 Consist or Lading Speed Restriction ! Section 5.11 Warning and Enforcement ! Section 5.11.1 Reactive (Overspeed) Warning and Enforcement ! Section 5.11.2 Predictive Warning and Enforcement ! Section 5.11.3 Restricted Speed Enforcement PTC Implementation Plan 39 (iii) Incursions into established work zone limits without first receiving appropriate authority and verification from the dispatcher or roadway worker in charge, as applicable and in accordance with 49 CFR part 214 ! Section 5.6 Work Zones ! Section 5.11 Warning and Enforcement ! Section 5.11.2 Predictive Warning and Enforcement (iv) The movement of a train through a main line switch in the improper position as further described in § 235.1005(e). ! Section 5.10 Route Integrity Protection ! Section 5.10.1 Monitored Hand-Operated Switches ! Section 5.10.2 Switches in Signaled Territory ! Section 5.11 Warning and Enforcement ! Section 5.11.2 Predictive Warning and Enforcement (2) Include safety-critical integration of all authorities and indications of a wayside or cab signal system, or other similar appliance, method, device, or system of equivalent safety, in a manner by which the PTC system shall provide associated warning and enforcement to the extent, and except as, described and justified in the FRA approved PTCDP or PTCSP, as applicable; ! Section 5.4.2 Wayside Signals ! Section 5.4.3 Cab Signals" ! Section 5.10.2 Switches in Signaled Territory ! Section 5.10.3 Other Monitored Devices ! Section 5.11 Warning and Enforcement ! Section 5.11.1 Reactive (Overspeed) Warning and Enforcement ! Section 5.11.2 Predictive Warning and Enforcement ! Section 5.11.3 Restrictive Speed Enforcement (3) As applicable, perform the additional functions specified in this subpart; (4) Provide an appropriate warning or enforcement when: (i) A derail or switch protecting access to the main line required by § 236.1007, or otherwise provided for in the applicable PTCSP, is not in its derailing or protecting position, respectively; {Applies to high speed passenger lines} ! Section 5.4.2 Wayside Signals ! Section 5.10.3 Other Monitored Devices ! Section 5.11 Warning and Enforcement ! Section 5.11.2 Predictive Warning and Enforcement (ii) A mandatory directive is issued associated with a highway-rail grade crossing warning system malfunction as required by §§ 234.105, 234.106, or 234.107; ! Section 5.7 Malfunctioning Highway Grade Crossing Warning Systems ! Section 5.11 Warning and Enforcement PTC Implementation Plan 40 ! Section 5.11.2 Predictive Warning and Enforcement (iii) An after-arrival mandatory directive has been issued and the train or trains to be waited on has not yet passed the location of the receiving train; ! Section 5.4.1.1 Track Warrant Control (iv) Any movable bridge within the route ahead is not in a position to allow permissive indication for a train movement pursuant to § 236.312; and ! Section 5.4.2 Wayside Signals ! Section 5.10.3 Other Monitored Devices ! Section 5.11 Warning and Enforcement ! Section 5.11.2 Predictive Warning and Enforcement (v) A hazard detector integrated into the PTC system that is required by paragraph (c) of this section, or otherwise provided for in the applicable PTCSP, detects an unsafe condition or transmits an alarm; and ! Section 5.4.2 Wayside Signals ! Section 5.10.3 Other Monitored Devices ! Section 5.11 Warning and Enforcement ! Section 5.11.2 Predictive Warning and Enforcement (5) Limit the speed of passenger and freight trains to 59 miles per hour and 49 miles per hour, respectively, in areas without broken rail detection or equivalent safeguards. ! Section 5.5.1 Permanent Speed Restrictions ! Section 5.11 Warning and Enforcement ! Section 5.11.1 Reactive (Overspeed) Warning and Enforcement 3.3.1 Application of V-ETMS on Amtrak V-ETMS will be installed on portions of Chicago Union Terminal, portions of New Orleans Union Passenger Terminal and on portions of the Northeast Corridor. In Chicago and New Orleans V-ETMS will operate without cab signals and will be fully compatible with all the carriers using the same system. On the Northeast Corridor ACSES and ATC will be the primary PTC system with V- ETMS as an additional vital overlay for interoperability with the freight carriers and with some MARC and VRE commuter trains. A back office server will hold the track database and will handle temporary speed restriction data. WIUs installed at each interlocking will function as an encoder for ACSES trains and a V-ETMS WIU for V- ETMS equipped trains. Each system will have its own unique message format and the WIU will be able to format a proper message for either an ACSES train or a V-ETMS train. All carriers operating on the NEC will be required to have on-board cab signal equipment which will provide signal aspect status for train separation therefore a WIU will not be required for every location. WIUs will be installed only at interlockings in the same PTC Implementation Plan 41 manner as ACSES. A V-ETMS 220 MHz data radio system will be installed to deliver information to and from the V-ETMS equipped trains. Amtrak plans to equip the following territory on the NEC for V-ETMS operation: ! Between CP Virginia and A interlocking in Washington, DC for VRE trains and Amtrak trains operating over CSX south of Washington. ! Washington Union Terminal to Lane interlocking in Newark, NJ for CSX, NS and Conrail freight operation and also for some MARC commuter trains and some Amtrak diesel operated traffic. ! Between Harrisburg, PA and Philadelphia for NS freight operation and for Amtrak diesel operated trains coming onto the NEC. ! Between New Haven, CT and Springfield, MA for Connecticut Southern Railroad freight operation. PTC Implementation Plan 42 4.0 Compliance [§ 236.1011(a)(2)] This section describes how Amtrak intends to comply with § 236.1009(c) and § 236.1009(d). It is divided into three parts corresponding to the three PTC systems which Amtrak will install and operate. 4.1 ACSES/ATC System on the Northeast Corridor The ACSES system was installed by an Order of Particular Applicability [FRA Docket No. 87-2, Notice No. 7]. It is a vital overlay system that provides the additional PTC functionality not provided by the signal and ATC system. Amtrak is submitting a Request for Expedited Certification (REC) and type acceptance for the ACSES system as described in § 236.1031(a)(3). The REC document provides a detailed description of the ACSES system which is the equivalent of a PTCDP as required by § 236.1013 along with reference to materials previously submitted to FRA which constitute the equivalent of a PTCSP as required by § 236.1015. Once FRA grants a type approval for the system its validity will automatically be ensured since the system is already implemented on the NEC. 4.2 ITCS System on Amtrak?s Michigan Line Amtrak installed the ITCS system on portions of its Michigan Line under a train control demonstration grant in cooperation with FRA, the State of Michigan and General Electric Transportation Systems (originally Harmon Industries). ITCS is a vital overlay system. FRA has been very involved with the development and testing of this system. Currently Amtrak is operating passenger trains at 95 mph under an FRA waiver. Amtrak is submitting a Request for Expedited Certification (REC) and type approval for the ITCS system as described in § 236.1031(a)(2). This system has been in operation for over 5 years and has received an assessment of Verification and Validation from an independent third party (Battelle Laboratories). The system is being expanded to include the entire territory between Porter, IN (MP 240.7) and Kalamazoo, MI (MP 143.2) owned by Amtrak. The REC document provides a detailed description of the ITCS system which is the equivalent of a PTCDP as required by § 236.1013 along with reference to materials previously submitted to FRA which constitute the equivalent of a PTCSP as required by § 236.1015. Once FRA grants a type approval for the system its validity will automatically be ensured since the system is already implemented on Amtrak?s Michigan Line. 4.3 Amtrak?s Implementation of V-ETMS Outside the Northeast Corridor most of Amtrak?s trains operate over other railroads, mostly the Class I carriers. In order to be interoperable with these carriers Amtrak will install the Vital Electronic Train Management System (V-ETMS) on most of its diesel locomotive fleet operating outside the NEC. Amtrak property outside the NEC and the PTC Implementation Plan 43 Michigan Line where PTC is required will be equipped with V-ETMS wayside and office equipment as well. This territory includes, portions of the Chicago Union Station terminal area, portions of the New Orleans Union Passenger Terminal, and a short track segment between CSX?s CP Virginia and ?A? interlocking in Washington Union Terminal in Washington, DC. On these areas of Amtrak property V-ETMS will be the only type of PTC system. In order to accommodate carriers that operate on the NEC but primarily operate in V- ETMS territory, Amtrak will provide a V-ETMS overbuild in ACSES territory that will allow operation of those trains without them having to be dual equipped with V-ETMS and ACSES as described in Section 3 of this document. 4.3.1 Utilization of Existing Type Approval and/or PTCDP The Class I North American freight carriers are working together to develop an interoperable train control system. They have jointly filed a PTCDP for the Vital Electronic Train Management System (V-ETMS) (FRA Docket 2010-0028) and are requesting a type approval for this system. Amtrak has participated on the ITC Committees formed by the Class I carriers and intends to utilize their PTCDP and Type Approval for the V-ETMS system. 4.3.2 Certifying the Validity of Type Approval § 236.1013(c) states that ?Each Type Approval shall be valid for a period of 5 years, subject to automatic and indefinite extension provided that at least one PTC System Certification using the subject PTC system has been issued within that period and not revoked.? Amtrak intends to complete its implementation of V-ETMS before that 5 year period expires. We will be working closely with the Class I carriers as well as commuter railroads such as Metra in Chicago and will be kept apprised of any changes or modifications to their plans. Amtrak will maintain its Type Approval status. 4.3.3 Handling of Unique Aspects of the PTCDP and Type Approval Amtrak does not foresee any significant variances in technology from the V-ETMS systems applied to the freight railroads. Amtrak has worked closely with Norfolk Southern Railroad (NS) to address interoperability issues for NS freight trains operating on the NEC. All carriers operating on the NEC are currently required to be equipped with cab signal systems including NS freight trains. CSX, NS and the UP all have cab signal territory on their railroads and intend to use cab signal equipment in combination with V-ETMS equipment in their PTC implementations. Outside the NEC it is not anticipated that there will be any significant variances or unique aspects of V-ETMS implementation. Amtrak locomotives operating in V-ETMS territory will be equipped with the same on- board equipment as the freight carriers. It is recognized that there will be differences in software configurations of the on-board equipment since braking algorithms and braking PTC Implementation Plan 44 procedures will be different for passenger equipment. These software configurations will be documented and fully tested. For any necessary deviations or variances from the approved freight PTCDP, Amtrak will prepare a document that will amend or replace language in that PTCDP. 4.3.4 Deliverables Amtrak will supply the following deliverables to FRA to support a petition for PTC System Certification: ! A PTC Implementation Plan (PTCIP) ! Reference numbers for a PTC Development Plan (PTCDP) and Type Approval submitted by the Class I carriers ! Amendments to the PTCDP (if applicable) ! A PTC Safety Plan (PTCSP) ! A detailed description of braking algorithms and any other software configuration variables unique to Amtrak?s on-board systems. 4.4 Project Risk Assessment The implementation of PTC on Amtrak will have a number of risks that are dependent on factors that are known and unknown. Risks will be assessed using the following ratings: Likelihood Ratings Rating Description Almost Certain (5) There is little doubt that the event will occur Likely (4) There is a strong possibility that the event will occur Possible (3) There is a possibility that the event will occur Unlikely (2) There is a slight possibility that the event will occur Rare (1) It is highly unlikely that the event will occur Impact Ratings Rating Examples Catastrophic (5) Fatal to project preventing completion or introducing long term delay Has a large financial impact to project budget Major (4) Significant delay to project schedule Significant financial impact to project budget Moderate (3) Has some impact on project schedule Has some impact on project budget Minor (2) Has small impact on project schedule Has small impact on project budget Insignificant (1) Minimal impact on project schedule Minimal impact on project budget PTC Implementation Plan 45 The risk rating will be obtained by multiplying the Impact Rating by the Likelihood Rating. A rating of Critical (20 or more) or High (10 or more) will require very careful management and monitoring and will require an up front contingency plan. A rating of Medium (6 - 9) will require management strategies to be developed and implemented by the Project Manager. A rating of Low (1-5) is an acceptable risk level and will be managed by normal control procedures. 