U.S. Deportment of Transportation
1120 Vermont Ave., N.W.
Federal Railroad Administration
Washington, D.C. 20590
SEP 9 2005
Mr. Richard F. Timmons
President
American Short Line and Regional Railroad Association
50 F Street, NW, Suite 7020
Washington, D.C. 20001
Mr. Edward R. Hamberger
President
Association of American Railroads
50 F Street, NW
Washington, DC 20001
Dear Sirs:
By letter dated September 2, 2003, the Senate Committee on Commerce, Science,
and Transportation (Committee) requested that the Federal Railroad
Administration (FRA) conduct an audit of "the railroads' use of remote control
locomotives (RCLs) and the effect of further implementation of this technology."
The letter goes on to say that
[t]he audit should include an assessment of the impact of RCLs on safety, including a comparison of the rate of accidents, injuries, and fatalities involving RCLs with similar operations involving manned locomotives. Additionally, the audit should assess the effects of remote control operations on the safety of highway rail grade crossings, hazardous materials transportation, the safety of remote control locomotives operated in urban areas, any unique operating characteristics presented by RCLs, and an assessment of the safety benefits of such operations. The report should include any recommendations for legislative or regulatory changes FRA determines necessary. We request that FRA report back to the Committee with preliminary findings and initial accident statistics within 6 months, and that a detailed final report is submitted within 18 months.
We are writing to advise you that this audit and an associated review have
resulted in two determinations that are of immediate interest to your members.
Both relate to the use of RCL technology in main line train movements. The first
concerns the suitability of the technology in the context of non-incidental main
line train movements and gives rise to specific recommendations. These
recommendations supplement FRA's Safety Advisory 2001-1 (Advisory). The second
determination has to do with the adequacy of training providing RCL operators
engaged in non-incidental main line movements and will be addressed with
individual railroads in context of review of their programs of training subject
to approval under 49 CFR Part 240.
In May 2004, FRA submitted the required interim report to Congress. Preliminary
data prepared for that report indicated that the safety record of RCL operations
over the seven-month period May 1, 2003, through November 30, 2003, had been
positive. However, the report listed four items that were left open pending
further review. One of those items was an operating practices issue entitled,
"RCL operations outside of yard switching operations." Interim Report at 9-10.
In the interim report, FRA explained that the Advisory was intended to address
RCL use in yard switching operations and how we were surprised to learn that
railroads had some RCL operations on main tracks. Most of the RCL main track
movements were found to be "incidental" as they were short switching movements,
with limited numbers of cars and the remote control operators (RCO) were
appropriately trained.
Now that we have had an additional year to study the issue, we continue to
believe that these incidental main track movements by RCLs are generally safe,
and we will not object to them unless we identify a specific safety concern.
Likewise, an additional year of monitoring and evaluating the non-incidental
movements by RCLs over main track has reaffirmed our initial concerns that,
given the limitations of RCL technology, non-incidental movements over main
track by RCLs can pose an unacceptable safety risk and thus should be strictly
limited. Further, it appears that RCO training provided to date is not
sufficient to support non-incidental main line operations.
The primary problem with the current state of the RCL technology is that it is
inadequate to control in-train forces during heavy-haul operations; similarly,
we are concerned that the way to operate the RCL over the main track, and its
variously graded conditions, without pulling the train apart, may require
manipulating the remote control device in a way that is counter-intuitive to the
way it was designed to be used. With regard to training, we have concluded that
the typical 80 hours of RCO training that is specified in each railroad's
locomotive engineer certification program is inadequate to prepare an RCO for
operating an RCL over main track; to conclude otherwise, would permit the absurd
situation of allowing an RCO to perform all the same operations as a train
service locomotive engineer, just with different equipment and significantly
less training. The inadequacy of the current technology and training is further
explained below.
Technology
After becoming familiar with the current RCL technology, FRA realized
the current systems in use by the major railroads have limitations when used
outside the yard environment. For example, FRA's initial concern was that the
current technology might not be suitable to control in-train forces during train
movements. The speed control feature on the remote control transmitter
(beltpack) was originally designed for yard switching operations. The speed
control works like an automobile's cruise control. A speed is selected, and the
computer will increase locomotive power until the desired speed is reached. The
computer will then automatically maintain the selected speed using locomotive
power and brakes.
When used for switching, i.e., limited number of cars on a yard-switching lead
track with limited horsepower, the system works well. The system is designed to
accelerate quickly to facilitate switching cars into classification tracks. When
this system is used to haul trains, however, the speed control feature must be
circumvented at times to control in-train forces. When starting a train, the
computer begins the movement slowly for approximately five to ten seconds, then
rapidly applies more horsepower in short intervals to gain the desired speed.
