June 18, 2024
Mr. Karl Alexy
Associate Administrator for Railroad Safety & Chief Safety Officer
Federal Railroad Administration
1200 New Jersey Avenue SE
Washington DC, 20590
RE: Amtrak Petition for Waiver of Compliance, Shunt Enhancer Equipment
Docket No. FRA-2023-0095
Dear Mr. Alexy:
On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s (FRA) notice regarding Amtrak’s petition for a waiver of compliance from the provisions of 49 CFR 229.71, Clearance above top of rail, to implement locomotive-mounted shunt enhancer equipment. TTD consists of 37 affiliated unions, including those representing the totality of rail labor, and we respectfully request that the FRA take our input on this matter into consideration.[1] Additionally, TTD notes that our affiliates, the Brotherhood of Railroad Signalmen (BRS) and the Brotherhood of Locomotive Engineers (BLET), have filed comments in response to this waiver request. We encourage the FRA to extend due consideration to the views expressed therein.
As stated in the petition, Amtrak seeks to install shunt enhancer antennas on its fleet of Siemens Charger SF4 locomotives. This equipment is designed to improve shunting of railroad track circuits and reduce the potential for a loss of shunt (LoS) incident. Amtrak explains that under conditions of worn wheels and dynamic profiles, the mechanical and electrical hardware of the truck-mounted antenna devices could protrude below 2.5 inches from the top of rail, which necessitates a waiver.
LoS within a track circuit is a significant safety concern as it can exacerbate the risk of train-to-train collisions and crossing accidents. Factors including the number of axles in a train, train speed, wheel profile, and weather, in addition to locomotive weight and contaminants on the wheel or rail can contribute to LoS.
Amtrak makes note of its participation in the industry-led LoS Committee, which is supported by the FRA. It should be noted, however, that as far as TTD is aware labor organizations have not been invited to participate in this committee. According to the petition, the shunt enhancer antenna has been identified, tested, and recommended by the LoS Committee. The LoS Committee confirmed that the shunt enhancer antenna “reliably demonstrate[s] improvement of a vehicle’s interaction with the wayside track circuits.” Based on the information included in the petition itself, it is unclear whether the addition of this equipment will make a meaningful difference in preventing LoS incidents. We recognize that this equipment may in fact be beneficial, but respectfully request that prior to granting the requested waiver, the FRA require Amtrak to submit additional information and data supporting the claims asserted. Stakeholders, the public, and the FRA must have the information necessary to fully and accurately assess the merits of this request. Unfortunately, the petition as originally submitted is insufficient.
Additionally, we request that the FRA require, as a condition of approval, Amtrak to conduct a root cause analysis following any LoS incident and to establish a reporting procedure for employees witnessing or experiencing a LoS event following the installation of the equipment. These reports should include Positive Train Control (PTC) implications, track conditions, geography, and note any variations specific to the host railroad. Labor union representatives must also be given the opportunity to participate in this process. The final reports must be fully transparent and available to the public to ensure stakeholders are able to evaluate the performance of the technology and monitor for any emerging safety concerns.
TTD does not stand in opposition to this waiver, but we request that the FRA require additional due diligence on the part of Amtrak prior to granting its petition. We appreciate the opportunity to comment on this docket and look forward to working with the FRA in the future.
Sincerely,
Greg Regan
President
[1] Attached is a complete list of the unions affiliated with TTD.