4.4.1 Risks to PTC Implementation For the ACSES and ITCS systems there is little risk for Amtrak?s success. Both of these systems are currently in service and Amtrak has many years experience in their operation. Amtrak currently has GE Transportation Systems under contract to complete the installation of ITCS on the Michigan Line. This work is scheduled to be completed by February 2011. If the project is not completed on time, there is plenty of time to recover and complete the work before the mandated deadline of December 31, 2015. Likelihood of not completing the work on schedule: Possible (3) Impact: Moderate (3) Risk Rating: Medium (9); Mitigation: Carefully monitor schedule and resolve conflicts quickly. Amtrak currently has Alstom under contract to design the ACSES system for the remaining portions of the NEC. The Amtrak locomotive fleet operating on the NEC already has ACSES equipment installed and operating on a daily basis. All carriers operating on the NEC between New Haven and Boston also are equipped with ACSES and are operating with it on a daily basis. Amtrak intends to complete its wayside installation on the NEC by December 31, 2012. If the project encounters problems, there should be plenty of time to recover and complete the work before the mandated deadline of December 31, 2015. Likelihood of not completing the work on schedule: Possible (3) Impact: Moderate (3) Risk Rating: Medium (9); Mitigation: Carefully monitor schedule and resolve conflicts quickly. Amtrak intends to change the ACSES data radio system from the current 900 MHz system to a new 220 MHz data radio for better performance. The risk of this change is minimal but if this solution either does not work or threatens to delay the project beyond the mandated deadline, we can fall back to the 900 MHz radio that we already know will work. Likelihood of solution not working or adding significant delay: Unlikely (2) Impact: Major (4) Risk Rating: Medium (8); Mitigation: Carefully monitor progress and resolve conflicts quickly. There will be interoperability risks for the commuter railroads operating on the NEC that intend to install ACSES on their own railroads. This risk is primarily theirs but Amtrak will try to mitigate these risks by working closely with them as they develop and PTC Implementation Plan 46 implement their systems. Amtrak has already provided detailed information to them and is working with them to set standards to ensure seamless interface between our systems and properties. Amtrak will work with them to test their equipment on the NEC to prove interoperability. Likelihood of not achieving interoperability: Unlikely (2) Impact: Catastrophic (5) Risk Rating: High (10); Mitigation: Tight coordination with commuters throughout the development of their systems. Aggressive testing will be required for compatibility and interoperability. The biggest risk that Amtrak faces is the implementation of the V-ETMS system. V- ETMS is not widely implemented and there is very little, if any, operating experience with it. It will not be the primary PTC system for most of Amtrak?s property. In fact, very little of Amtrak?s property will have V-ETMS as its primary PTC system. Since there is little wayside equipment for Amtrak to install the risk of not completing this work on time is extremely small, especially on Amtrak property outside the NEC. Likelihood of V-ETMS not being completed on time: Rare (1) Impact: Major (4) Risk Rating: Low (4); Mitigation: Schedule WIU installation and BOS installation early and coordinate closely with tenant railroads. On the NEC, Amtrak plans to utilize the same wayside interface unit (WIU) that is used for ACSES as the WIU for V-ETMS. The WIU will be able to respond to an ACSES train with an ACSES message format and a V-ETMS train with a message format used by that system. There is a risk that this will not work reliably. If this proves to be a problem, Amtrak can install two WIU?s at each interlocking, one for ACSES and one for V-ETMS. Likelihood that WIU will have a negative impact on schedule: Possible (3) Impact: Moderate (3) Risk Rating: Medium (9); Mitigation: Install test WIU early. Carefully monitor progress and resolve problems early. The risk outside the NEC is that interoperability issues will delay the final implementation of the system. This will largely be beyond Amtrak?s control as Amtrak is not the driving force behind the V-ETMS system. Amtrak can mitigate its risks in this area by working closely with the Class I carriers and equipping test trains that can be used to flush out the interoperability issues early in the process. Other than technical risks, the other major risk to Amtrak is that funding will not be available to complete its implementation of PTC on time or that it will not be able to fund PTC on its host carriers where PTC will be required only because of the presence of Amtrak passenger trains. These risks are beyond the scope of this document and will have to be addressed through other channels. PTC Implementation Plan 47 5.0 Interoperability [§ 236.1011(a)(3)] This section describes how the PTC systems on Amtrak will provide interoperability with its tenant railroads. It is divided into three parts corresponding to the three PTC systems which Amtrak will install and operate. Appendix A contains interoperability agreements signed by both Amtrak and its tenant carriers. 5.1 Northeast Corridor and Feeder Lines 5.1.1 Agreement Provisions Relevant to Interoperability [§236.1011(a)(3)(i)] Amtrak is the host railroad to the following tenants on the Northeast Corridor: ! Virginia Railway Express (VRE) operating into Washington Union Terminal (WUT) from CSX territory. (Letter of Understanding (LOU) Appendix A, p. 59) ! Maryland Area Regional Commuter (MARC) operating into WUT from CSX territory and between WUT and Perryville, MD. (LOU Appendix A, p. 32) ! Southeastern Pennsylvania Transportation Authority (SEPTA) operating between Newcastle, DE and Trenton, NJ on the NEC spine and between Philadelphia and Thorndale, PA on the Harrisburg Line. (LOU Appendix A, p. 48) ! New Jersey Transit Rail Operations (NJT) operating between Philadelphia and New York City. (LOU Appendix A, p. 38) ! The Long Island Rail Road (LIRR) operating between Harold Interlocking in Queens, New York into Penn Station New York. (LOU Appendix A, p. 28-29) ! Connecticut DOT Shoreline East Service operating between New Haven, CT and New London, CT. (Already equipped with ACSES) ! Norfolk Southern Railway (NS) with trackage rights between New York and Washington on the NEC spine and between Philadelphia and Harrisburg on Amtrak?s Harrisburg Line. (LOU Appendix A, p. 41) ! CSX Transportation with trackage rights between New York and Washington and a short distance on Amtrak?s Springfield Line in Connecticut and between Attleboro, MA and Transfer Interlocking (Amtrak leases and operates this territory) in the Boston area. (LOU Appendix A, p. 22) ! Providence & Worcester Railroad Company (P&W) with trackage rights between New Haven, CT and Providence, RI. (Already equipped with ACSES) ! Connecticut Southern Railroad operating on Amtrak?s Springfield Line between New Haven, CT and Springfield, MA. (LOU Appendix A, p. 18) ! Pan Am Railways with trackage rights on Amtrak?s Springfield Line. (LOU Appendix A, p. 44) ! Canadian Pacific Railroad with trackage rights between Perryville and Landover, MD. (LOU Appendix A, p. 9) ! Conrail Shared Assets with trackage rights between Philadelphia, PA and Newark, NJ. (LOU Appendix A, p. 12) PTC Implementation Plan 48 Amtrak has formed an ACSES Users Group on the NEC and has held regular meetings since the Rail Safety Improvement Act of 2008 was passed. The group consists of technical representatives of Amtrak and all the commuter railroads operating over the NEC that have property of their own on which they have indicated that they intend to install an ACSES compatible system. The purpose of the group is to share information and establish standards to ensure that our systems are interoperable. From time to time CSX and NS have participated in the meetings to share information on their plans for implementing the V-ETMS system. The members of this group include MBTA, Metro North Commuter Railroad, The Long Island Rail Road, New Jersey Transit and SEPTA. Amtrak has also been holding frequent meetings with Norfolk Southern Railroad representatives to discuss the interoperability of NS freight trains on the NEC. Amtrak has agreed to work with NS and CSX on a solution whereby freight trains equipped with V-ETMS can operate in ACSES territory without the necessity of dual equipping their locomotives. We believe we have a solution and have agreed to work together to test and implement it. This solution will also be used to accommodate VRE commuter trains operating into Washington Union Terminal, Conrail Shared Assets and Canadian Pacific Railway. Amtrak has had conversations with MARC about their concerns over interoperability. All of their locomotives and cab cars are equipped with ATC and they have indicated that they intend to equip their electric locomotives with ACSES as well. Their diesel locomotives and cab cars operate over CSX territory as well as on the NEC and CSX will install a V-ETMS system on their railroad. MARC is concerned that there is not enough room on their cab cars to install ATC, ACSES and V-ETMS. We will be working with MARC to use the solution being worked out with CSX and NS to allow their V-ETMS equipped trains to work on the NEC. Amtrak has been in contact with Connecticut Southern Railway and Pan Am Railways both of which have indicated that they will equip a small number of locomotives to operate on the Springfield Line. ACSES has already been installed on the NEC between New Haven, CT and Boston, MA. Agreements are already in place with MBTA, Connecticut DOT Commuter, the P&W Railroad and CSX. All of these carriers are presently operating with ATC and ACSES and are not admitted to that portion of the NEC unless these systems are operable. Amtrak has sent formal letters to all of its tenants on the NEC indicating its intentions to complete its installation of ACSES throughout the NEC and its feeder lines. Amtrak has extended its offer to work with each carrier to address interoperability issues and has included a Letter of Understanding for each tenant to sign, indicating its agreement to work with Amtrak to implement PTC technical solutions which meet the requirements of interoperability. Copies of these signed agreements are attached in Appendix A. PTC Implementation Plan 49 5.1.2 Technology Applicable to Interoperability [§236.1011(a)(3)(ii)] All carriers that operate on the NEC today are required by FRA order to have operating ATC equipment. That technology will continue to be a requirement for interoperability. Most commuter tenants will, in addition, be equipped with ACSES systems with an interoperable 220 MHz data radio. Our wayside equipment consisting of transponders, WIU?s, BCP radios etc. will all have to be compatible using the same message formats and protocols. Our TSR safety servers will have to be compatible and TSR?s will have to be delivered in the same manner. We will have to design and implement interfaces where trains can seamlessly go from one property to another without delay and without missing vital information. Some freight and commuter tenants will, in addition to having on-board cab signal equipment, have an on-board V-ETMS system. Amtrak will have to build and maintain a back office server ( BOS) that will contain a database in GPS coordinates that will be downloaded to the tenant locomotive before it arrives on the NEC. The BOS will also handle TSR data in much the same way that the ACSES TSR Safety Server does. Amtrak will install a WIU at each interlocking that will be capable of providing the required information to the V-ETMS equipped train. This WIU may be the same WIU used for ACSES or it may turn out to be a separate device. An interoperable 220 MHz radio system will be required to deliver data from the BOS and from the WIU to the tenant locomotive. NORAC rules are in effect on the NEC and all train crews operating on the NEC are required to be NORAC qualified. In addition to NORAC rules, all crews are required to be qualified on the Amtrak Northeast Corridor Employee Timetable and Special Instructions. Amtrak has developed operating rules and special instructions in the use of ACSES on the NEC. We have shared these rules with the other carriers that are in the process of developing specifications for their PTC systems. We must work closely with our tenants to develop operating rules that will ensure interoperability. 5.1.3 Obstacles to Interoperability [§236.1011(a)(3)(iii)] Amtrak has had almost 10 years experience with the ACSES system and will be in a good position to help the commuter railroads that intend to implement ACSES on their own railroads. There will be challenges and we will have to pay particular attention to our interfaces but there are no known obstacles. For the tenants that plan to operate with V-ETMS, Amtrak will work closely with them to make the operation to and form the NEC as seamless as possible. Since V-ETMS is a new system, there will be many challenges but since this system will be so widely used there are no know obstacles. PTC Implementation Plan 50 5.2 Amtrak?s Michigan Line 5.2.1 Agreement Provisions Relevant to Interoperability [§236.1011(a)(3)(i)] ITCS has been in full service on the Michigan Line since 2000. Amtrak and NS have an existing agreement whereby a number of NS locomotives have been equipped with ITCS on-board equipment for operation on the line. Amtrak will expand its installation of ITCS to cover all main line track that it owns. This will not alter the agreement presently in effect. The Chicago South Shore and South Bend Railroad operates over a very short distance on the Michigan Line in the Michigan City area (MP 228.0 to MP 228.79. They operate three days per week (Monday, Wednesday and Friday. The President of Chicago South Shore & South Bend Railroad has agreed by letter (Appendix A, p. 52) to operate during a night-time window between 11:45 pm and 5:30 am central time when no Amtrak passenger trains operate thereby providing temporal separation between CSS&SBRR freight trains and Amtrak passenger trains. Amtrak and the Chicago South Shore and South Bend Railroad are hereby requesting FRA to grant an exception as provided by §236.1006 (b) (4) (ii) with the additional condition that temporal separation will be provided as described above. 5.2.2 Technology Applicable to Interoperability [§236.1011(a)(3)(ii)] The ITCS technology is already in place and both Amtrak and NS are operating in the territory with on-board ITCS equipment today. A WIU at each wayside location monitors the status of signals, switches and highway crossings. A server located at a control point (usually an end of siding location) polls the WIU?s in its zone to check status conditions. The server communicates with each train operating in its zone using a 220 MHz data radio relaying signal, switch and crossing status. It also relays temporary speed restriction information from the TSR server in the dispatching center. A GPS receiver on the locomotive provides positioning data and the on-board computer contains a GPS map of the territory. The on-board system enforces all speed restrictions and all speeds associated with the wayside signal aspects. Operating rules have been developed around the ITCS system and are used by both Amtrak and NS. 5.2.3 Obstacles to Interoperability [§236.1011(a)(3)(iii)] There are no known obstacles since both NS and Amtrak are already operating in ITCS territory. A suitable solution will have to be worked out with the Chicago South Shore and South Bend Railroad for their limited operation on the line. 5.3 V-ETMS Territory 5.3.1 Agreement Provisions Relevant to Interoperability [§236.1011(a)(3)(i)] Amtrak is the host railroad to the following tenants at Chicago Union Terminal: PTC Implementation Plan 51 ! Metra which operates commuter service into and out of Chicago Union Station. ! BNSF Railway, Norfolk Southern Railway, Union Pacific Railroad and Chicago Rail Link all of which operate freight interchange service through a portion of Chicago Union Terminal. Amtrak has informed them that a V-ETMS system will be installed in Chicago and Amtrak has executed an Interoperability Letter of Understanding with each of these tenants. A copy of these agreements can be found in Appendix A. (LOU BNSF Appendix A, p. 3; NS, p. 41; UP p. 56 and Chicago Rail Link p. 15) Amtrak is the host railroad to Canadian National Railway in the New Orleans Union Passenger Terminal where CN makes occasional freight deliveries. Amtrak has informed CN that a V-ETMS system will be installed in New Orleans and has executed an Interoperability Letter of Understanding with CN. A copy of this agreement can be found in Appendix A on page 6. The Class I railroads have formed committees to prepare specifications for the V-ETMS system components. Amtrak has participated in these committee meetings and will use the PTCDP developed by the Class I carriers to implement its V-ETMS applications. 5.3.2Technology Applicable to Interoperability [§236.1011(a)(3)(ii)] Amtrak will equip its diesel locomotive fleet that operates outside the Northeast Corridor with the V-ETMS onboard PTC system. Amtrak will install a V-ETMS Back Office Server and equip the wayside with V-ETMS equipment in Chicago Union Terminal, New Orleans Union Passenger Terminal and on portions of the NEC where the Class I carriers will operate using the V-ETMS system. Amtrak will use the PTCDP that the Class I carriers have filed with FRA to ensure interoperability. 