I'm confused by many of the documents the MBTA has filed on the FRA web-site:
First off, MBTA PTC Implementation Project Plan v8.0 of August 2016 says I-ETMS PTC will be co-located with ACSES II PTC on the Freight Mainline. There is much discussion of I-ETMS v. ACSES II back office integration and rolling stock interoperability (plus a reference to a "Springfield Terminal PTC-IP" [Implementation Plan] which can't be found on the FRA PTC docs website https://www.fra.dot.gov/Page/P0628
. Here's the URL to the downloadable 245 page MBTA PTC IP v8.0: https://www.regulations.gov/document?D= ... -0030-0031
But the next version of MBTA PTC IP (ie, v9.0) removes all references to I-ETMS implementation tasks/goals/deliverables and FRA responds with a 2 page set of comments/question including:
The list of tenant railroads includes NS. While FRA is aware of Amtrak, P&W, Pan-Am, and CSX locomotives being equipped with ACSES II, this is the first PTCIP that states that the I-ETMS system will not be utilized on MBTA territory. Please confirm that NS locomotives will be properly equipped to operate on MBTA territory.
In its v10 PTC IP, MBTA downplayed its listing of NS as a tenant RR of the MBTA but FRA disapproved v10 in March 2017 due to:
1. The RFA [Request for Amendment] does not address the removal of the Interoperable Electronic Train Management System PTC installation on MBTA North side territories, which are indicated in the PTCIP by strike out only.
2. The RFA, makes no mention of MBT A tenant operations over Pan Am Southern territory between Fitchburg and Wachusett, MA, nor does it address how MBTA trains are to traverse said territory. These tenant operations began October 2016 and increased to 13 round trips per day in December 2016.
In May 2017, MBTA submitted v11 of its PTC IP which indicates PTC on the Fitchburg from Westminster east will be implemented with ACSES II. Furthermore, in the Interoperability section lists NS as a tenant RR but then says:
MBTA is actively working with each tenant railroad to ensure that all rolling stock operated on MBTA North Side territory will be equipped with onboard ACSES II in ABS Mode with 220
MHz radio systems by the extended 2018 deadline. Once MBTA’s PTC System is fully implemented, no non-ACSES equipped locomotives will be permitted into either its ATC with ACSES II South Side territory or on ACSES II in ABS Mode North Side territory. In its effort to ensure interoperability, MBTA will “cap” any non-ACSES equipped train entering MBTA territories with a MBTA ACSES equipped locomotive. Please refer to the PTC Implementation Plans for Amtrak, CSX and NS for their rolling stock fleet PTC characteristics.
In August 2017, FRA approved MBTA PT IP v11. And last month, FRA approved MBTA's request for "substitute criteria" to permit MBTA to defer PTC revenue operation to no later than December 31, 2020 conditioned on "...MBTA shall complete formal field qualification testing2(FQT) of its Advanced Civil Speed Enforcement System II (ACSES II) on its Stoughton Branch from Milepost (MP) 15.0 to MP 19.6 by December 31, 2018,..."
Lastly note that in its Q2 2018 PTC Progress Report, NS indicates that none of its locomotives will have "non I-ETMS Transponder Readers" installed.
Net: I'm very confused re: what the FRA officially believes is happening wrt to Fitchburg line PTC installation. Taking the most recent on-file FRA approved MBTA plans, it would appear that "In its effort to ensure interoperability, MBTA will “cap” any non-ACSES equipped train entering MBTA territories with a MBTA ACSES equipped locomotive"! Or alternatively, the FRA web-site filings reflecting the latest implementation plans are out-of-date.