The New York Times is one of the world's great newspapers, with an enviable reputation and impressive history. Therefore, when they miss the mark - especially in such a profound way - it tends to hurt.
Earlier this week, the Times printed an editorial entitled "Don't Bargain With Rail Safety," outlining the publication's unilateral support of the Positive Train Control concept. It's full of misconception, innuendo and baseless imputation, and indicates a thorough lack of understanding regarding railroading, business operations and the political process.
The Times apparently believes any request to delay implementation of P.T.C. must be based on greed ("groups [such as the A.A.R.] contend the costs outweigh the benefits"), partisan politics ("House Republicans, ever determined to do [the railroad] industries' bidding, have taken up their cause") and ignorance of the facts (since railway executives "question the availability of equipment").
While I acknowledge the temptation for mass media to ride the "robber baron" express, this all still seems a bit outrageous.
In many aspects of life, especially within the political world, there are actions which are taken for but one primary reason: the deep-seated fear of appearing impotent.
If a simple problem requires simple attention, then a bona fide emergency or horrific incident of some sort demands an almost immediate response. The last thing politicos want is to be labeled as someone who fails to do something, even if it later ends up being the wrong thing.
If the inevitable reaction involves spending large sums of money, especially if the cash belongs to someone else (or at least the taxpayer, presuming that's not the same thing), it's even better. We've seen it time and again.
In response to the Chatsworth, California Metrolink collision of 12 September '08, a new piece of legislation was quickly ushered through Congress by the Senate Commerce and House Transportation and Infrastructure Committees. The Rail Safety Improvement Act of 2008, which (among many other things) mandates installation of Positive Train Control technologies, was signed into law by President George W. Bush on October the 16th: just 34 days after the incident which spawned it and over 15 months prior to the release of the N.T.S.B.'s official report regarding the incident.
Admittedly, the A.A.R. issued a statement in support of the bill prior to its passage. Still, how can we expect our industry's emissary go on record as supporting anything but "safety first" (after all, the railroads coined that expression) and standing unified against the loss of life?
The phrase which just crossed my mind is "under duress."
Only days after the Metrolink/UP crash, then F.R.A. Administrator (and current Amtrak President) Joseph H. Boardman told reporters that "[P.T.C.] would have stopped the [passenger] train before there was a collision." A locomotive Engineer willing to take his job seriously and respect the lives and equipment entrusted to his care "would have stopped...before there was a collision," too; but, we won't go there.
The N.T.S.B. soon followed with a statement indicating P.T.C. (or a similar system) "would have prevented this accident." With all due respect to the Safety Board, this remark seems far less prescient when one remembers P.T.C. had already been on the N.T.S.B.'s Most Wanted List of Transportation Safety Improvements for years.
In all this, the fact that P.T.C., even now, does not exist as an off-the-shelf technology seems lost to those standing on the outside, bloviating. Its multi-billion dollar price tag is apparently meaningless.
Of course, there must also be piles of cash available for lawsuits. It took but three days after the Chatsworth incident for the first claims to be filed. Bolstered by the previously mentioned remarks, attorneys began alleging that Metrolink "chose not to use the available rail safety features" which, in context, seemingly referred to P.T.C.
Naturally, there are other, older systems (electro-mechanical by design) such as Automatic Train Stop and various forms of cab signaling which have been successfully used for generations. Interestingly, several U.S. passenger carriers began to make public statements shortly after the Metrolink event intended to reassure both the general public and their customers regarding the relative safety of their operations. Every one of the systems outlined either indicated their reliance on time-proven technologies and/or operational standards, or emphasized various forms of temporal separation (which, in all honesty, may only mean that passenger train collisions would never involve freight trains).
One of the nice things about A.T.S. and cab signals (along with other forms of Automatic Train Control) is that those systems can overlay existing signaling and communication devices. Many of the technologies now in place have been successfully used since the 1920s. Britain's own Great Western Railway developed the very first automatic safety control system in 1906.
Admittedly, an incremental approach to P.T.C. - the only sort which could possibly meet the fed's arbitrary deadline - would also overlay existing systems, with wayside components ("interface units") being used to dovetail individual signals, switches, detectors and the like into a new digital network. In turn, that data link would connect specific pieces of equipment (such as locomotives and hi-rail vehicles) and voice communications services with the other devices, so that every vital ingredient was included.