5.3.3 Obstacles to Interoperability [§236.1011(a)(3)(iii)] There are no known obstacles to interoperability at this time. V-ETMS is a new system and has yet to be implemented over a widespread area of the country. There will be many challenges in implementing the system but there will be many railroads involved to meet these challenges. PTC Implementation Plan 52 6 Installation Risk Analysis [§236.1011(a)(4)] 6.1 General Overview The purpose of this risk analysis is to determine the order of implementation of PTC on each Amtrak line segment by comparing their relative risks. Amtrak is unique to the railroad industry. It is the only nationwide intercity passenger railroad and it operates the only high speed rail corridor in North America with passenger train speeds up to 150 mph. The Northeast Corridor has a mix of high speed intercity passenger trains, lower speed commuter passenger trains and freight trains. This analysis considers a number of factors that are relevant in identifying the risk associated with a mainline track segment. Amtrak has placed a higher risk rating on speed than may be found in the analysis done by other railroads. As speed increases there are more civil speed restrictions associated with curves as evidenced by Amtrak?s employee timetable. The impact of a collision at higher speeds tends to be more severe thereby increasing the risk factor. The factors considered in this analysis are: ! Annual Million Gross Tons (MGT) Level of freight ! Presence and volume of Passenger traffic ! Presence and volume of TIH/PIH material (loads and residue) ! Presence and volume of other hazardous materials ! Method of operation ! Presence or absence of underlying block signal, cab signal, train stop or train control systems ! Maximum authorized speeds of train operations ! Number of tracks ! Track grades and curvatures ! Frequency and location of track turnouts (i.e., spurs and sidings) ! Past accident/incident statistics ! Presence or absence, and types, of wayside hazard detectors ! Number and types of at-grade crossings (both highway-rail and rail-to-rail) PTC Implementation Plan 53 ! Number of passenger stations on the line segment Appendix N contains the actual risk analysis. Due to the fact that the risk analysis contains Sensitive Security Information (SSI) that is controlled under 49 CFR parts 15 and 1520, it is not included in the body of this document. PTC Implementation Plan 54 7 Deployment Sequence and Schedule [§236.1011(a)(4)(5)] 7.1 General This section describes PTC implementation sequence on the Amtrak system. For the NEC and Michigan Line this implementation is an expansion of existing systems. For Chicago and New Orleans Amtrak will be implementing the V-ETMS System being developed by the Class I freight railroads. Appendix C through L provides timetable information and track and signal layout drawings for each line segment. This information is provided to aid in understanding the implementation sequence. 7.2 Northeast Corridor (NEC) ACSES is already in service on the NEC between Mill River and Cove Interlockings (Line 3) on the line between New Haven, CT and Boston, MA. There are two segments in service between New York and Washington, DC. These segments are; a) track 2 & 3 between County Interlocking (MP 32.8) and Ham Interlocking (MP 55.7) on the New York Division (Line 1) and; b) tracks 2 & 3 between Ragan Interlocking (MP 29.7) and Prince Interlocking (MP 57.3) on the Mid-Atlantic Division (Line 2). Our plan is to complete these two line segments (Line 1 & 2) first followed by Line 6 (JO to Shell), Line 4 (Philadelphia to Harrisburg), Line 5 (Mill River to Springfield) and Line 8 (Empire Connection). 7.2.1 Material Procurement The table below shows the major material items for the ACSES system with their status. Table 7.2.1 ? Material Procurement and Delivery Item Status Delivery Begins Transponders On order April 2010 Radio houses On order April 2010 Antenna Poles On order May 2010 On-board ACSES Systems On order May 2010 Wayside Maint. Tools On order Sept. 2010 Encoders (WIU) Out for bid Dec. 2010 Data Radios Out for bid Dec. 2010 TSR Server Replacement On order Dec. 2010 7.2.2 Design Amtrak contracted Alstom to design the ACSES transponder and encoder layouts and to prepare the databases that will be used to program the transponders and encoders. This contract was awarded in November 2010. The table below provides a schedule for this design. PTC Implementation Plan 55 Table 7.2.2 ? ACSES Design Line Segment Start Design Design Complete Line 2 Zoo to Ave. Nov. 2009 May 2010 Line 1&7 NYP to Zoo Mar. 2010 July 2010 Line 6 JO to Shell July 2010 Sept. 2010 Line 4 Phil. To Harrisburg Sept. 2010 Dec. 2010 Line 5 Mill River to Springfield Dec. 2010 Feb. 2011 Line 8 Empire Connection Dec. 2010 Feb. 2011 Following the completion of design for each line segment, installation of transponders will begin followed by installation of encoders and data radios. Once all transponders, encoders and radios are installed, testing will begin for each line segment. Testing will be done with test trains and each line segment will be placed in service upon final testing. 7.2.3 Transponder Installation Transponder installation will begin upon completion of the design for each line segment. Installation will be done by C&S construction forces on each division so that installation work can be done concurrently in some cases. The transponders will come with mounting hardware that can be installed ahead of the actual installation of the programmed transponder which will enable the installation to begin once the transponder locations are identified. The transponders themselves can be installed as they are programmed. Construction transponders will be installed at the entrance and exit points of the construction zones so that trains will not react to the newly installed transponders until all testing has been completed for that zone. The table below shows the sequence of installation with the expected completion dates. Table 7.2.3 ACSES Transponder Installation Line Segment *Quant. To Install Installation Start Installation Complete Line 2 Zoo to Ave. 1550 May 2010 Oct. 2010 Line 1&7 NYP to Zoo 1398 July 2010 Dec. 2010 Line 6 JO to Shell 155 Dec. 2010 Feb. 2011 Line 4 Phil. To Harrisburg 910 Jan. 2011 July 2011 Line 5 Mill River to Springfield 300 Mar. 2011 July 2011 Line 8 Empire Connection 140 Mar. 2011 May 2011 *Quantities to install are taken from estimates. 7.2.4 Installation of Radio Houses and Antenna Poles Radio house installation can begin before arrival of the radios. The location of each radio house has already been determined and installation of these houses and antenna poles will begin about the same time as the installation of transponders on each line segment. The PTC Implementation Plan 56 radios will be installed once their delivery begins. The table below shows the sequence of installation of radio houses and antenna poles. Table 7.2.4 Installation of ACSES Radio Houses and Antenna Poles Line Segment Quant. To Install Installation Start Installation Complete Line 2 Zoo to Ave. 26 May 2010 Oct. 2010 Line 1&7 NYP to Zoo 36 July 2010 Dec. 2010 Line 6 JO to Shell 7 Dec. 2010 Feb. 2011 Line 4 Phil. To Harrisburg 20 Jan. 2011 July 2011 Line 5 Mill River to Springfield 12 Mar. 2011 July 2011 Line 8 Empire Connection 3 Mar. 2011 May 2011 7.2.5 Installation of Encoders (WIUs) and Data Radios Delivery of encoders or WIUs will begin in December, 2010. Radio delivery is expected to begin about the same time. Encoders will be wired into each interlocking picking up signal status and switch position information. Radios will installed into the radio houses and connected to the encoders and the TSR delivery network. The table below shows the sequence of installation for this work. Table 7.2.5 Installation of ACSES Encoders and Data Radios Line Segment Qty. Encoders Qty. Radios Start Complete Line 2 Zoo to Ave. 96 36 Jan. 2011 July 2011 Line 1&7 NYP to Zoo 111 26 Jan. 2011 Sept. 2011 Line 6 JO to Shell 27 7 Sept. 2011 Dec. 2011 Line 4 Phil. To Harrisburg 52 20 Oct. 2011 Mar. 2012 Line 5 Mill River to Springfield 22 12 Mar. 2012 June 2012 Line 8 Empire Connection 4 3 Apr. 2012 June 2012 7.2.6 Testing and Commissioning Following all of the installation for each line segment, test trains will used to verify the design. Upon completion of testing and making any corrections that are necessary, the line segment will be commissioned or placed in service. Amtrak may elect to place portions of the line segments in service before testing has been completed for the entire line segment. For example, the Baltimore to Washington portion of Line 2 may be placed in service when testing is complete for that portion. The remaining portion of Line 2 from Philadelphia to Baltimore would follow upon completion of testing. The following table provides the testing and commissioning sequence and schedule. PTC Implementation Plan 57 Table 7.2.6 ACSES Testing and Commissioning Line Segment Begin Testing Place in Service Line 2 Zoo to Ave. July 2011 Nov. 2011 Line 1&7 NYP to Zoo Sept. 2011 Jan. 2012 Line 6 JO to Shell Jan. 2012 Mar. 2012 Line 4 Phil. To Harrisburg Mar. 2012 July 2012 Line 5 Mill River to Springfield July 2012 Oct. 2012 Line 8 Empire Connection Oct. 2012 Dec. 2012 7.2.7 Installation of V-ETMS on the NEC Amtrak will install infrastructure to accommodate V-ETMS trains for those carriers that need to operate with this system. This infrastructure will be limited to the portions of the NEC where those trains will operate. There will be an office component of this system consisting of a Back Office Server (BOS) which will contain a database with signal locations, curves, etc. defined in GPS coordinates. The BOS will interface to the CETC dispatching system to deliver train movement authority to the V-ETMS trains and to deliver TSR data in much the same way that the ACSES TSR Safety Server delivers TSR information. The Encoders or WIUs that will be installed for ACSES will also serve as WIUs for V- ETMS. A V-ETMS data radio will be installed at base stations where voice radios are currently installed. The WIUs will be networked so that a base radio unit may handle multiple WIUs. Since all trains operating with the V-ETMS onboard system will also be equipped with cab signal equipment, WIUs will not be required at every signal location. A WIU at each interlocking will provide V-ETMS trains the same information that is provided to ACSES equipped trains except in the V-ETMS message format. Since the specifications for V-ETMS are in the final stages of development and ACSES is already a mature system, the installation of V-ETMS on the NEC will follow the ACSES installation. The lines that will be equipped for V-ETMS operation are: ! Line 2 between Zoo Interlocking (MP 0) and Landover Interlocking (MP 128.8) and between CP Virginia and ?A? Interlocking in Washington, DC ! Line 1 between Lane Interlocking (MP 12.3) and Zoo Interlocking (MP 88) ! Line 4 between Zoo Interlocking (MP 0) and Roy Interlocking (MP 94.3) ! Line 5 between Mill River Interlocking (MP 1.5) and CSX CP 98 (MP 62) in Springfield, MA The following tasks will be performed: PTC Implementation Plan 58 ! Order Back Order Server Oct. 2012 ! Order Wayside Data Radios Oct. 2012 Task Start Finish Survey and Mapping Line 2 (Inc. A to CP Virginia) Oct. 2012 Mar. 2013 Install radios Line 2 (Including A to CP Virginia) Mar. 2013 Sept. 2013 Test and Place in service Line 2 (Inc. A to CP Virginia) Sept. 2013 Dec. 2013 Survey and Mapping Line 1 Mar. 2013 Sept. 2013 Install radios Line 1 Sept. 2013 Mar. 2014 Test and Place in service Line 1 Mar. 2014 Sept. 2014 Survey and Mapping Line 4 Sept. 2013 Mar. 2014 Install radios Line 4 Mar. 2014 Sept. 2014 Test and Place in service Line 4 Sept. 2014 Dec. 2014 Survey and Mapping Line 5 Mar. 2014 June 2014 Install radios Line 5 June 2014 Sept. 2014 Test and Place in service Line 5 Sept. 2014 Dec. 2014 7.3 Michigan Line The Michigan Line is already equipped with ITCS between MP 150.38 and MP 216.07. Amtrak currently has a contract with General Electric Transportation Systems (GETS) to complete the installation of ITCS on the rest of the line between Kalamazoo (MP 143.20) and MP 150.38 on the west end and between MP 216.07 and Porter (MP 240.57) on the east end of the line. The contract includes design and installation of all new signal locations within the contract area including highway crossings. This work is scheduled to be completed by Feb. 2011. A detailed schedule can be found in Appendix J along with timetable information and track charts. 7.4 Chicago and New Orleans Chicago and New Orleans will be equipped with V-ETMS. These installations cover small areas and the work will be done concurrently. A Back Office Server will be ordered for the Chicago Dispatching Center in October 2012. WIUs and radios will be installed beginning in June 2012. Testing and cut-over will be completed by Dec. 2013. This is based on funding being available to do this work within this schedule. Even though these installations are small testing will take a considerable amount of time due to all the railroads that we will have to interface with. This schedule could change depending on the installation schedules of the interfacing railroads. PTC Implementation Plan 59 The following tasks will be performed: Task Start Finish Survey and Mapping Chicago Union Terminal Oct. 2012 Dec. 2012 Survey and Mapping NOUPT Oct. 2012 Dec. 2012 Order Back Office Server for Chicago Dispatching Oct. 2012 Order Wayside Materials for Chicago and NOUPT Oct. 2012 Install WIU?s in Chicago Union Terminal June 2012 Dec. 2012 Install WIU?s NOUPT Oct. 2012 Dec. 2012 Test and Place in Service Chicago Union Terminal Jan. 2013 June 2013 Test and Place in Service NOUPT June 2013 Dec. 2013 PTC Implementation Plan 60 8 Rolling Stock [§236.1011(a)(6) 8.1 General This section describes the rolling stock that will be equipped with PTC technology. Many of Amtrak?s locomotives are already equipped. In some cases, some Amtrak locomotives may have to be equipped with more than one system. 8.2 Rolling Stock to be Equipped [§236.1011(a)(6)(i)] The equipment shown in Table 8.2-1 operates daily on the Northeast Corridor and is already equipped with ATC and ACSES except for the P32 Dual Mode locomotives. These locomotives are equipped with ATC and ACSES equipment is on order and will be installed by Dec. 31, 2010. Table 8.2-1: Amtrak Northeast Corridor Fleet Equipment Type Description Fleet Size PTC System Required Comments P42 Diesel 11 ACSES/ATC Already equipped P32 DM Dual Mode 18 ACSES/ATC ACSES equip. ordered AEM-7 Electric 49 ACSES/ATC Already equipped HHP-8 Electric 15 ACSES/ATC Already equipped Acela Trainsets* Electric 20 ACSES/ATC Already equipped Cab Coach Metroliner cab car 17 ACSES/ATC Already equipped *Acela trainsets have two power cars. Each power car is equipped with ATC and ACSES. PTC Implementation Plan 61 The equipment shown in Table 8.2-2 is operated outside the Northeast Corridor except for 11 of the P42 locomotives which operate on the NEC and are currently equipped with ATC/ACSES. All of the remaining equipment will receive V-ETMS on-board equipment including the P32 Dual Mode locomotives which will also be ACSES equipped. Table 8.2-2: Amtrak Fleet Roster to be Equipped with PTC LVPS ATC Equipment Vehicle Class Builder Number of Units Power source Event Recorder Brake System P42 GE 205 Diesel 74 VDC GRS Micro Cab/PHW WABTEC CCB I P40 GE 29 Diesel 74 VDC GRS Micro Cab/PHW WABTEC 26 L P32ED GE 15 Diesel 74 VDC None WABTEC 26 L P32ED GE 3 Diesel 74 VDC PHW WABTEC 26 L P32DM GE 18 Diesel 74 VDC PHW WABTEC CCB I Cab Bags Amtrak 21 NPCU 74 VDC None WABTEC 26 L Cab Bags Amtrak 1 NPCU 74 VDC PHW IITS WABTEC 26 L Surf CABS Alstom 9 NPCU 74 VDC PHW IITS WABTEC 26 L Gen Set MPI 2 Diesel 74 VDC None WABTEC 26 L Table 8.2-3: Numbers by Class Vehicle Class Numbers P42 1-142, 144-148, 150-207 P40 800-806, 809,811, 813-818, 821-828, 830-832, 835, 837,839 P32ED 500, 503-518 P32DM 700-717 Cab Bags 90200 90208, 90213-90215, 90218-90222, 90224, 90225,90229, 90230, 90250- 90253, 90278,90340 90368, 90413 Surf Cabs 6900-6908 Gen Sets TBD 8.3 Schedule [§236.1011(a)(6)(ii)] All the electric fleet, operating on the NEC, is already equipped with ATC and ACSES. 