The computer is not programmed or designed to make train-handling decisions,
i.e., to take into account the number of cars and tonnage that are in the train
being moved or the topography of the track over which the train is operating.
Consequently, the computer will attempt to start the train too quickly. If
locomotive power is not applied gradually, excessive in-train forces could be
generated. FRA has observed that some RCOs compensate for this feature by
setting the speed control to the coast position (reduces pulling forces)
periodically as the train is being started. If the locomotive's rapid
acceleration rate is left unchanged, the train may separate due to excessive
in-train forces. Separation is likely if the locomotive consist is capable of
developing high tractive effort. The system has little ability to apply
locomotive power in a gradual, conventional manner, as it was designed for rapid
acceleration.
Another area of concern involves the RCL braking system, which is also primarily
designed for yard switching movements. All locomotives are equipped with two air
brake systems: the locomotive or independent air brake (which controls the air
brakes on only the locomotive) and the automatic train air brake (which controls
the air brakes on both the locomotive and the cars in the train). As the name
implies, the independent air brake operates the locomotive brakes independently
of the automatic air brakes. Light locomotive and switching movements are
primarily controlled by the independent air brake, whereas trains are primarily
controlled by the automatic air brake. The onboard computer controls a movements
initially by using the independent air brake. The system is designed to react to
speed changes within plus or minus 0.5 miles per hour (mph) of the current speed
selection. For example, if the speed control is set at 7 mph, the brakes will
apply once the speed exceeds 7.5 mph and will release once the speed drops below
7.5 mph. Conversely, if the speed drops 0.5 mph below the set speed, the
computer will direct the locomotive to increase power to maintain the selected
speed, which will cause slack action in the train. Since plus or minus
fluctuations in speeds greater than 0.5 mph often occur as trains move over the
main track, the independent air brake will constantly apply and release, or
locomotive power will increase or decrease, causing the train slack to run in
and out as the train progresses. The longer and heavier the train, the more
dramatic this slack action becomes. While the system is suitable for switching
operations, it does not work well during train movements. Depending on
locomotive horsepower, train size, and train makeup, excessive slack action in
the train could cause a derailment due to excessive in-train forces.
RCOs have the ability to use the automatic air brake to a limited degree,
depending on software modifications to the system. The RCL automatic air brake
system was originally designed to supplement the locomotive air brakes when
stopping heavy drafts of cars in yards. If the locomotive air brake is fully
applied and more braking effort is needed to control speed, the speed control
feature will make an additional predetermined brake application with the
automatic brake. (The automatic air brake system, can be used only if the cars
being handled have the air hoses coupled between them and the cars are charged
with air). Once the movement slows to the selected speed, the brakes are
released. Again, this system works well when handling heavy drafts of cars from
one track to another in the yard. This function is not desirable when
controlling longer trains on the main track because the computer works faster
than the train air brake system. For example, under certain track profiles
(short downhill, uphill track configurations), the system could apply and
release the brakes before the brakes fully apply on the rear of a long train.
This would create a situation where the brakes would be releasing on the head
end of the train at the same time they are applying on the rear end. This
condition could cause excessive in-train forces.
After considering all the information above, FRA believes that, given sufficient
training, an RCO could develop the skills to operate small trains on the main
track over flat terrain for limited distances. However, given all the variables
that exist (e.g., train tonnage, train length, locomotive horsepower, track
terrain), proper train handling could prove difficult for larger trains over
greater distances.
FRA does not believe that further modification of RCL technology could overcome
these limitations while providing a level of safety equal to that of
conventional operations on the main line. FRA is concerned that—under the best
of circumstance—signal latency between the beltpack and the RCL would introduce
an additional, and unnecessary, element of delay between initiation and
execution of commands by the operator. The delay, when giving commands to the
RCL, may interfere with train handling calculations and decisions, and that is
one reason why FRA has taken a conservative view of the acceptable train length
this current RCL equipment should handle. Moreover, the "fail-safe" feature that
acts to stop the locomotive, when command signal interference ("No Com") is
experienced, denies the RCO adequate control over the train movement. For
example, there have been incidents in yards where the RCL suddenly stopped
because of communication failure and caused a section of the cars being handled
to break away. In one instance these cars rolled into the side of a train,
causing a derailment. To have such occurrences on high-speed main tracks could
prove catastrophic. FRA recognizes that penalty brake applications can and do
occur to engineers during conventional main track operations. However, the
engineers have the ability to immediately respond to these situations with
considerably more controls than those afforded to RCOs. Importantly, there is no
sound reason to introduce additional causes of undesired air brake applications.