Most major railroads have studied the concept of P.T.C., under many different names and (sometimes quite forced) acronyms, for decades. It should be noted that, from the start, our industry - including the Brotherhoods - has remained dedicated to the basic notion of automatic train control safety devices and, along with the F.R.A., the N.T.S.B. and Congress, stands in agreement with today's stated goals for P.T.C. Those objectives include preventing several types of dangerous events: collisions between trains, overspeed operations, movement through misaligned switches and incursion into properly established work zones. [Issues regarding switches and speed control (or the lack thereof) regularly make the top ten in the F.R.A.'s annual safety analysis lists.]
At present, there are 11 ongoing projects, involving 9 different systems and 6 manufacturers. Thankfully, the four major players - NS, UP, BNSF and CSX - hammered out a cooperative agreement back in late '08, understanding what's ultimately at stake. Several individual approaches to P.T.C. are in the works, but all those under the purview of the four Class Is previously mentioned are being designed to maintain interoperability by way of Wabtec's Electronic Train Management System.
This is important since P.T.C., no matter how it ultimately evolves, should essentially be universal in scope - for the same reasons developments like standard gauge and rolling stock brake and coupler appliances have been so important.
Therefore, our question for the day: what's a justifiable alternative to the legislated time schedule as it now exists?
Well, I suppose the simple answer would be to approach this matter from a completely new perspective. Instead of knee-jerk politics creating a mandate for change, allow the industry to use this as an opportunity: a chance to make a technological leap into the future.
Right now, what's in it for the railroads? As it currently stands, P.T.C. is yet another example of an unfunded mandate - nothing more. We're insisting that the capital needs for presumed public benefits be covered with private money. To meet the bare minimum requirements will only give us a fancy (and expensive) train control system, similar to what was in development more than a century ago. Moreover, a fair estimate for the cost of base-line P.T.C. overlay is 1.2 million dollars per mile of high-density main line track. Washington needs to move away from the idea that spending large sums of money tends to do anything but consume large sums of money.
Yes, saving innocent lives is crucial! No one argues with that. Still, if we were never allowed to do anything which posed even the slightest risk of danger, we'd never accomplish anything at all!
Give our industry time to establish goals, develop standards and set priorities. P.T.C., properly handled, could lead to a great, systemic change for North American railroading, similar in its own way to dieselisation. It must be noted, however, that the switch from steam to diesel-electric power occurred over a 30-sum-odd year period and - get this - was due to the railroads' own decisions, goals and investments. No governmental edicts were involved. The industry was also able to make this change gradually over time and at its own pace; no absolute deadlines were established. Finally, diesels promised something for the coffers immediately; there was an initial financial incentive. I've seen the figures: steam locomotives offered better tractive effort at speed. Apart from that, things like maintenance costs and the inability to operate multiple units with one engine crew sealed their fate.
So, what might be in it for the railroads if they get P.T.C. right the first time 'round?
How about significant increases in equipment utilization, employee productivity, energy efficiency, scheduling ability and, above all, safety? How about dramatically improved customer service? How about eliminating the causes of incidents instead of just the incidents themselves?
Out here in the real world, the best solutions involve answers to actual problems. Those solutions are not magic, nor do they often stem from a singular epiphany, but come about through necessity, trial and error, and scientific research.
Those solutions also can't be legislated into existence.
It seems pretty simple, doesn't it?
oamundsen: You make excellent points. As for texting while driving a train, it is more than dumb engineers who put us all at risk. If you can do so without distracting yourself, take a look at how many motorists who share the road with you are babbling away on their cell phones and/or texting while driving. The late engneer at Chatsworth is only worth the attention he still gets because he took 25 other souls with him. Every survey I've seen finds there is a universal response: yes, texting and distracted driving are really bad; and no, I'm a good driver and am not distracted when I do it.
The National Association of Railroad Passengers agrees that December 31, 2015, is not a feasible PTC deadline. We support Senate-passed language that would let the Secretary of Transportation grant up to three one-year extensions for cause, on a company-by-company basis. We oppose the industry’s preferred, blanket, five-year extension in the bill passed by the House Transportation and Infrastructure Committee.
We also agree with the industry that it makes sense to start implementation of PTC in less complex areas rather than in, say, Chicago, although we understand that railroads in southern California have a specific commitment to begin early there.