49 sets of VETMS equipment is on order from Wabtec. The first five sets should be delivered by April 30, 2010. These five sets will be installed on P42 locomotives to be used for test trains on the BNSF between Oklahoma City and Fort Worth. The remaining sets will be installed on equipment used in the Los Angeles basin. Amtrak?s goal is to have all the locomotive fleet used in the Los Angeles basin equipped by December 31, 2012. PTC Implementation Plan 62 Following is a schedule for equipping the fleet of 292 vehicles: Year No. of Sets of V-ETMS to be Installed 2010 49 sets 2011 50 sets 2012 50 sets 2013 50 sets 2014 50 sets 2015 43 sets It should be noted that the dual mode locomotives operated between New York and Albany will have to be equipped with both ACSES to operate on Amtrak and Metro North and V-ETMS to operate on CSX. Also, the fleet of locomotives that operate with ITCS on the Michigan Line will also have to be equipped with V-ETMS to operate in NS territory. 8.4 Tenant Railroads [§236.1011(a)(iii)(A) and (B)] 8.4.1 Tenants Operating on the NEC The following tenant railroads are already equipped with ACSES to operate between New Haven, CT and Boston, MA: ! MBTA ! CSX ! P&W ! Connecticut DOT Commuter trains The following tenant commuter railroads operating on the Northeast Corridor will equip with ACSES and are filing their own PTC Implementation Plans: ! The Long Island Rail Road ! New Jersey Transit ! Septa Each of the above railroads will provide a schedule of installation with their PTCIP?s. MARC will equip their electric locomotives with ACSES and their diesel fleet and cab cars with V-ETMS to operate on the NEC between Perryville, MD and Washington, DC. MARC is filing its own PTC Implementation Plan and will provide a schedule of installation in it?s PTCIP. PTC Implementation Plan 63 Virginia Railway Express (VRE) operates from Virginia to Washington Union Terminal through the First Street Tunnel between CSX?s CP Virginia and Amtrak?s ?A? interlocking in WUT. VRE will be required to equip with V-ETMS to operate on CSX and will also operate with V-ETMS on Amtrak. VRE is filing their own PTC Implementation Plan and will provide a schedule of installation in their PTCIP. Norfolk Southern operates on portions of the NEC between New York and Washington with the heaviest amount of traffic between Perryville, MD and Baltimore. NS also operates local freight on the Harrisburg Line between Philadelphia and Harrisburg, PA. NS will operate with V-ETMS in this territory and will provide a schedule of installation with their PTC Implementation Plan. CSX operates on portions of the NEC between New York and Washington and for a short distance on the line between Mill River and Springfield in New England. CSX will operate with V-ETMS in this territory and will provide a schedule of installation with their PTC Implementation Plan. Canadian Pacific Railway has operating rights between Perryville and Landover, MD but seldom operates any freight trains in this territory. CP will operate with V-ETMS if and when they operate on the NEC and will provide a schedule of installation with their PTC Installation Plan. Conrail Shared Assets operates local freight service between Newark, NJ and Philadelphia, PA on the NEC. Conrail will operate with V-ETMS and will provide a schedule of installation in their PTC Installation Plan. Connecticut Southern Railroad operates local freight trains on the Springfield Line between New Haven, CT and Springfield, MA. They plan to equip a few of their locomotives with V-ETMS or ACSES to operate on this segment of the NEC. They have responded to our request for an equipment schedule by letter (Appendix A, p. 19) stating that they will comply with the regulations but are unable to provide specifics as to the number of locomotives that will be equipped or a schedule for installation. Pan Am Railways operates local freight trains on the Springfield Line between New Haven, CT and Springfield, MA. They plan to equip 3 GP-40 locomotives (#?s 360 ? 362) with ACSES by July 2012 (see Pan Am letter, Appendix A, p. 45). 8.4.2 Tenants Operating on the Michigan Line Norfolk Southern operates a small fleet of ITCS equipped locomotives on the Michigan Line. Amtrak and NS plan to work with General Electric Transportation Systems to make ITCS equipped locomotives interoperable with V-ETMS territory. The Chicago South Shore and South Bend Railroad operates on a short section of the Michigan Line in the Michigan City, IN area between MP 228.0 and MP 228.79. As explained in Section 5.2.1, Amtrak and Chicago South Shore and South Bend Railroad PTC Implementation Plan 64 are requesting an exception per §236.1006 (b) (4) (ii) with the additional condition that temporal separation will be maintained between Amtrak passenger trains and CSS&SBRR freight trains. Providing FRA grants this exception, Chicago South Shore and South Bend Railroad freight engines will not be equipped with ITCS on-board systems and will operate within the described territory (MP 228.0 to MP228.79) unequipped with temporal separation. 8.4.3 Tenants Operating in Chicago Union Terminal Metra operates commuter service into Chicago Union Terminal and will equip all of their fleet with V-ETMS on-board equipment. Metra is filing its own PTCIP and will provide a schedule of installation with its plan. Norfolk Southern Railway, Union Pacific Railroad and BNSF Railroad all operate freight trains between CP 21st Street and 16th Street (BNSF Jct.). NS and UP will operate with V-ETMS on-board equipment and BNSF will operate with ETMS. Each of these railroads are filing their own PTC Implementation Plans and will provide a schedule of installation with their plan. Chicago Rail Link operates some freight service between CP 21st Street and 16th Street (BNSF Jct.). Amtrak has requested information about the number of locomotives that will be equipped and a schedule to do so but CRL has not provided this information (see latest e-mail correspondence, Appendix A, p. 15A). 8.4.4 Tenants Operating in New Orleans Union Passenger Terminal Canadian National Railroad operates an occasional local freight train in NOUPT to deliver paper to the Times Picayune. CN will operate with V-ETMS on-board equipment. CN is filing its own PTCIP and will provide a schedule of installation with its plan. PTC Implementation Plan 65 9 Wayside Devices [§236.1011(a)(7)] 9.1 General This section identifies the wayside devices or subsystems which must be installed for the PTC system. It is broken down by line segment as the systems will be installed. It addresses major components. The unit counts may change as design is finalized by line segment. At this stage of the project these are estimated quantities only. Wayside Interface Units (WIU) or Encoders will be installed at interlockings. It is estimated that one WIU or encoder will be required for every 4 controlled signals. The schedule for installation was addressed in Section 7 and will not be repeated here. 9.2 Northeast Corridor ? ACSES Installation Following is a breakdown of the equipment to be installed on the NEC for ACSES by ACSES line segment. Line 3 (Mill River to Cove) already has ACSES installed and in service. Line Segment Transponders Encoders or WIU BCP Radio & Antenna Line 1 & 7 New York to Zoo 1398 111 26 Line 2 Zoo to Avenue 1550 96 36 Line 4 Philadelphia to Harrisburg 910 51 20 Line 5 Mill River to Springfield 300 22 12 Line 6 JO to Shell 155 27 7 Line 8 Empire Connection 140 4 3 Total 4453 311 104 9.2.1 Northeast Corridor ? VETMS Overlay in ACSES Territory The WIU?s at the interlockings will serve as ACSES Encoders and V-ETMS WIU?s so no additional wayside equipment will be required other than V-ETMS base radios which will be installed approximately every 10 miles. A Back Office Server will be installed at the new CETC dispatching center in Wilmington, DE to handle the V-ETMS database, movement authorities and TSR data. V-ETMS base radios and antennas will be installed as follows: Line 1 Hudson to Zoo: 7 locations Line 2 Zoo to Avenue: 12 locations Line 4 Philadelphia to Harrisburg: 10 locations Line 5 Mill River to Springfield: 6 locations 9.3 Michigan Line ? ITCS Installation Most of the Michigan Line already has ITCS installed. Amtrak currently has a contract with General Electric Transportation Systems (GETS) to complete the installation of PTC Implementation Plan 66 ITCS on the line. The following devices will be installed along with new wired houses for most of the signal and crossing locations. Location Qty. / Type Servers WIU Radio/Antenna Control Points 6 8 Signals & Crossings 61 A fiber optic cable is being installed on the Michigan Line. All the WIUs will be connected to the server locations by the fiber cable. No 220 MHz radios will be required at the WIU locations. 9.4 Chicago Terminal ? V-ETMS Chicago Terminal will have V-ETMS installed between Polk Street and 21st Street (CN Crossing) where passenger speed is 30 mph and freight speed is 10 mph. An MTEA is being submitted for the passenger terminal where passenger speed is 15 mph. Location WIU Radio/Antenna CP Taylor 1 1 CP Roosevelt 2 1 CP 16th Street 1 1 CP Lumber Street 1 1 21st Street (CN Crossing) 1 1 A Back Office Server (BOS) will be installed in the dispatching center at Chicago Union Station and a data radio and leaky coax cable will be installed in the platform area of the station for train initialization and downloading of database information. 9.5 New Orleans Union Passenger Terminal ? V-ETMS New Orleans Union Passenger Terminal will have V-ETMS installed on segments previously described where passenger speed is 30 mph. An MTEA is being submitted for the area between the station building to CP Clara and the South Wye where passenger speed is only 10 to 15 mph. Location WIU Radio/Antenna CP Clara 1 1 CP North Wye Jct. 1 1 CP Carrollton Jct. 1 1 Southport Jct. 1 1 East City Jct. 1 1 A data radio and antenna will be installed in the platform area of the station for train initialization and downloading of database information. The terminal is dispatched from the Chicago dispatching center where the BOS will be located. PTC Implementation Plan 67 9.6 CP Virginia to ?A? Interlocking ? Washing Union Terminal ? V-EMTS This line segment connects Washington Union Terminal to the CSX mainline leading south. This segment is used by Amtrak and VRE passenger trains. Location WIU Radio/Antenna CP Virginia 1 1 Signals 18LA and 20LA 1 1 Signals 1339/1349 1 1 ?A? Interlocking 1 1 A data radio and antenna will be installed in the lower level platform area of Washington Union Station for train initialization and downloading of database information. The BOS will be located at the CETC dispatching center in Wilmington, DE. PTC Implementation Plan 68 10 Designating Track as Main Line or Non-Main Line [§236.1011(a)(8)] 10.1 General Amtrak defines main track as a track designated by Timetable upon which train movements are authorized by ABS or interlocking rules. On Amtrak, all main tracks are signaled. Non-signaled tracks are not designated as main tracks and are generally operated at restricted speed. Yards, industrial tracks, Maintenance of Way storage tracks, non-signaled sidings and non-signaled running tracks are not main line track. These tracks are not used by revenue passenger trains. In some cases, yard tracks and yard leads are signaled but are not considered main tracks. For example, Wye Bridge Switching Center in Ivy City Yard in Washington, DC is a non-vital switching center equipped with power operated switches protected by low signals displaying only Restricting. Sunnyside Yard in Queens, New York consists of Loop interlocking on the loop tracks leading from the main tracks in F interlocking to the yard, R switching center and Q interlocking. No revenue passenger trains operate in Sunnyside Yard and all trains operate at restricted speed. All of these tracks are non- main line tracks. 10.2 Main Line Track Appendix C through L contains timetable information and track charts that can be used to determine main line tracks. Appendix C contains track charts and timetable information for the Main Line ? New York to Philadelphia (NYP) (Line segments 1&7). The chart in section 240-N1 on Page 165 of the timetable lists all the main line tracks between A Interlocking in New York and Zoo Interlocking in Philadelphia. All non-main line tracks are shaded yellow on the track charts in Appendix C. Appendix D contains track charts and timetable information for Main Line ?Philadelphia to Washington (PW) (Line segment 2). The chart in section 240-P1 on Pages 187 and 188 of the timetable lists all the main line tracks between Girard Interlocking and CP Avenue in Washington, DC. All non-main line tracks are shaded yellow on the track charts in Appendix D. Appendix E contains track charts and timetable information for Main Line ? Philadelphia to Harrisburg (PH) (Line segment 4). The chart in section 240-G1 on Pages 232 and 233 of the timetable lists all the main line tracks between Zoo Interlocking in Philadelphia and State Interlocking in Harrisburg. The chart in section 240-C1 on Page 245 of the timetable lists the main line tracks on the 36th Street Connection linking Penn Interlocking and 30th Street Station in Philadelphia to the Harrisburg Line. All non-main line tracks are shaded yellow on the track charts in Appendix E. PTC Implementation Plan 69 Appendix F contains track charts and timetable information for Main Line ? Mill River to Springfield (MRS) (Line segment 5). The chart in section 240-M1 on page 133 of the timetable lists the main line tracks. All non-main line tracks are shaded yellow on the track charts in Appendix F. Appendix G contains track charts and timetable information for New York Penn Station to New Rochelle (JO to Shell) (Line segment 6). The chart in section 240-H1 on page 143 of the timetable lists the main line tracks between Harold and CP216 on the Hellgate Line and the chart in section 240-T1 on page 151 of the timetable lists the main line tracks between New York Penn Station and Harold. All non-main line tracks are shaded yellow on the track charts in Appendix G. Appendix H contains track charts and timetable information for the Empire Connection (Line segment 8). The chart in section 240-E1 on page 147 of the timetable lists the main line tracks between A Interlocking and CP12 on Metro North Railroad. All non-main line tracks are shaded yellow on the track charts in Appendix H. Appendix I contains track charts and timetable information for Washington Union Terminal including the track segment between CP Virginia and A Interlocking. All non- main line tracks are shaded yellow on the track charts in Appendix I. Appendix J contains track charts and timetable information for the Michigan Line. All non-main line tracks are shaded yellow on the track charts in Appendix J. Appendix K contains track charts and timetable information for Chicago Union Station. The main tracks are shown as solid black lines on pages 2 and 3 of the timetable. Appendix L contains track charts and timetable information for New Orleans Union Passenger Terminal. All non-main line tracks are shaded yellow on the track chart in Appendix L. 10.5 Non-Main Line Track Yards, industrial tracks, running tracks, storage tracks, repair tracks, etc. are not considered main line tracks. Generally trains operate at restricted speed not exceeding an upper speed limit listed in the timetable for these tracks. In most cases these tracks are not signaled but in some cases they are. These tracks are not generally used by revenue passenger trains. Following is a list of Major Yards on the Northeast Corridor all of which are Non-Main Line tracks: ! Southampton Yard in Boston, MA ! Sunnyside Yard in New York including Loop, R and Q Interlockings ! Penn Coach Yard in Philadelphia ! Ivy City Yard in Washington, DC including Wye Bridge switching station ! Wilmington Shops, Wilmington, DE PTC Implementation Plan 70 Following is a list of yards and terminals outside the NEC that are not considered main line track: ! 14th Street Yard in Chicago (Chicago Union Terminal) ! Coach Yard in New Orleans Union Passenger Terminal ! Coach yard in Toledo, Ohio (leased by Amtrak) ! Hialeah Yard in Miami, FL ! Sanford Autotrain Facility in Sanford, FL ! Lorton Autotrain Facility in Lorton, VA ! Oakland Yard in Oakland, CA ! 