-1-
State of California / Public Utilities CommissionSan Francisco
M E M O R A N D U M
Date:May 24, 2018
To:The Commission
(Commission Meeting May 31, 2018)
From:Elizaveta I. Malashenko, Director, SED, CPUC
Roger N. Clugston, Dep. Director, Office of Rail Safety
Amy C. Yip-Kikugawa, Asst. General Counsel
Paul King, Retired Annuitant, CPUC
Patrick S. Berdge, Principal Counsel
Subject:Federal Railroad Administration’s Request for Information on Automation in the Railroad Industry, Docket No. FRA-2018-0027[1]
RECOMMENDATION: The California Public Utilities Commission (“CPUC”) should file comments in response to the Request for Information (“RFI”) concerning the future of automation in the railroad industry, issued by the Federal Railroad Administration (“FRA”) on March 29, 2018. Public comments should be received by May 7, 2018.[2]
BACKGROUND: The FRA is interested in hearing from industry stakeholders, the public, local and State governments, and any other interested parties on the potential benefits, costs, risks, and challenges to implementing automated railroad operations. The FRA intends to support the integration and implementation of new automation technologies to increase the safety, reliability, and the capacity of the nation's railroad system.
The FRA recognizes that there are varying levels of automation that already are, or could potentially be, implemented in the railroad industry. Railroads are presently implementing statutorily mandated positive train control technology (a processor- based/communications-based train control system) to prevent train accidents by automatically controlling train speeds and movements if a train operator fails to take appropriate action in certain operational scenarios. The FRA also seeks to understand how the rail industry's plans for future automation may affect other stakeholders, including railroad employees, the traveling public and freight shipping industry, railroad industry suppliers and equipment manufacturers, communities through which railroads operate, local and state governments with roles in regulating highway-rail grade crossing safety, and any other interested parties.
The FRA poses 25 questions in its request for information and data.
PROPOSED COMMENTS: The Safety and Enforcement Division (“SED”) seeks the Commission’s approval of comments addressing the following positions and concerns.
Automation of the railroad industry has been ongoing since the inception of the industry. It is a critical and essential part of railroad transportation both freight and passenger. The development of Positive Train Control (“PTC”) is one example of this evolutionary and necessary automation in the railroad industry. The delayed implementation of PTC by the nation’s Class I railroads demonstrates the complexity and difficulty in developing safe and sound automation in the industry. The next evolutionary stage in the railroad industry’s automation must carefully build on PTC to ensure that all developments in automation are safely implemented and compliant with all safety requirements. In that light, the CPUC recommends that the FRA ensure that any advancements in the railroad industry’s automation not be confused with the development of autonomous motor vehicles. The CPUC cautions that the state of automation in the U.S. railroad industry is not at a stage that would safely permit consideration of plans for the operation of automation-aided and autonomous trains over the nation’s general railroad system of transportation.
AUTOMATION IN THE RAILROAD INDUSTRY REQUIRES SPECIAL ATTENTION TO SAFETY
Safety is paramount in the railroad industry and any improvements in automation must demonstrate compliance with all applicable and appropriate safety and reliability concerns. PTC provides revolutionary, as well as evolutionary, improvements to railroad safety. It will provide similar benefits and improvements to more efficient railroad operations.
USE OF PTC-ACQUIRED DATA AND EXPERIENCE TO DEVELOP RAILROAD AUTOMATION
For the foreseeable future, the bulk of automation in the railroad industry will be the result of the large amounts of data produced by the implementation and development of
PTC.[3] The benefits of Global Positioning System (“GPS”) data will provide a basis for substantial improvements in:
•velocity,
•routing,
•line capacity,
•service reliability,
• more efficient use of cars and locomotives,
• safer and more efficient windows for track maintenance, and
• fuel savings[4]
SPECIALCONSIDERATIONSIN THE IMPLEMENTATION OF AUTOMATIONINTHERAILROADINDUSTRY
A critical concern is that software failures in cars, on roads, in live traffic, can be more catastrophic than software failures on a personal computer on a desk.” The concern is that train accidents can be far more catastrophic than car accidents, given the large numbers of passengers and volumes of hazardous materials trains carry. SED’s comments address the following variables.
•Benefits
•Security
•Designed-in error (“Design error or flaw”)
•Levels of automation and the different problems of each level
•Automation Bias
•Automation-induced complacency
•Training needed for human-automation interaction
•Characteristics of optimal human-automation systems
•New accident report fields
•Close call reporting
•Socio-technical context
CONCERNS RAISED BY PUBLIC AND PRIVATE HIGHWAY-RAIL CROSSINGS
•It would be helpful to develop automated rail taxonomy.
•Additional sensors or technologies are required in automation-aided and autonomous trains to detect and react, especially when nearing stations and highway-rail crossings.
•Railroad trains should be able to recognize stations, highway-rail crossings and, on the railroad right-of-way, the existence of a pedestrian, vehicle, or other object, and be able to stop before a collision occurs.
•Railroad automation will require additional funds from the federal government for grade separations. Additionally, the FRA should mandate that fully automated trains operate only over exclusive right-of-ways.
•Adequate testing of cyber protections against interference with automation technology is essential.
•The railroads must work with Federal, State, and local regulatory bodies for the proper implementation of the new technology.
•Coordination between state and local governmental agencies concerning the safety of railroad operations at public and private at-grade highway-rail crossings is imperative.
•The use of automation-aided and autonomous trains may help eliminate certain human errors such as those involving fatigue, complacency, outside distractions, etc. At the same time, train personnel may not be properly attentive because of over-dependence on automated systems when approaching a dangerous condition at a public or private crossing. Train personal must always be aware of situations that may require special alertness. They must always be able to react quickly to dangerous circumstances.
CONCLUSION: Because of the important safety implications of automation-aided and autonomous trains and the Commission’s role in overseeing railroad safety under California statutes and the CPUC/FRA Rail State Participation Program Agreement,[5]SED recommends filing these comments.
215520627
[1]See the FRA’s RFI, 83 Fed. Reg. 12646 (March 29, 2018).
[2]The Safety and Enforcement Division filed a very brief set of comments on May 7, 2018, as a placeholder for a full set of comments to be considered at the Commission’s May 31, 2018 Conference.
[3]TRAIN, April 10, 2018, “BNSF Railway Executive Chairman Matt Rose says Tuesday his company hopes to extract efficiencies out of positive train control implementation, but added that he is not about eliminating crews from cabs.”
[4] See: Positive Train Control (PTC): Calculating Benefits and Costs of a New Railroad Control Technology, July 30, 2004, ZETA-TECH Associates.
[5]49 C.F.R. § 212 et seq.