But we think the industry should use any legislated time extension in part to rectify a serious flaw in PTC implementation, whether or not FRA amends its rule to require such a correction. The rule currently does not require the PTC system to know where the end of train is (or train weight). Thus, as the National Transportation Safety Board noted in its report on the BNSF rear-end collision near Red Oak, Iowa, the system which is being installed (which we have dubbed “PTC-Lite”) will not prevent restricted-speed, rear-end collisions. At Red Oak, two engine crew in the following coal train were asleep and died when they rear-ended another train.
More generally, we are concerned about what the industry has done and not done in the 22 years since the National Transportation Safety Board put PTC on its first most-wanted list after Burlington Northern’s successful demonstration of an early version of PTC. Some of the functionality that was to be included with PTC has been achieved independently, or allegedly so, with the result that the industry now characterizes PTC as a costly, stand-alone, unfunded mandate. Hence the difference between earlier and current cost-benefit analyses. Hence also an inefficient use of radio spectrum.
As Grady Cothen wrote, “Piecemeal implementation of technology to address discrete needs has advantages in all fields of endeavor, including administrative simplicity, rapidity, and lower risk. But unifying the operation of components and subsystems at higher levels can avoid duplication and deliver synergistic affects . As a system is strained to capacity, and as unit costs rise in relation to revenues, it becomes more important that synergies be realized.” Cothen, a Cheverly, MD, consultant, was until just under two years ago the longtime Deputy Associate Federal Railroad Administrator for Safety. This quote is from his paper, “Integration of Railway Electronic Systems to Achieve Safety and Efficiency,” in the proceedings of the April 2012 Joint Rail Conference in Philadelphia.
ARailroaderWhoRemembersThings wrote “What if the railroad had been double track? (That was the system of safety improvement favored by the Commodore Vanderbilt some 175 years ago.)” PTC-preventable collisions occur on single-track, double-track, and triple-track lines. And it would be grossly uneconomic to install a second (or third) main track without bidirectional signaling on all main tracks. Thus, while multiple tracks could reduce the possibility of a head-on collision, depending on common operating practices, it would not eliminate that possibility. Moreover, multiple tracks would only marginally reduce the possibility of a rear-end collision.
Larry Kaufman wrote, “The current PTC mandate requires radio frequency that does not yet exist and probably will not exist before the 2015 deadline. That is not a function of railroad recalcitrance, but of the limitations of technology.” But the jury is out on the railroads’ decision to use 220 mh for PTC while continuing to monopolize and manage their underutilized 160 mh frequencies. The railroad industry apparently has yet to narrowband its 160 mh frequencies – that is, to use 364 channels in the same amount of spectrum where it currently has 91. From 1996, radios were required to have narrowband capability. Starting next January 1, the FCC will sanction operators who have not narrowbanded.
The State of Maine, noticing how underutilized 160 is, wants to use it for public service. Maine told the FCC: . "...AAR has indicated it would oppose any request to coordinate these frequencies for public safety use...Maine contends that its proposed use of railroad frequencies would have no significant impact on future frequency availability for railroads in or near Maine because the state currently has 'very limited railroad service within its borders and none of the large (Class I) railroads currently operate track within the State."
For more critical commentary, see my lengthy column in our February 2012 newsletter, available to NARP members on-line and to others request to me. HarverK400 is on target.
Thanks for commentary and reply. To make all this much easier, can we agree to avoid re-visiting the policy question of how highway funding should be done? It is a distraction, and not very productive...
In now more decades that I care to be reminded, I have followed various credible studies on all of it. Conclusions fit to three slots: Some noting commercial use doesn't carry its weight. Some noting the burdens are too much. And, finally, the bulk of it declaring it is just about right. So, who knows?
Besides, were tax loads on commercial traffic increased, so go the prices at retail stores everywhere. Would it make a difference to those rail carriers, which also rely heavily on owned or dedicated highway services? In many cases, the entities own their own trucks!
Anyway, the thread here involves PTC. There is excellent comment and observation here already. So, little to add, other than it may be a credible idea on very heavily run segments of rail. With lesser volumes, there is a point where it is all trade offs?
I believe the time has come for me correct some myths that have been stated about PTC by well-meaning folks on this message board. Here goes:
Myth #1: “The Rail Safety Improvement Act of 2008, which (among many other things) mandates installation of Positive Train Control technologies, was signed into law by President George W. Bush on October the 16th: just 34 days after the incident which spawned it and over 15 months prior to the release of the N.T.S.B.'s official report regarding the incident.”