8th Street Yard in Los Angeles, CA ! King Street Yard, Seattle Washington ! Rensselaer Maintenance Facility and Yare in Rensselaer, NY ! Beech Grove Mechanical Facility in Beech Grove, IN ! St. Louis Coach Yard in St. Louis, MO ! Brighton Park Maintenance Facility in Chicago, IL Many of the above are leased by Amtrak. This list includes the larger facilities. There are numerous other small yards or storage tracks around the country that are not main line track. Main line track would be defined in the timetable by the host railroad that Amtrak operates over that is associated with the facility, yard or storage track. The track charts in Appendix C through M are included as reference for property covered in this PTCIP. Non-main line tracks are identified on these charts by yellow highlighting. Operation on these tracks is at restricted speed and in some cases it is defined as ?restricted speed not exceeding XX? where XX is some speed less than 20 mph. PTC Implementation Plan 71 11 Exceptions to Risk-Based Prioritization [§236.1011(a)(9)] The design of the ACSES expansion on the NEC is already under contract and much of the material is already on order. The ACSES work will be completed for all lines on the NEC before V-ETMS is installed in Chicago even though Chicago Union Terminal ranked higher in priority than Lines 5, 6 and 8 on the NEC. The design of Line 6 (JO to Shell) is scheduled to be completed before Line 4 (Harrisburg Line) which has higher priority. The work force in New York will be able to continue working on Line 6 after the completion of Lines 1&7 (New York to Philadelphia). There is only 4 months difference in the completion dates for Lines 4 and 6. The Michigan Line is third from last in priority but will be completed first, even before completion of any of the NEC ACSES lines. ITCS is already in service on this line and Amtrak has a contract with General Electric Transportation Systems (GETS) to complete the installation of ITCS. The contract is funded with ARRA funds and must be completed by February 2011. ACSES and ITCS are mature PTC systems and therefore can be completed much faster than V-ETMS which is new and unproven. Amtrak will have to work closely with Metra and the Class I railroads in Chicago to implement V-ETMS. Close coordination will also be required with NS and CSX as V-ETMS is developed and implemented on the NEC. For this reason the implementation of V-ETMS will lag behind the completion of ACSES and ITCS. PTC Implementation Plan 72 12 Alternative Arrangements for Rail-to-Rail At-Grade Crossings [§236.1011(a)(10)] There are two rail-to-rail at-grade crossings on Amtrak property. Each of them is addressed below. 12.1 At-Grade Crossing in Michigan City, IN Amtrak?s single main track crosses Northern Indiana Commuter Transportation District (NICTD) tracks at CP 10th Street in Michigan City, IN. There are no connecting tracks between the two railroads. The speed on the Amtrak main track is 50 mph. NICTD plans to install V-ETMS on their railroad and will install a WIU on their track to enforce a positive stop at their home signals. Amtrak is installing ITCS and will install an ITCS WIU to enforce a positive stop at the Amtrak home signals. 12.2 At-Grade Crossing at CP 21st Street in Chicago Union Terminal Amtrak?s two main tracks leading into Chicago Union Terminal cross two main tracks belonging to Canadian National Railroad. The speed on the Amtrak main tracks is 15 mph and the speed on the CN tracks is restricted speed not exceeding 10 mph. Amtrak will install V-ETMS between CP 21st Street and Polk Street in the terminal and will enforce a positive stop at the crossing diamonds at CP 21st Street. The CN tracks will not be PTC equipped. PTC Implementation Plan 73 13 Main Line Track Exclusion Addendum [§236.1019] 13.1 General This section discusses Main Line Track Exclusion Addendums (MTEAs) that are being requested for various areas of Amtrak property. MTEAs on other railroads will be filed in their PTC Implementation Plans. The MTEA requests being filed as part of this plan are in accordance with § 236.1019(b) ? Passenger terminal exception. In all cases the MTEA areas are in Passenger terminal or station areas where speeds are 20 mph or less. Each MTEA request is detailed separately in the following sections. Each MTEA submission provides a summary track description and layout as well as a narrative description of the normal train operations. MTEA?s are being requested for each of the following areas: 1. Washington Union Terminal (between the south limits of ?A? Interlocking to the north limits of ?C? Interlocking including all of ?K? interlocking) where speeds are 15 and 20 mph. 2. Penn Station New York (between west limits of ?A? Interlocking and east limits of ?JO? and ?C? Interlocking) where speeds are 15 mph. 3. Boston South Station (between east limits of Cove Interlocking and Tower 1 Interlocking where speeds are 15 mph, between Tower 1 Interlocking and Boston South Station where speeds are 10 mph and between Broad Interlocking and Tower 1 where speeds are 15 mph). 4. Springfield Terminal (between Sweeney Interlocking and Springfield Station where the speed is 10 mph). 5. Harrisburg, PA passenger terminal area (between signals 100L &102L in State Interlocking and the west limits of Harris Interlocking, Amtrak/NS boundary, where speed is 15 mph). 6. Chicago Union Station (between Polk Street and Canal Street where speed is 15 mph). This includes the North and South Passenger terminal areas and the connecting tracks between them. 7. New Orleans Union Passenger Terminal; ((a) between CP Clara Street and NOUPT Station Tracks where speed is 10 mph; (b) between CP Clara Street and South Wye Jct. where speed is 15 mph; (c) between CP South Wye Jct. and Earhart Jct. where speed is 15 mph; (d) between North Wye Jct. and South Wye Jct. where speed is 10 mph). PTC Implementation Plan 74 13.2 Washington Union Terminal (WUT) An MTEA is requested for Washington Union Terminal between the South limits of ?A? Interlocking starting at signals 18L and 20L (Fig. 13.2-3) and the North limits of ?C? Interlocking (Fig. 13.2-1) including all of ?K? interlocking (Fig. 13.2-2) and all platform tracks within Washington Union Station with the exception of numbers 40, 41 and 42 tracks between CP Avenue and Bridge J (shaded in pink in Fig. 13.2-1). The CSX tracks north of signals 445 and 513 (shaded in blue in Fig. 13.2-1) are not included in this MTEA. The basis for this MTEA request is § 236.1019(b) Passenger terminal exception. The trackage in the terminal area for which the MTEA is being requested is used exclusively by passenger and commuter operations. The maximum track speed within WUT on the tracks included in this request is 15 mph (20 mph northbound between J and H signal bridges and on all tracks except 40 and 42 within the terminal). All trains operating into and out of WUT on Amtrak operated tracks will be equipped with an onboard cab signal system which will enforce restricted speed capped at 20 mph within the terminal. Trains operating from CSX tracks will be equipped with a V-ETMS PTC system and speeds will be capped at 20 mph by that system to the extent which is possible. Interlocking rules are in effect, prohibiting reverse movements (except with signal indications controlled by a dispatcher) for the entire area for which the MTEA is being requested. Freight movements will not be performed within the MTEA area. The speed on tracks 40 and 42 between CP Avenue and Signal Bridge ?J? is 45 mph. These tracks are equipped with cab signals and will be PTC equipped. The speed on track 41 is only 15 mph but a positive stop will be enforced at signal 419 for northbound moves. The crossovers between 39 and 40 tracks will provide flanking protection for the 45 mph moves on track number 40. The terminal is a slow speed area with closely spaced signals. It would be extremely difficult, if not impossible, to place transponders the proper distance to enforce a positive stop at stop signals. Likewise, it would be extremely difficult, if not impossible, to enforce a stop signal at the proper point with a system such as V-ETMS that uses GPS for location determination due to the close spacing of signals. There are many switching moves within the terminal for adding and dropping cars and changing engines further complicating the installation of PTC. WUT is used by Amtrak intercity passenger trains and MARC and VRE commuter trains. There are 24 Amtrak trains and 30 VRE trains operating into and out of the terminal through the First Street Tunnel each day. There are 88 Amtrak trains operating between WUT and Philadelphia and 48 MARC trains operating between WUT and Baltimore with another 38 MARC trains operating between WUT and CSX lines. In addition, there are numerous moves to and from Ivy City Yard each day. PTC Implementation Plan 75 Figure 13.2-1 WUT ? ?C? Interlocking PTC Implementation Plan 76 Figure 13.2-2 WUT ? ?K? Interlocking PTC Implementation Plan 77 Figure 13.2-3 WUT ? ?A? Interlocking PTC Implementation Plan 78 13.3 Penn Station New York (PSNY) An MTEA is requested in Penn Station New York between the 10th Avenue signal bridge (westbound signal bridge just east of the 10th Avenue Portal) and signal 162E on the Empire Connection and the east limits of ?JO? (512W signal on Line 1 and 508W signal on Line 2) and ?C? (634W signal on Line 3 and 636W signal on Line 4) interlockings. The tracks in E-Yard and the tracks leading to The Long Island Railroad?s West side storage yard (1,2,3 and 4 Lead tracks) are not considered main line tracks and will also not be PTC equipped. Refer to the track and signal layout drawing Figure 13.3-1 in Appendix M. The basis for this MTEA request is § 236.1019(b) Passenger terminal exception. The trackage in the terminal area for which the MTEA is being requested is used exclusively by passenger and commuter operations. The maximum track speed within PSNY is 15 mph except for 3X and 4X tracks which will be limited to 20 mph. All trains operating into and out of PSNY are equipped with an onboard cab signal system. The onboard cab signal systems will enforce restricted speed (not exceeding 20 mph) within the limits of Penn Station. Interlocking rules are in effect, prohibiting reverse movements (except with signal indications controlled by a dispatcher) for the entire area for which the MTEA is being requested. Freight movements will not be performed within the MTEA area. Penn Station New York is the busiest station on the Amtrak network. There are 114 daily Amtrak trains and 340 New Jersey Transit trains operating to and from the station through the two North River (Hudson River) tunnels and 24 Amtrak trains operating to and from the station through the Empire tunnel. There are 42 daily revenue Amtrak trains and 455 Long Island Rail Road revenue trains operating to and from the station through the four East River tunnels. Additionally there are 197 non-revenue Amtrak and NJT trains operating through the East River tunnels to and from Sunnyside yard and 108 non-revenue LIRR trains operating to and from the Long Island Rail Road. Due to the close spacing of signals and switches in this complex terminal it would be extremely difficult if not impossible to install PTC to enforce a positive stop at stop signals. All trains operate at slow speed (15 mph) and there are many switching moves that are made throughout the day. PTC Implementation Plan 79 13.4 Boston South Station An MTEA is requested in the Boston South Station terminal area between the ?end of track? in South Station (including all of Tower 1 interlocking) to the east limits of Cove interlocking on the NEC main tracks and to Broad interlocking on the Dorchester Branch. Refer to the track and signal layout drawing in Figures 13.4-1 and 13.4-2 in Appendix M. This property is owned by MBTA but is leased to and operated and dispatched by Amtrak. The basis for this MTEA request is § 236.1019(b) Passenger terminal exception. The trackage in the terminal area for which the MTEA is being requested is used exclusively by passenger and commuter operations. The maximum track speed within this area is 15 mph (10 mph within South Station platform areas). All trains operating into and out of South Station are equipped with an onboard cab signal system. The onboard cab signal systems will enforce restricted speed (not exceeding 20 mph) within the limits the MTEA area. Interlocking rules are in effect, prohibiting reverse movements (except with signal indications controlled by a dispatcher) for the entire area for which the MTEA is being requested. Freight movements will not be performed within the MTEA area. There are 38 daily Amtrak trains operating to and from South Station. MBTA operates 112 trains into the station from the Northeast Corridor through Cove interlocking and 102 trains per day from their commuter lines through Broad interlocking. There are also yard moves to and from Southampton Yard. All trains are operated at slow speed (15 mph max.). PTC Implementation Plan 80 13.5 Springfield Passenger Terminal An MTEA is being requested in Springfield, MA for the area between the South limits of Sweeney interlocking to and including the station tracks (tracks 4, 6 and 8) in Springfield Station. Refer to track and signal layout chart in Figure 13.5-1 on the following page. The basis for this MTEA request is § 236.1019(b) Passenger terminal exception. The trackage in the terminal area for which the MTEA is being requested is used exclusively by passenger and commuter operations. The maximum track speed within this area is 10 mph. All trains operating into and out of Springfield Station are equipped with an onboard cab signal system. The onboard cab signal system will enforce restricted speed (not exceeding 20 mph) within the limits the MTEA area. Interlocking rules will be in effect, prohibiting reverse movements (except with signal indications controlled by a dispatcher) for the entire area for which the MTEA is being requested. Freight movements will not be performed between Sweeney and Springfield station on No.2 track. Amtrak operates 12 daily trains between New Haven, CT and Springfield, MA. These trains terminate at Springfield Station and then make the reverse run to New Haven. There are no other carriers operating into Springfield Station on these tracks. PTC Implementation Plan 81 Figure 13.5-1 Springfield Passenger Terminal PTC Implementation Plan 82 13.6 Harrisburg, PA Passenger Terminal An MTEA is being requested for the Harrisburg, PA passenger terminal area between signals 100L & 102L and the west limits of Harris interlocking (boundary between Amtrak and NS). Refer to the track and signal layout drawing in Figure 13.6-1 on the following page. The basis for this MTEA request is § 236.1019(b) Passenger terminal exception. The trackage in the terminal area for which the MTEA is being requested is used exclusively by passenger trains. The maximum track speed within this area is 15 mph. All trains operating into and out the terminal are equipped with an onboard cab signal system. The onboard cab signal system will enforce restricted speed (not exceeding 20 mph) within the limits the MTEA area. Interlocking rules will be in effect, prohibiting reverse movements (except with signal indications controlled by a dispatcher) for the entire area for which the MTEA is being requested. Freight movements will not be performed within the MTEA area. Amtrak operates 28 trains per day to and from the Harrisburg terminal not including switching moves for turning trains, changing engines etc. All moves are made at slow speed (15 mph) and there is seldom more than 2 trains moving at one time. PTC Implementation Plan 83 Figure 13.6-1 PTC Implementation Plan 84 13.7 Chicago Union Terminal An MTEA is being requested for the portion of the Chicago Union Terminal between the Polk Street Overhead Bridge South of Chicago Union Station to Canal Street (junction with Metra) at the Northern end of the Terminal. Refer to the track and signal layout drawings in Figures 13.7 ? 