FRA Review of Training Programs
All the major railroad RCL training programs provide a minimum of two weeks of
training for railroad employees with no previous experience operating a
locomotive. The two-week training period takes into account that the trainees
are former conductors with significant railroad experience. Approximately two to
three days are spent in the classroom, with the remainder of the time spent in
the field as on-the-job training. RCOs receive little additional training in air
brakes, train handling, signal recognition, track-train dynamics, etc. These are
all subjects associated with the fundamentals of main track operations,
regardless of speed or distance. Starting or stopping a train at low speeds is
normally the time that in-train forces can be the greatest. Extreme care must be
taken during these times. Yard transfer and local freight work also expose RCOs
to a large number of signal aspects and configurations found in multi-terminal
areas. RCOs should be as knowledgeable in these subject areas as conventional
engineers. Consequently, FRA believes that RCOs should receive additional
training if they operate on main tracks.
In FRA's interim report to Congress, FRA recognized how the major railroads
defined the duties of an RCO in the programs filed with FRA and noted that these
programs, as understood by FRA, did not contemplate extensive movements on main
track. Interim Report at 4. In hindsight, it is clear that some railroads take a
broader view of the description of RCO duties, and it is therefore appropriate
to review their locomotive engineer training programs to determine that required
competencies are being addressed.
Accordingly, FRA will, as necessary, reopen review of railroad RCO training
programs where it is clear that the railroad is committed to non-incidental main
line movements. In initiating this review, FRA will apply the following
criteria:
1. RCOs should be required to have the same or the
equivalent level of classroom training as that provided for conventional train
service engineers on each railroad. Examples of necessary training will likely
include railroad safety and operating rules; switchman, trainman, and conductor
duties and responsibilities; engineer duties and responsibilities (RCO); and, in
many areas, the physical characteristics of multiple-terminal transfer routes.
2. Regarding on-the-job training (OJT), each RCO should have a minimum of 120
hours of actual, documented hands-on operating experience. (Note: FRA is willing
to consider a railroad's amended program that credits previously worked hours
for those RCOs who have worked main track assignments prior to the
implementation of the minimum OJT training requirement). As with all training,
railroads should remain flexible and provide more than the minimum of OJT
training when necessary; e.g., if the track profile is difficult or the distance
poses specific issues, OJT training should be increased on a case-by-case basis.
Although this review will include an opportunity for the railroad to suggest
modifications of these criteria as applied to their specific circumstances, FRA
will expect substantial improvements to existing RCO training programs where
non-incidental main line operations are contemplated.
Recommended Restrictions on Non-Incidental Main Line Movements
In a similar vein to our published minimum guidelines in the Advisory,
FRA recommends the following course of action for those railroads that
voluntarily choose to conduct RCL operations outside of yard switching
operations. In recognition of the existing and inherent technological
limitations discussed in this letter, FRA strongly suggests that each railroad
should establish standard operating procedures that limit RCL movements outside
of yard switching operations. At a minimum, we recommend that the following
limitations should apply to all RCL movements requiring brake tests under 49
CFR. Part 232:
a. Locomotive consist should not exceed 3000
horsepower, utilizing no more than eight (8) axles.
b. Train length should not exceed 1000 feet (approximately 20 car lengths).
c. Train speed should not exceed 15 mph.
d. Operations should be prohibited on any grade of 0.5 percent or greater that
extends for more than V4 of a mile.
FRA notes that, while these criteria have the status of recommendations and
as such are subject to discussion and adaptation, it will be necessary to
determine that reasonable limits are being set in practice or FRA will have to
take more definitive action.
In summary, FRA has concluded that RCL technology has limited application to
main track operations. It is clear that current RCL systems and training
programs are designed for yard switching operations and that enhanced training
must be provided where non-incidental main line operations are contemplated.
Even where RCOs are properly trained and qualified for main line operations, FRA
recommends that railroads adopt operational restrictions that reflect the
inherent limitations of a system configured for yard operations that rely upon
radio-frequency transmission of safety-critical commands.
Because of the importance of this issue to the railroad industry, FRA would
appreciate it if you could disseminate the contents of this letter to your
member railroads. Your consideration of this matter is greatly appreciated.
/s/ Daniel C. Smith
Associate Administrator for Safety