Fact: The Rail Safety Improvement Act (H.R. 2095) was introduced in Congress by Congressman James Oberstar on May 1, 2007, exactly 500 days before the Chatsworth collision occurred. When the bill was introduced, it included the provision mandating PTC implementation on lines carrying passenger trains and PIH and TIH hazardous materials. The implementation date was specified as December 31, 2014.
During those 500 days, Senate and House subcommittees and committees approved the bill, and it also passed in a bipartisan floor vote (377-38) in the House of Representatives on October 17, 2007, and passed by unanimous consent in the Senate on September 1, 2008, 11 days before Chatsworth. As of the date of the Chatsworth collision, September 12, 2008, all that needed to be done was to convene a conference committee of members of both the Senate and House to reconcile differences in the Senate and House versions of the bill.
In the days immediately following Chatsworth, that is exactly what happened. The conference committee met and the Senate members agreed to the House version of the bill that has been amended to set a PTC implementation date of December 31, 2015. On October 1, 2008, 19 days after the collision, the Senate approved this version of the bill by a bipartisan vote of 74 - 24. President George W. Bush signed the bill into law on October 16, 2008. You can confirm this information by going to the Library of Congress web site: thomas.loc.gov/.../z .
It is also worth noting that several CEO’s of the major railroads had been in Washington, DC, earlier in the week of the Chatsworth collision to meet with Members of Congress and their staffs to: (1) inform them that they had agreed to adopt an interoperable PTC standard, (2) inform them that they were planning to implement PTC, and (3) seek financial assistance in the form of investment tax credits for their PTC projects. I know this because one of the CEOs told me.
I believe that it is quite likely that, in the days immediately following the Chatsworth collision, Members of Congress and their staffs figured that the least harmful thing they could do to the railroads, and yet still make it look like Congress was doing something useful, would be to mandate the railroads to do something they said they were already planning on doing, i.e., implement PTC. However, because of the Wall Street “train wreck” that occurred on September 15, 2008, 3 days after Chatsworth, and the financial disaster that followed, the possibility of railroads getting financial assistance for PTC disappeared.
Myth #2: “In all this, the fact that P.T.C., even now, does not exist as an off-the-shelf technology seems lost to those standing on the outside, bloviating.”
Fact: Twenty years ago, the ARES PTC system was available essentially off-the-shelf. In 1992, Burlington Northern Chairman Gerald Grinstein stated, “We designed ARES in the 1980’s and have tested it for more than two years on Burlington Northern’s line serving the Mesabi Iron Range. The system is now ready for implementation.” [NB: ARES was tested for 5 years, from 1987 through 1992, on 17 locomotives, 2 high-rail vehicles, and 230 miles of track. It worked. ARES was integrated with precision dispatching, AEI train consist information, UMLER car length data, locomotive health reporting of the status of dynamic brakes and air brakes, work order reporting system, and track forces terminals.]
Several months after a fatal collision near Kelso, WA, of BN and UP freight trains on BN track on September 13, 1993, the two railroads issued a request for proposal for PTC on the their lines in the Pacific Northwest. Rockwell International, the developer and system integrator of the ARES PTC system, submitted a proposal to implement in that territory an integrated, vital, non-overlay, “off-the-shelf” ARES system, the same as had been tested on the Mesabi Iron Range. The UP, however, convinced BN that they should contract with GE-Harris to design and develop a non-vital overlay system called Positive Train Separation, or PTS. Unfortunately, the GE-Harris PTS system failed both in the Pacific Northwest and on the Alaska Railroad, and the concept was abandoned.
In the late 1990’s, Rockwell International decided to leave the surface transportation electronics business for both railroads and roads and stay with avionics. It sold its Railway Electronics business unit and the ARES PTC technology to Wabtec. Even though Wabtec maintained the capability to produce an integrated, vital, non-overlay PTC system, they decided to offer what their railroad customers desired, and that was a non-vital overlay PTC system that became known as the Enhanced Train Management System, or ETMS. A consultant to FRA who examined the software of the various PTC systems over the years, noted that ETMS still used quite a bit of the ARES software.