1 to 13.7 ?4 in Appendix K. The basis for this MTEA request is § 236.1019(b) Passenger terminal exception. The trackage in the terminal area for which the MTEA is being requested is used exclusively by passenger trains. The maximum track speed within this area is 15 mph. All trains operating into and out the terminal will be equipped with an onboard V-ETMS system. The V-ETMS system will enforce the 15 mph speed restriction to the maximum extent possible within the limits the MTEA area. Interlocking rules will be in effect, prohibiting reverse movements (except with signal indications controlled by a dispatcher) for the entire area for which the MTEA is being requested. Freight movements will not be performed within the MTEA area. There are 58 daily Amtrak trains operating to and from Chicago Union Station not including yard moves. There are 151 Metra commuter trains operating between CP Canal and the North side of the station and 134 Metra trains operating to and from the South side of the station. PTC Implementation Plan 85 13.8 New Orleans Union Passenger Terminal (NOUPT) An MTEA is being requested for the following portions of NOUPT: ! Between CP Clara Street and the Passenger Station including all platform tracks. ! Between CP Clara Street and Earhart Jtc. ! Between CP South Wye Jct. and CP North Wye Jct. Refer to the track and signal layout drawing in Figure 13.8-1 in Appendix M. The basis for this MTEA request is § 236.1019(b) Passenger terminal exception. The trackage in the terminal area for which the MTEA is being requested is used exclusively by passenger trains. The maximum track speed within this area is 15 mph (10 mph between North Wye Jct. and South Wye Jct.). All trains operating into and out the terminal will be equipped with an onboard V-ETMS system. The V-ETMS system will enforce the 15 mph speed restriction to the maximum extent possible within the limits the MTEA area. Interlocking rules will be in effect, prohibiting reverse movements (except with signal indications controlled by a dispatcher) for the entire area for which the MTEA is being requested. Freight movements will not be permitted within the MTEA area where revenue passenger trains are operated. There are four daily, and two tri-weekly, trains operating to and from NOUPT. The Crescent operates daily (one train each direction) between New York and New Orleans through the East City Jct. connection between NOUPT and the Norfolk Southern Railway. The City of New Orleans operates daily (one train each direction) between Chicago and New Orleans through the Southport Jct. connection with the Canadian National Railroad (formerly Illinois Central). The Sunset Limited operates between Los Angeles and New Orleans with arrivals in New Orleans on Tuesdays, Fridays and Sundays and departures on Mondays, Wednesdays and Fridays. The Sunset Limited operates through the Southport Jct. connection with CN. If trains operate on schedule, there is never more than one revenue train moving at a time. There is an occasional freight delivery to the Times Picayune by a CN local freight. These deliveries are scheduled when no revenue passenger trains are operating in the terminal. PTC Implementation Plan 86 14.0 Appendices The following appendices are included as attachments to this document: 14.1 Appendix A ? Agreements and Letters between Amtrak and its Tenant Railroads 14.2 Appendix B ? Agreements and Letters between Amtrak and its Host Railroads 14.3 Appendix C ? Track Charts and Timetable Information for NEC Line 1 and 7 - New York to Philadelphia 14.4 Appendix D ? Track Charts and Timetable Information for NEC Line 2 ? Philadelphia to Washington 14.5 Appendix E ? Track Charts and Timetable Information for NEC Line 4 ? Philadelphia to Harrisburg 14.6 Appendix F ? Track Charts and Timetable Information for NEC Line 5 ? Mill River to Springfield 14.7 Appendix G ? Track Charts and Timetable Information for NEC Line 6 ? JO to Shell 14.8 Appendix H ? Track Charts and Timetable Information for NEC Line 8 ? Empire Connection 14.9 Appendix I ? Track Charts and Timetable Information for CP Virginia to Washington Union Terminal 14.10 Appendix J ? Track Charts and Timetable Information for Michigan Line 14.11 Appendix K ? Track Charts and Timetable Information for Chicago Union Station 14.12 Appendix L ? Track Charts and Timetable Information for New Orleans Union Passenger Terminal 14.13 Appendix M ? Track Charts in Support of MTEA Requests (Section 13) 14.14 Appendix N ? Risk Analysis NTSB Hearing Jeff Young Youn Asst. Vice President ? Transportation Systems March 4, 2009 1 Topics to Address ? Current Train Control Systems ? Concerns with Existing Systems ? How does PTC Address Concerns with Existing Systems ? UP PTC Pilot Locations ? PTC Challenges Challenge ? PTC Implementation Plan ? PTC Project Timeline 2 Dark Territory Track Warrant Control AMTKTrack Warrant Authority Limits ? Main Track Not Signaled ? Movement Authority Conveyed By Track Warrant or Direct Traffic Control Authorit Conveye rac Contro permit ?2. [X] Proceed From (Station or Location) To (Station or Location) On Main Track Spokane Subdivision ?8. [X] Hold Main Track At Last Named Point ? Train separation provided by train dispatcher and train crew 3 Automatic Block System (ABS) Track Warrant Control AMTKTrack Warrant Authority Limits ? Main Track Signaled for Movement in Both Directions rac Bot Direction ? Movement Authority Conveyed By Track Warrant or Direct Traffic Control permit ?2 [X] Proceed From (Station or Location) To (Station or Location). On Main Track Spokane Subdivision ?8. [X] Hold Main Track At Last Named Point ? Train separation provided by train dispatcher, train crew and signal system 4 rai signa syste Automatic Block Signal (ABS) Current Of Traffic Field Signal Indication ? Two Main tracks with an assigned direction of movement ? Movement authority is conveyed by signal system ? The tracks are only signaled for movement in the assigned direction ? Train separation provided by train crew and signal system 5 Centralized Traffic Control (CTC) Field Signal Indication ? One or More Main Tracks Signaled for Traffic in Both Directions ? Movement authority is conveyed by signal system ? Train dispatcher controls switches and signals from distantrai control signal location ? Train separation provided by train crew and signal system 6 Automatic Train Stop (ATS) Operation Field Signal Indication In Cab Acknowledgement ? In Cab alarm sounds when train passes any signal that is not green ? Engineer has six (6) seconds to acknowledge ATS alarm or the si alar train brakes are applied ? Once the acknowledgment is performed, there is no further enforcement ? Train separation provided by train crew and signal system assisted by ATS alarms 7 Automatic Cab Signal (ACS) Operation Field Signal Indication In Cab Acknowledgment ? All wayside signal indications are displayed in the locomotive cab Wh l ti t i ti i l i t? en ocomo ve passes a more res r c ve s gna , eng neer mus acknowledge within six (6) seconds or the brakes are applied ? Once the acknowledgment is performed, there is no further enforcement ? Train separation provided by train crew and signal system assisted by ACS alarms 8 Automatic Train Control (ATC) Operation Field Signal Indication CAB Signal Indication ? All wayside signal indications are displayed in the locomotive cab ? When locomotive passes a flashing yellow signal, an alarm sounds and the engineer has six (6) seconds to acknowledge or the brakes si will be applied. ? The engineer then has seventy (70) seconds to reduce to 20mph or less, or the brakes will be applied. ? Once the train is under 20mph no further enforcement is applied ? Train separation provided by train crew and signal system assisted by d t l 9 spee con ro Concerns with Existing Systems ? Systems are reactive as opposed to predictive ? Many systems wait for a violation to occur before any form of enforcement is invoked (ATS and CCS) S t d d h li? ys ems epen on uman comp ance ? Very time consuming to design and install 10 PTC Interoperability Objectives S f? Meet Rail a ety Act requirements ? Train to train collisions Incursions of trains into established work zone limits? zon ? Over-speed derailments ? Movement of a train through a switch in the wrong position ? Meet regulatory requirements for production deployment ? FRA?s new CFR Part 236 Subpart I ? Support industry interoperability initiatives ? Telecomm, system behavior, human factors 11 GPS UP?s PTC System Vital Train Management System (VTMS) Position Reference Back Office Server (BOS) VTMS On Board Equipment ? Human-Machine Interface Display Terminal ? On-Board Computer ? Location Determination System ? Digital radio (voice & data)Computer-Aided Dispatching 12 VTMS ? System Overview Track Databaseac Speed Restrictions Work Zones Train Consist Movement Authorities ? Switches ? Work Zones ? Signals Initialization Warning Curve Speed Restrictions Braking Curve Predictive Braking 13 Vital Train Management System (VTMS) Pilot Locations South Morrill & Powder River Subs North Platte S.Morrill Bill Green River Cheyenne ChicagoBoone ? 193 miles multiple track CTC/ACS ? 75+ trains per day ? 50 AC44 locomotives to equip KC Denver St. Louis Boone Sub ? 123 Miles CTC/ATC ? 62 trains per day CP Canada Washington S ttl Eastport Cranbrook Spokane Sub 140 Mil TWC/D k pe da ? 50 AC44 locomotives Nampa ea e Spokane Portland ? Mi es TWC/ ar ? 7 trains per day ? 15 UP SD9043 locomotives and 15 CP locomotives 14 Positive Train Control (PTC) Challenges ? Communications Spectrum ? Ensuring enough throughput for safe and efficient movement of trains ? Interoperability ? Communications, System Behavior and Response and On Board Display ? Predictive Enforcement Complexity ? Ensure safe braking calculations ? Installation of Wayside Interface Units (WIUs), Locomotive Equipment and Telecommunications Infrastructure ? 24,751 WIUs to install (9.9 per day between now and 12/31/2015) ? 6,000 Locomotives (2.4 per day between now and 12/31/2015) ? 970 Base Station Radios ? Uncertainty with new Subpart I Regulations 15 Communications Spectrum ? Spectrum is like a highway - ? Radio channels are like lanes of the highway ? Too much traffic on a channel of Spectrum will cause congestion ? The 220 spectrum was purchased by UP and NS to support the expected data traffic from the freight railroads. ? Additional spectrum will be needed as more railroads are added ? Early projection for spectrum is ~250 KHz ~25 (5 25KHz channel pairs) of 220 MHz spectrum ? Spectrum demand study will commence soon 16 Interoperability ? Communications ? Standards that permit one railroad?s locomotive to safely and efficiently operate over another railroad?s infrastructure ? UP, NS BNSF and CSX have agreed to interoperable communications standards ? The four Class 1 railroads have agreed to locomotive display standards ? Simplifies training and increases safety through common operating standards ? UP, NS, BNSF and CSX are using WABTEC for the on board PTC system 17 Interoperability Scenario CANADABlaine Aberdeen Seattle BNSF Union Pacific UP & BNSF both operate on BNSF trackage WASHINGTON Centralia Kelso BNS PascoVancouver Portland Wishram Oregon Trunk Jct Hinkle 18 OREGON What is the Interoperability Agreement? ? BNSF, CSX, NS and UP are signatories ? Agreement to implement technical standards for: ? Locomotive to wayside communication ? Locomotive to back office communication ? Locomotive on board system behavior ? Locomotive on board displays ? Agreement for governance ? Working committee ? Steering committee ? Executive committee Agreement to manage 220 MHz spectrum 19 ? manag 19 Predictive Enforcement Complexity ? Predictive braking algorithms (software) must stop trains before authority violations with very high fdegree o reliability ? Algorithms must be smart enough to adapt to changing conditions ? Weather Train tonnage? ? Different types of cars Weight variation in the train? 20 Uncertainty with new Subpart I Regulations ? PTC scope beyond CFR 236 Subpart H requirements ? Current PTC systems development has been done to meet the standards with CFR 236 Subpart H ? How to deal with Class 2 and 3 railroads exempt from RSIA b t t Cl 1 li th t i PTC u opera e on ass nes a requ re 21 Priority Areas for Implementing PTC ? UP has committed to have PTC installed in the LA Basin by 12/31/2012 ? Commuter/Passenger lines will be next ? Southern and Northern California ? Chicago, Salt Lake City, Denver, etc. ? Followed by TIH routes ? Risk assessment will dictate remaining implementation plan 22 Project Timeline Pilot Program 2008 2009 2010 2011 2012 2013 2014 2015 2016 Regulatory Filing Regulatory Approval System Deployment LA Basin Complete System Deployment Complete 23 http://strategicrailroading.com/   Teddy Bear- No Time For Strategy November 23rd, 2010 | Author: Ron Lindsey Arguably, the most frequent Teddy Bear (i.e. fatuous, rationalizing statements) coveted and expressed by railroaders and suppliers alike is ?We have no time for strategy. . . too much going on.? As a consultant that focuses on the strategic deployment of technologies aligned with the appropriate changes in the business processes (a.k.a. strategic railroading), I have been able to maintain my cool in such conversations by chiming in with ?Really??, and with some semblance of respect, I believe. But, what I want to do, really, is reach across the desk and slap the guy silly while calmly screaming ?What in the world are you thinking here?? ? or ? ?You need to let go of those next-year?s bonus issues for a moment.? ? or ? ?So, I guess you don?t own, or plan to own, stock in the company?? Granted, I have a self-serving interest in getting this individual to think beyond the horizon of his bonus plan. And, if s/he did so we could have a win-win ? Really! Approaching a railroad or a supplier to talk about technology and process strategies, either individually or ideally together, is not a simple cold-call situation for which I was well trained 40 years ago during my span with IBM. Back then IBM was challenged with getting business executives to understand the value of computers to handle simplistic clerical efforts, e.g., updating inventory, accounts receivables, and processing payroll. Back then, the primary functions didn?t change with the use of the computer. The clerks just disappeared. Therefore, any business executive with a clerical workforce was a possible mark for a computer salesperson that could spin business cases. As such, a major part of IBM?s training was on how to make and present the business case using real- world adaptations to the principles that the thousands of MBA?s that were hired had learned in class. We talked about inventory turnover, return on investment, internal cost of capital, discounted cash flows, regression analysis, and even econometric modeling. BUT, we didn?t talk about changing the underlying business processes beyond that of the back office; we didn?t get into the functional operations of the company. The point here is that making a cold-call on an executive back in the 70?s was not the same as hitting on Operations management of today that don?t understand what technologies can do for their core business processes. Today, there are four primary challenges to advance railroad operations in sync with a strategic technology plan. The first challenge is identifying which positions in the individual railroads and across the supplier community would be willing to talk about technology and/or process strategy? Unfortunately, to my knowledge, there is not one position associated with operational (non IT) technologies in any of the railroads or the suppliers that have any form of the Greek root strategia in its title. Additionally, as I