Myth #3: “The cost-benefit study of the current PTC mandate was conducted by the FRA and was based solely on the parameters of the legislation. It found a cost of about 22 times the benefit; clearly not something that any capitalist would undertake…”
Fact: In its PTC Final Rule, FRA included the capital costs ($5 billion for the US railroads), operations and maintenance costs ($5 to 8 billion, representing the net present value of 20 years of O&M), and safety benefits. For reasons I do not know, FRA elected to not include business benefits in the numbers presented in the PTC Final Rule. All parties concerned – railroads, unions, suppliers, FRA, and NTSB – have long agreed that safety benefits alone could not justify the investment in PTC.
Too many people add together the capital costs if PTC and the net present value of 20 years of O&M, getting $10 to $13 billion for the cost of PTC. This distorts and inflates the cost picture for PTC, compared with other benefit-cost analyses. If the same approach were used elsewhere, the cost of a new road locomotive would be $12 million instead of $2.5 million, and the cost of a new Ford Fusion would be $120,000 instead of $25,000. It is important that people are consistent on whether they are using capital costs or total costs including O&M in their benefit-cost analysis comparisons.
FRA published a report in 2004 with a business benefits analysis that showed a rate of return of 144% for an investment in an integrated, vital, non-overlay PTC system. In 2010, Oliver Wyman, Inc. published a report for the AAR showing that railroads would obtain virtually no business benefits as they implement a non-integrated, non-vital, overlay PTC system. I believe that both reports are correct; the business benefits are dependent on the type of PTC system implemented. I tend to believe that railroads executives, board members, and financiers would normally prefer to see PTC implemented to maximize business benefits.
Many railroads, and some officials at FRA, believe that only safety benefits can be used to justify an FRA regulation. However, Executive Order 12866, “Regulatory Planning and Review,” dated September 30, 1993, states; “Further, in choosing among alternative regulatory approaches, agencies should select those approaches that maximize net benefits (including potential economic, environmental, public health and safety, and other advantages; distributive impacts; and equity), unless a statute requires another regulatory approach.” You can confirm this by going to the National Archives web site at: www.archives.gov/federal-register/executive-orders/pdf/12866.pdf.
Myth #4: FRA requires railroads to implement non-vital overlay PTC systems.
Fact: FRA’s PTC Final Rule is a performance-based rule, not a design-based rule. A railroad must submit to FRA a PTC Implementation Plan that describes the configuration of the PTC system they plan to implement. They must also present an analysis showing how that system will prevent collisions and overspeed accidents, as specified in the rule. If FRA, upon review of the implementation plan and safety analysis, concurs with it, FRA will then instruct the railroad to implement the PTC system described in the implementation plan. If that system is a non-vital overlay PTC system, that is what the railroad must then implement; if the system is an integrated, vital, non-overlay PTC system, that is what the railroad must then implement.
Non-vital overlay PTC systems cost more to implement (because they require PTC to tie into every intermediate signal) and provide fewer business benefits (because they continue to operate on block occupancy, relay-based logic) than do vital, non-overlay systems which operate on a different paradigm using the continuous, real-time position and speed information generated by the GPS receivers on locomotives and maintenance vehicles.
Ron Lindsey, in his PTC article in the April 2012 issue of Railway Age makes an interesting point: “Regrettably, the technicians that are handling the extensive complexities of delivering an interoperable PTC solution are neither charged with, nor have they been provided with, the necessary management directives and the proper resources to address both the tactical and strategic perspectives. Specifically, the railroads’ technicians have significantly expanded the technical issues of PTC, and therefore the capital investment, beyond what is required, and they have done so without the necessary strategic perspective that could perhaps justify their activities.
Myth #5: FRA requires the adoption of 220 MHz radio frequencies for mobile radios for PTC, or, if FRA does not, the architecture of ETMS requires the adoption of 220 MHz radio frequencies for mobile radios for PTC.
Fact: As a result of tests over the past 25 years, railroads have concluded that VHF radio frequencies work best for the digital mobile communications that are an integral part of PTC. Both 160 MHz and 220 MHz are options in the VHF band.
The four major railroads concluded that there would be difficulties in converting their existing 160 MHz frequencies that are used now for analog voice communications to digital data communications. As a result, they created a jointly owned company called PTC220, LLC to acquire 220 MHz radio frequencies on the open market before it became widely know that railroads were interested in these frequencies. It now appears that they did not acquire sufficient 220 MHz radio frequencies for all the US railroads, and as a result the current owners of 220 MHz radio frequencies are charging significantly more for them, causing problems especially for commuter railroads, but also for large and mid-size freight railroads.