have pointed out in other postings on this blog, there aren?t even technologists. That is, while the railroads and suppliers have scores of technicians that push technologies at any costs, there aren?t those individuals that could do so in a pragmatic, cost-effective fashion, with or without modifying the underlying processes to take advantage of what the advancing technologies can do. The second challenge is that the focus of the Class I railroads to meet the Positive Train Control (PTC) mandate deadline of 12/31/2015 has been the black hole of technicians. They have been totally and reluctantly drawn into the challenge of interoperability, or so it would seem. Actually, what has really happen is that they have willingly escaped into their respective caves to do what they really like to do; design the ultimate technology platform, whether or not it is required. No one is watching, challenging, or redirecting these guys because they are the High Priests of what can has to be done ? and no one else really understands, and therefore challenges, the underlying principles of their religion. The third challenge, therefore, is getting railroad operations management involved so as they will take charge of advancing their railroads via advancing technologies based upon sound business logic that is both pragmatic and cost- effective; business cases that include terms like return on investment, discounted cash flows, regression analysis, etc. Again, there is no position in the railroads currently that could be reasonably charged with this responsibility: It certainly isn?t the CIO. What is needed is a Chief Technologist or something like that ? maybe Chief Strategic Technologist, whatever. Lastly, the fourth challenge is that of involving and evolving the suppliers. With only one exception in the past 2 decades in North America, they have kowtowed to the tactical issues that drive their railroad customers so as to make their bonuses. The bottom-up approach to marketing products and services in the rail industry is a very traditional approach and rightfully so for the past 100 years because the technologies have been, aaahhh ? traditional. Now, wireless data offer a paradigm shift in operations, just as IT has evolved over the past 40 years, and to bring the possible advancements to the industry will require top-down marketing. That simply isn?t happening today ? and probably won?t until the PTC issue has subsided sometime after the < 2016 deadline. The good news is that I am starting to hear rumblings from railroaders and suppliers alike that the PTC interoperability issues are out of control. Indeed, it is possible that perhaps some railroads won?t buy into the 220 MHz network as it being the universal wireless data panacea. Indeed, the requirement for a Communications Management Unit (CMU) on board to handle multiple wireless paths, as first addressed in my quarterly journal Full Spectrum a decade ago, is hopefully being revitalized. Maybe, it never really died in the minds of some, especially when the 220 MHz network began being slammed down the throats of several Class I?s two years ago.         http://strategicrailroading.com/2010/07/a?wealth?of?wireless?missing? opportunities/   A Wealth of Wireless ? Missing Opportunities   July 25th, 2010 | Author: Ron Lindsey  This is the third of three postings to address the Strategic Core Infrastructure that  is  required  to  advance  railroad  operations  .  .  .  essentially,  the  technology  that  is  required to pursue Strategic Railroading. Each posting addresses one of the three  core  technologies  that  together  comprise  the  core  infrastructure.  Whereas  the  previous  two  postings  addressed  INTELLIGENCE  (The  Mobile  Node)  and  POSITIONING  (The  Positioning  Engine),  this  posting  addresses  COMMUNICATIONS.  As  recently  as  2  years  ago,  the  adage  too­much­of­a­good­thing  would  not  have  seemed  appropriate  when  discussing  wireless  technologies  that  could  be  used  by  railroads. But since then, the sky has opened up with the expanding availability of  commercial wireless networks and most importantly the opportunity to implement  trunking in the railroads? extensive 160?161 MHz band that is subjected to the FCC?s  Refarming Order, a.k.a. narrow?banding.  As to the latter, the efficiency of trunking,  which dynamically allocates available channels to users (versus the traditional use  of  dedicated  channels,  e.g.,  one  channel  per  yard  crew),  in  concert  with  the  opportunity  for  a  multiple?fold  increase  in  the  number  of  channels  obtainable  by  narrow?banding provides the railroads with an unprecedented amount of capacity  to handle both voice and data in even the most complex metropolitan and mainline  operations.  Apparently  that wasn?t enough  for most Class  I  technicians.  They wanted more ?  and more ? and so a 220 Mhz band was purchased several years ago that will result  in  two  parallel  VHF  networks  across  the  industry.  The  timing  was  fortuitous  it  seems, because with the subsequent, and foreseen, PTC mandate that would require  a  wireless  data  infrastructure,  the  220  Mhz  band  readily  resolved  three  major  challenges for the technicians, albeit with a price tag expected to approach a cool $  Billion.  First,  the  railroad  technicians  were  able  to  avoid  the  significant  challenge  (but a clearly an achievable one with the use of trunking) of reshuffling the channels  required  for  the  FCC?s  refarming mandate.  Second,  the  railroad?s  technicians  once  again  were  handed  their  most  desired  type  of  project,  i.e.,  develop  the  ultimate  wireless  communication  infrastructure  whether  it  is  needed  or  not.   Third,  the  railroads? technicians finally had a true reason to cooperate in building an industry? based  communications  platform.  Up  until  the  PTC  mandate,  the  ?Roadmap  to  Interoperability?,  as  the  technicians  referred  to  their  efforts  to  define  conformity  across the industry, better represented an etch?a?sketch of numer???ous paths with a  roadblock on each since  it seemed each major railroad had its individual technical  agenda.  There  are  several  key  underlying  points  that  are  not  being  considered  by  Class  I  technicians or by their management when it comes to the cost?effective deployment  of technologies? most importantly wireless data.  It takes so little data to achieve the majority of the business benefits of advanced  operations  within  a  railroad,  and  across  the  industry.  For  example,  for  U.S.  freight railroads the periodicity of train speed and position data required to  optimize  the  use  of  meet/pass  planners  is  no  more  frequent  than  every  5  minutes;  PTC does not require extravagant wireless platforms.  This is not traffic control;  Either  the  160  Mhz  with  trunking  or  the  sophisticated  220Mhz  platform  will  handle any railroad?s requirements.  Railroads could be  using commercial  cellular and/or the Meteorcomm  that  they  bought into NOW to advance key operating advances. There is no reason to  wait for either VHF infrastructure to be advanced.  Bottom?line: More can be done with less and it can be achieved NOW.  When it comes to implementing and designing for wireless data, the Class I railroads  are not considering the railroad?s bottom line.  What a shame.  Hence, my posting on  the use of Technologists in lieu of technicians to build a strategic technology plan in  sync with a strategic operating plan, a.k.a. Strategic Railroading. http://strategicrailroading.com/2010/07/the-positioning-engine-changing- railroads-core-technology/ The Positioning Engine ? changing railroad?s core technology   July 15th, 2010 | Author: Ron Lindsey   The  North  American  railroads  have  the  opportunity  to  make  a  phenomenal  paradigm shift in running their operations, both individually and collectively as an  industry. However, to date they have failed to recognize the possibilities, yet alone  to take a proactive position to break away from traditional railroading and make  the  transition  to  strategic  railroading,  i.e.  syncing  strategic  operations  with  a  strategic technology plan.    The  reasons  for  such  an  unfortunate  lack  of  progress  are  actually  quite  few  but  nonetheless difficult to overcome with the railroads? current management teams.  In  the  simplest  terms,  the  reasons  reduce  to  the  lack  of  a  true  business  perspective  relative to the deployment of technologies by railroads and suppliers alike.  This is  due to the lack of Technologists that can provide cost?effective technology solutions  that support operational changes ? instead of the current terror of technicians who  believe they are driven to deliver the ultimate system, i.e., technology platforms that  only they can design.    The  shift  to  strategic  railroading  is  based  upon  making  substantial  changes  in  a  railroad?s  core  technology  infrastructure,  i.e.,  the  mixture  of  communication,  intelligence,  and  positioning  technologies.   Such  changes  will  eliminate  the  constraints  placed  upon  operations  by  the  two  traditional  technologies  that  have  been in use since the early part  of the  last century,  i.e.,  track  circuits and wireless  voice.   Each  of  the  three  technologies  that  comprise  the  core  technology  infrastructure  will  be  explored  in  individual  postings  with  this one  addressing  the  positioning perspective.    I  start  this  perspective  by  first  looking  back  to  the  80?s  and  90?s  to  several  interesting, not always successful, pursuits of various positioning concepts. At that  point, wireless data was beginning to get some facial hair with End?of?Train (EOT)  being the first true application of its use across the industry.  More importantly, or  so it seemed at the time given the hype of the GE?Harris combo, a significant attempt  was  made  by  several  railroads  to  advance  traffic  management.  Referred  to  as  Advanced Train  Control Systems (ATCS),  this platform attempted  to  incorporate a  concept for a positioning technology to ascertain which track a train was on when in  parallel track operations, as well as another concept for determining the precision of  position along the track required for moving block. Fortunately, the industry soon  rejected  the  two  ill?founded  concepts,  i.e.,  transponders  embedded  in  tens  of  thousands  of  track  miles,  and  expensive,  on?board  gyro  platforms  infused  with  convoluted track databases.  Shortly after the demise of ATCS, I was employed by CSX to develop a Positive Train  Control (PTC) system for dark territory operation.  A major challenge was to find a  solution  for  parallel  track  operation  without  the  availability  of  track  circuits  to  declare block/track occupancy. Luckily, I had the advantage of what not to do given  the  ATCS  failure.  The  solution  I  developed,  that  has  since  been  used  in  all  PTC  pursuits by  freight  railroads  in North America, was to monitor switch  position for  the back office system to ?route? the train within the accuracy of GPS once the initial  track  was  known  by  PTC.   There  were  significant  additional  advantages  to  monitoring switches, i.e., being able to enforce a train should the crew be in danger  of violating either the switch?s position or run?through speed.    While routing has been incorporated successfully into PTC functionality, there  still  remains the issues of accuracy and timeliness of positioning data for the purpose of  advancing  railroad  operations.  Specifically,  what  is  missing  is  the  middle  ground  between  what  the  century?old  technologies  provide  and  what  the  technicians  left  unmanaged with seemingly unlimited  capital funds would provide (as  is  currently  the case).  The former can only provide block ID, and not actual position or speed of  a train  in signaled territory. In dark territory, not even that level of information  is  available.   Contrarily,  the  un?tethered  technician  will  attempt  to  deliver  real  time  data of both position and speed, even though it clearly isn?t necessary. Such fatuous  pursuits by technicians result in expensive wireless infrastructures.  There are two key points here ?    1) The advanced traffic management systems being deployed in Europe, ERTMS, are  using GSM?R wireless with base  stations  as  close  as every 4Km so as  to  insure no  more  than  a  7second  lapse  in  transmitting  critical  information  to  keep  the  high  speed  trains  moving.   Such  an  approach  can  increase  the  cost  of  the  wireless  infrastructure  by  a  factor  of  10  compared  to  what  is  required  when  dealing  with  slower freight trains.    2)  A  number  of  years  ago,  I  contracted  an  Operations  Research  (applied  mathematics)  consultancy  to  determine  the  pragmatic  requirement  for  reporting  train  position  and  speed  in  a  fashion  capable  of  supporting  meet/pass  planners.   This  analysis  showed  the optimum  frequency  of  reporting  such  data  ranges  from  reports every 5 ? 15 minutes, depending upon the level of traffic. This is not real ­ time data, but rather in­time data; the difference is critical when deploying wireless  data infrastructure as well as the design of the back office systems that use the data.  With  in­time  data, dispatchers can foresee traffic conflicts and dynamically re?plan  train movements; a concept I refer to as Proactive Traffic Management (PTM) and  introduced to the industry 6 years ago.    In  addition  to  the  use  of  wireless  to  report  train  position  and  speed,  there  is  a  variety of positioning data that are being provided for singular activities, including  OS?s,  AEI  and  wayside  detection  reports.  Hence,  there  is  an  opportunity  to  merge  these  data  into  a  single  data  base/server  that  can  be  used  to  service  all  requiring  applications with improved timeliness and quality of data. Such capability would be  the function of a positioning engine that is a type of Kalman filter that maintains a  statistically rational tracking of trains based upon a continuously updated data base.  I know  of  only one  railroad  that  has  built,  reportedly,  such  a  strategic component  within their IT infrastructure.    Revving up a  positioning  engine  requires  a  succession  of  steps;  I  can  envision  the  following:  1.  Construct  a  locomotive  tracking  platform  by  integrating  AEI  reports  with  recurring  wireless  data  transmissions from the  locomotives;  2.  Incorporate a  locomotive?to?train  converter  to form a  train  tracking platform;  3.  Introduce  train  OS?s from CAD as well as the status of critical manual switches (e.g., dark territory  operation)  and  layer  on  train  routing  logic.  Voila!  You  have  an  IT  server  that  is  available  for  all  purposes  including  the  management  of  traffic,  crew,  track  gangs,  and  locomotives,  as  well  as  PTC.  This  is  an  enterprise  solution  that,  most  interestingly,  can  be  provided  outboard  and  independently  of  the  CAD  ?  CTC  infrastructure. This is a solution that can stand easily on its own merits without the  organizational, technical, and functional barriers that are normally confronted when  taking on changes to a railroad?s operations practices or its stoic IT infrastructure.    I am not suggesting that the above 3?step process to obtaining a positioning engine  is  particularly  easy.  But,  it  needs  to be done now given  that  the PTC mandate has  resulted  in  the  railroads  finally  working  together  to  develop  a  wireless  strategy,  albeit an overly complex and unnecessarily expensive one. Actually there are really  two  levels  of  positioning  engines  required.  The  first  level  is  required  by  each  railroad,  and  for  a  railroad  not  to  do  so  affects  only  that  particular  railroad.  The  second  level  of  positioning  engine  is  for  the  industry.  What  I  refer  to  as industry  intra­operability  is  a  strategic  platform  that  is  required  to  improve  the  advancement of all railroads. It is the ability to know where assets are regardless of  which  railroad  they  are  operating.  The  advantages  can  be  significant,  including  fueling,  maintenance,  and  traffic  management.  Industry  intra?operability  will  addressed in a separate posting.    Lastly,  positioning  data  is  only  as  good  as  the  reliability  and  accuracy  of  the  reference  points.   This  means  that  the  railroads  require  substantial  GIS  systems.   Fortunately,  that  seems  to  be  the  case  for  each  railroad  individually,  but  not  necessarily  from  an  industry  standpoint.   Furthermore,  the  GIS  platform  within  a  railroad needs to be enterprise level in concert with the positioning engine. That is,  the E?GIS platform needs to be common to all applications requiring such data, and  the data collection and modifications requirements need to be specifically assigned  to  individual  departments  with  no  overlap.  Simply  stated,  there  can  only  be  one  source  for  any  given  data  element ?  or ? a  version  of  the  positioning  gateway  is  required to blend multiple sources of the same data into one usable source. This is a  critical design point for safety systems such as PTC.    From: Warren Havens <warren.havens@sbcglobal.net> To: Shirley Thomas <SThomas@dart.org> Cc: jstobaugh@telesaurus.com Sent: Fri, November 12, 2010 12:39:45 AM Subject: Fw: 220 MHz Spectrum Acquisition Inquiry I amend here some language below, and forgot an item and added it this time. Also, I am sending this now since I will be mostly out today, Friday, and you asked for a response by today. While making a market, and any actual government contract RFP (as opposed to a information request) involve far more than a few days, we are happy to respond to the degree we can in that timeframe. I also add our GM, Jimmy Stobaugh to this email. Feel free to give him or me a call if you would like to discuss. Numbers are listed below my name below. ----- Forwarded Message ---- From: Warren Havens <warren.havens@sbcglobal.net> To: Shirley Thomas <SThomas@dart.org> Sent: Fri, November 12, 2010 12:22:27 AM Subject: Re: 220 MHz Spectrum Acquisition Inquiry Ms. Thomas. Our offer (for discussion purposes only, not an offer biding on acceptance) -- (A) No cost for spectrum in the lower ranges of what you seek if, in an assignment agreement: (1) DART represents, and we agree to certain terms, as to DART use the spectrum for a bona fide Intelligent Transportation Systems function or functions (PTC may fit this, at least genuine PTC, not PTC as a device for other purposes), (2) We get rights to certain non-cash consideration. That would not take much DART time or resources (and it may want to do this anyway since we and our experts would contribute value) and would be within what most experts in ITS at the higher levels find valuable to advance ITS for both your metro area and the nation. (B) On the same basis as A, we may assign 2x or more of LMS spectrum (in the FCC wide-area ITS radio service, Multilateration LMS). It is good for higher speed data to trains, especially in urban areas. A world class technology and equipment is available (actually, two), shown to work very well on trains up to very high speeds. This can be used along with the 200 MHz. It is a good idea to upgrade or build new wireless using sufficient spectrum for all of the voice and data applications needed. - - - - - That is what I can offer in a short deadline, and also that I have no problem being fully public. We will be making the same offer to other US metro railroads soon, and seek one or possible two who are interested at this time. I give you a two-day deadline (just kidding). Why we are interested in this and can make such offers is reflected in the documents, in the various ITS and Tech related Folders in the Scribd link below: the one below my closing name and list of companies below. I generally understand your comment on the public nature of (at leas some) documents held by DART, being a public agency. We have a consultant engaged in federal and state FOIA requests to obtain public records from government entities dealing with wireless, including railroads and PTC, and including in our lower 200 and lower 900 MHz bands. FRA is sending us the documents next week, it stated to me this week, and we hope to get docs from FTA soon, then from metro railroads including DART. - - - - - With regard to MCLM AMTS spectrum, Spectrum Bridge informed me that it will not inform parties it solicits to buy this spectrum of the legal claims against the spectrum and MCLM, at least not until some point: obviously, a contract has reps and warranties, and legal-proceeding claims have to be disclosed (to not be fraudulent). As for MCLM, the reason the FCC Enforcement Bureau (EB) stated that they are investigating MCLM and its owners, the Depriests, and the reason a half dozen major credits obtained court judgements still pending against them, includes that they misrepresent to get funds: that is shown over and over. It is all in easily accessible public documents. My point is that if you rely on Spectrum Bridge and MCLM for disclosures of claims against MCLM and its AMTS license that includes your area, you may not obtain full or accurate information. You can of course do your own due diligence. In this regard, claims against MCLM and this license are in part reflected on the FCC ULS system under this license. That should include at least two of the major proceedings. There is another person in our companies more fully aware than I am: if you have interest, I could have him give you details of this and above paragraph. But I believe that, in addition what is on US, there are the following cases involving our companies as plaintiff/ petitioners and MCLM as the main respondent which also effectively challenge the subject license (among other things): a case before the DC Circuit Court, one before the 9th Circuit Court, one before the FCC filed last month. The above-noted EB action is another proceeding (under Sections 308 and 312 of the Communications Act) that also may result in revocation of the subject license, and which I believe also is not reflected on ULS (except for mention in some of our pleadings). Proceedings noted in the following Internet link may also contain current claims to and against the subject license: http://www.scribd.com/doc/36514605/Donald-and-Sandra- Depriest-MCLM-Etc-FCC-courts-www. Since the document at that link was prepared some months ago, there have been a number of additional court cases and some judgements against MCLM and Depriests, the most recent for several million dollars by default: Depriest and his company did not appear at all, and could not be located for service. If his FCC licenses and licenses-based-companies were legitimate, he would and could defend him, it seems to me. Also see results by Googling: "scribd depriest mclm court" Because my companies were the lawful high bidders for the AMTS spectrum MCLM obtained in Auction 61 by disqualifying rule violations (we provide the facts and law on that in multiple proceedings indicated above, all public), we defend our claim when MCLM assigns any of that spectrum by challenges to that before the FCC. That is also clear in FCC proceedings. Spectrum that is not valid under law, cannot be laundered by assignment even if to an entity with clearly meritorious purposes who did not take part in wrongdoing underlying the invalidity. See FCC v. WOKO. 329 U.S. 223; 67 S. Ct. 213; 91 L. Ed. 204; 1946 U.S. LEXIS 3147 (1946), and In re Applications of Harry Wallerstein. 1 F.C.C.2d 91; 1965 FCC LEXIS 390; 5 Rad. Reg. 2d (P & F) 811. July 28, 1965. We believe that laundering itself is taking part in the wrongdoing where the facts of the wrongdoing and the applicable law are clear, as would be clear upon proper due diligence in FCC spectrum assignments by MCLM. Regards Warren Havens President Skybridge Spectrum Foundation V2G LLC Environmentel LLC Verde Systems LLC Telesaurus Holdings GB LLC Intelligent Transportation & Monitoring Wireless LLC Berkeley California www.scribd.com/warren_havens (for Skybridge) www.atliswireless.com www.tetra-us.us 510 841 2220 x 30 510 848 7797 -direct From: Shirley Thomas <SThomas@dart.org> To: warren.havens@sbcglobal.net Sent: Wed, November 10, 2010 2:05:05 PM Subject: 220 MHz Spectrum Acquisition Inquiry Mr. Havens, on behalf of Dallas Area Rapid Transit (DART), I am requesting that you provide DART with prices for the possible acquisition of the following amounts of AMTS spectrum for use throughout and up to the outer boundaries of Dallas, Tarrant, Collin and Denton Counties in Texas: 175 kHz 250 kHz 500 kHz 700 kHz 750 kHz 1MHz I understand that you require a non-disclosure agreement. As you may know, public entities like DART are required to maintain their records as public records. Although DART could agree not to voluntarily disclose information received from you, if copies of documents containing information of any sort are requested by a member of the public, DART would have to send those documents to the Texas Attorney General for a determination as to whether the documents have to be made public or whether an exception would allow the documents to be withheld. At the time such a letter is sent to the Attorney General, you would be notified that you have an opportunity to communicate directly with the Attorney General to present your reasons as to why the documents should be exempt from disclosure. Although I understand that there are issues that will require negotiation, DART is anxious to take an acquisition of 220 spectrum to its Board for approval in early December. Therefore, we are requesting that, if you are interested in selling this spectrum to DART, you provide me with firm prices for the above-listed spectrum no later than 5:00 p.m. Central Time on Friday, November 12, 2010. Thank you for your consideration. Shirley Thomas Senior Assistant General Counsel Dallas Area Rapid Transit P.O. Box 660163 1401 Pacific Avenue Dallas, Texas 75266-7255 214-749-3176 214-749-3660 fax Federal Railroad Administration Transportation Secretary LaHood Announces Recipients of New Railroad Safety Technology Grants U.S.Department of Transportation Office of Public Affairs Washington, D.C. www.dot.gov/affairs/briefing.htm News DOT Home About DOT DOT Jobs News Services FRA 21-10 Friday, November 19, 2010 Contact: Warren Flatau Tel.: 202-493-6024 U.S. Transportation Secretary Ray LaHood today announced that seven projects will share $50 million to help make the nation?s rail system safer by facilitating deployment of Positive Train Control (PTC) collision avoidance systems and other advanced technologies. The projects will receive money through the new Railroad Safety Technology Grant (RSTG) program. PTC systems use Global Positioning System (GPS) technology to monitor and control a train?s movements, in order to enforce speed limits, prevent train collisions and, help keep rail workers safe. Awards vary in size and scope ranging from $500,000 to $21 million, and include private corporations, academic institutions and public authorities. ?Safety is our highest priority,? said Secretary LaHood. ?This new program will help keep the rails safer by accelerating installation of positive train control technology where it is most needed.? The Federal Railroad Administration (FRA) received 41 grant applications requesting more than $228 million. Decisions on the competitively awarded grants were based on technical merit, including the extent to which a project helps achieve interoperability between technologies, and the recipient?s project management capabilities and financial commitment to share costs. Noting that all railroads will benefit from the work funded by the program, Federal Railroad Administrator Joseph C. Szabo said, ?We are funding projects that confer the greatest benefits to the entire railroad community.? Transportation Secretary LaHood Announces Recipients of Ne... http://www.fra.dot.gov/Pages/press-releases/228.shtml 1 of 3 12/8/10 5:12 PM FRA issued a Notice of Funding Availability on March 29, 2009 inviting applications from passenger and freight railroads, industry suppliers and state and local governments. Notably, the program requires that selected projects be ready for deployment within 24 months of receiving a grant award and that grantees share 20 percent of the total cost. Recipients must also have received FRA approval of a Technology Implementation Plan and PTC Implementation Plan, or successfully demonstrated that they could do so. The RSTG program was authorized by the Rail Safety Improvement Act of 2008 (RSIA), which imposed a statutory deadline of December 31, 2015 for PTC implementation on mainline tracks that carry passenger trains and certain hazardous material shipments. The selected projects are distinct and will help achieve resolution of technical challenges affecting all stakeholders. Grant awardees for the Fiscal Year 2010 RSGT Program are as follows: Grant Recipient and Location of work Project Title and Description Award Amount Southern California Regional Rail Authority (SCRRA) Shared LA PTC Communications Infrastructure: The project will develop and test the communications best practices guide for all railroads that must implement a standard Vital Train Management System (VTMS) which requires s an interoperable communication architecture that will allow trains to operate safely across railroad networks using the Los Angeles basin as the prototype. $6,605,446 National Railroad Passenger Corporation- (Amtrak) Washington, D.C. Advanced Civil Speed Enforcement System (ACSES) ? Vital Train Management System (VTMS) Interoperability: The project will focus on achieving interoperability between the PTC system used on Amtrak?s Northeast Corridor, known as ACSES, and the VTMS being adopted by freight railroads. $12,850,000 New York Metropolitan Transportation Authority (MTA) ? Long Island Advanced Civil Speed Enforcement System (ACSES) ? Interface Control Documentation: The MTA will develop and test the interface specifications (i.e. Interface Control $6,596,000 Transportation Secretary LaHood Announces Recipients of Ne... http://www.fra.dot.gov/Pages/press-releases/228.shtml 2 of 3 12/8/10 5:12 PM Railroad/Metro North Railroad, New York Document) for the major subsystems of the Amtrak Northeast Corridor ACSES PTC System. Meterocomm Communications Corporation- Renton, Washington 220 MHz PTC Radio HW Design Integration testing and Locomotive Noise Study: The project builds the required radio platform for an interoperable communications network across multiple railroads deploying the Vital Train Management System (VTMS) technology using a 220MHz radio frequency. $21,050,000 Howard University- Washington, D.C. PTC System Identity Management: The project will develop performance models for cryptographic key management required to ensure safe and secure interoperable PTC system communication. $857,106 Railroad Research Foundation- Washington, D.C. Rail Corridor Risk Management: The project will enhance and provide ongoing implementation of the Rail Corridor Risk Management System (RCRMS) as a key enabling technology for the industry in accomplishing the objectives of the Rail Safety Improvement Act of 2008. $1,541,448 Westinghouse Airbrake Corporation- Cedar Rapids, Iowa Video PTC Database Survey Verification: The project will prove the ability to use ordinary video currently collected in a locomotive run through a subdivision to validate PTC Survey location points. $500,000 #### Transportation Secretary LaHood Announces Recipients of Ne... http://www.fra.dot.gov/Pages/press-releases/228.shtml 3 of 3 12/8/10 5:12 PM