The big four freight railroads also jointly acquired another company named Meteorcomm, LLC, to design digital radios for the 220 MHz frequencies for PTC. There were no other suitable radios commercially available for the 220 MHz frequencies.
Ron Lindsey makes some interesting points in his Railway Age article regarding the issue of 160 vs. 220 MHz radio frequencies: “PTC-220 LLC, the industry’s entity responsible for PTC wireless, has not clearly defined the wireless data and coverage requirements. And yet, PTC-220 designated a new 220 MHz band for PTC for which they acquired some spectrum and have been seeking even additional spectrum—a request that has been rejected by the FCC due to PTC-220’s inability to justify the additional requirement.
“PTC-220’s intent is to install a wireless network in parallel with other bands already owned by the railroads that they rejected on an all-or-nothing basis—what I have referred to as the “Chicago Syndrome”—for the past two decades. That is, if a technology can’t handle the complexity of the multi-railroad Chicago operations, then it shouldn’t be used elsewhere. Or, with the counterpart relative to trunking, if a technology is used in Chicago, then it has to be used everywhere. This myopic mindset has too often been a constraint in advancing technologies in the freight rail industry.
“What PTC-220 has done is forgo the ability to blend various bands selectively (as provided for by the onboard PTC platform) in a synergistic fashion even though several Class I’s are doing exactly that. Arguably, the most appropriate and cost-effective choice would be the 160-161 MHz band that is currently being upgraded from an analog platform to a digital one to effectively comply by 2013 with an FCC mandate. Unfortunately, however, for this migration the railroads are deploying a conventional digital platform with assigned channels instead of a trunked radio approach that dynamically assigns channels as requested. Hence, what has not been considered by PTC-220 is that the significant increase in efficiency of the trunked approach may have permitted the 160 MHz band to handle PTC’s requirements without building the parallel 220 MHz network. If not a trunked 160 MHz band alone, then the railroads’ other bands at 44 MHz and 900 MHz for wayside-to-office communications could be included, as well as commercial cellular and even wired code-line infrastructure. Again, several Class I’s are doing exactly that in spite of PTC-220’s arguments to the FCC that the 220 MHz band is the one and only solution.”
If anyone is interested in receiving copies of the FRA PTC Business Benefits Report, the Oliver Wyman, Inc. report on PTC business benefits for the AAR, the ARES Safety Analysis which describes its architecture in some detail, or any other material on ARES, please send me an email at firstname.lastname@example.org.
As one who has contributed to some of the mythology that Steve Ditmeyer discusses, I only can say he has done a masterful job of discussing this important issue dispassionately. Having known and worked with Steve for more than 40 years, I can assure one and all that he is passionate on the subject of PTC.
Many thanks Steve for clearing up those myths!
I just realized that I contributed to a 6th myth about PTC, and that I need to correct it, Here it is:
Myth #6: The railroads were given no financial assistance by the federal government to implement PTC.
Fact: It is true that the Rail Safety Improvement Act of 2008 did not provide either grants or investment tax credits to railroads to help them implement PTC. However, the Federal Railroad Administration administers the Railroad Rehabilitation and Improvement Financing (RRIF) Program that provides low-cost loans and attractive repayment schedules to railroads for a variety of investments, including train control systems. Up till now, only short line railroads have taken advantage of the RRIF program, and indeed FRA is required to hold a portion of the funds for disbursement to short lines only, but the funds are available to the Class I railroads also if they elect to utilize them.
When Congress passed the Federal Aviation Administration’s reauthorization in February 2012, they included a provision to establish a financial assistance program “for the purpose of equipping general aviation and commercial aircraft with communications, surveillance, navigation, and other avionics equipment as determined by the Secretary to be in the interest of achieving NextGen capabilities for such aircraft.” I was informed by a former Under Secretary of the US Department of Transportation that this provision was based on FRA’s RRIF program.
Thanks, Steve, for your diligence and devotion to accuracy. My recollection is that RRIF originally was for short lines only and Class 1 eligibility was added some years later. I seem to recall that the program originally had an authorization of $3.5 billion, and when it was increased to $35 billion, Class 1s were made eligible.
If anyone has better information, please keep us myth-makers on the straight and narrow.
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