The impact of the proposed third track through the Town of Ashland can be organized into the following three categories:
- Cultural — including the loss of historic buildings and sites; and
We are publishing a series of posts outlining concerns to do with all three areas. Posts to date include:
This is the second post in the Cultural series (although it could also be considered to be a safety topic).
I have worked as a professional engineer on large projects for much of my career. Hence I am familiar as to how such projects are organized and managed. In particular, as a result of my book-writing activities, I have a reasonable grasp as to how engineering standards are developed and implemented. However my experience has been in the process industries (oil refineries, chemical plants, offshore oil and gas platforms). This HSR Project is, of course, to do with a different industry: railways. Therefore I request that anyone who has worked on the design or construction of a railroad expansion project such as this to critique the work that I have done and correct any errors or false assumptions.
Basis of Design
It is normal for project managers to create a document that summarizes the technical and engineering standards that they will be following for their project . They have to follow legal requirements, of course — of that there is no choice. But there is generally some flexibility as to which industry standards and practices are to be adopted. With regard to this proposed project the project team has published a 105 page document entitled the Basis of Design (BOD), dated February 24, 2015 (DRPT 2015).
Shown below is the first page of the BOD’s Table of Contents.
The design engineers must follow the standards that are provided in the BOD. Only in rare circumstances can the design engineers claim an exemption.
Development of Design Standards
For background it is useful to to understand how engineering codes and standards are developed and applied.
The Regulatory Process
In the United States, the federal regulatory process starts when both Houses of Congress develop a law or statute. Generally, each House develops its own version. These are then sent to committee, where a compromise bill is agreed upon. This, in turn, goes to the President, who signs it (unless he chooses to use his power of veto). Once a statute becomes law, the affected agencies, such as the Federal Railroad Administration (FRA) in this case, develop specific regulations. It is the regulations, not the law itself, that companies are expected to follow. (The words “regulation” and “rule” are used synonymously in this post.)
Once the regulation has been written it is listed in the Code of Federal Regulations (CFR) and indexed in the Federal Register. The public and other interested parties are invited to comment on this draft regulation. Following the implementation of a standard, the agency can modify it through Letters of Interpretation. If a person or organization disagrees with some part of the regulation, they can challenge it in court on the grounds that it does not meet the intent of the original Congressional statute. If the court agrees, the standard is implicitly changed.
This whole process is illustrated in the sketch below.
Rules and regulations generally do not provide sufficient detail for engineers to make detailed design decisions. Therefore all industries have standards-setting bodies that develop detailed guidance. For example, AREMA (the American Railway Engineering and Maintenance-of-Way Association) published the 2016 Manual for Railway Engineering, Chapter 5 of which contains a Recommended Practice entitled Track (AREMA 2016) and which is probably the most relevant to these discussions.
Usually these engineering standards are not a formal legal requirement unless they are adopted into a regulation by reference. However, even when they are not legally required, failure to follow them is hard to justify.
On page 18 of her book Ashland, Ashland Rosanne Shalf describes the history of the railroad in Ashland.
Workers laid the first twenty miles of single track to the Hanover site in 1836 . . . Workers began to lay double lines of track along the route in 1903.
The first engineering standards in the United States were developed in the early years of the 20th century with an initial focus on boiler explosions. The newly formed American Society of Mechanical Engineers (ASME), for example, published its first first boiler code in the year 1914. This means, therefore, that when the existing Ashland tracks were installed it is very unlikely that the engineers at the time had to worry about code to do with spacing requirements between the tracks and adjacent pedestrians and buildings. And, as the picture at the head of this post shows, there simply wasn’t the density of building and road traffic in the town as we have now.
Any project that involves upgrading an existing facility will likely face the challenge of “grandfathering” old designs. Standards generally become more stringent over time. But it is not practical to re-engineer an existing facility every time a new version of a standard is published. So it is normal for the facility to be “grandfathered”, i.e., it can remain “as is” and does not need to meet the latest code. An example in day-to-day life is to do with backup cameras on automobiles. It is likely that future rules will require that they be installed on all new cars but that old cars will not need to have them retrofitted.
In industry this concept of grandfathering only holds if the original facility is not significantly modified. If large changes are made then it is likely that the entire system will have to be upgraded to meet the latest standards. Adding a third track to two existing tracks constitutes a huge change. Hence I assume that the entire system will need to be upgraded to 2016 standards and to meet the requirements of the BOD for spacing between the tracks and pedestrians and buildings.
Minimum Separation Distances
Chapter 3 of the BOD — “Highway” — appears to be the most pertinent to this discussion, particularly Section 3.3.6, which is entitled “Pedestrians/Bike Paths/Trails”. Page 3-4 provides an inactive link to a document entitled Vtrans Pedestrian and Bicycle Facility Planning and Design Manual that presumably provides more detail. (I was unable to open the link or to locate the document on the internet.) The recommended minimum separation distances are provided in Figure 3-1, which is reproduced below.
No matter how detailed the rules and standards may be there are always gray areas that require interpretation and the application of professional judgement. For example, Page 3-5 of the BOD shows three types of rail operation.
A normal first response would be to put the town of Ashland into the first category:
“11 trains or more per day. Max Speed over 45 mph”.
But trains are not allowed to travel at 45 mph through town, so maybe the town does not fall into that category. It is not clear if the standard means,
. . . per day or Max Speed . . .
. . . per day and Max Speed . . .
Judgment is called for (or else the project engineering manager reviewed this document with an insufficiently sharp pencil).
There is currently a discussion going on to do with a “Minor Upgrade” to the tracks through Ashland. (This option was removed from a recent Board of Supervisors motion.) No definition has been provided for the word “minor”, thus making the whole discussion rather vague. However, it may not be that all that important. Based on the the information in this post it is likely that any upgrade that can materially affect the capacity of the railroad will be large enough to obviate the existing exemption from code. Hence it is probable that,
All minor upgrades are actually major upgrades
Hence even a “minor” upgrade will lead to destruction of historic homes and businesses and will be enormously costly.
All engineering projects have to meet a plethora of codes and standards. In order to fully understand the impact of this proposed project on the town of Ashland we need to identify which of those codes apply. Based on the preliminary analysis provided here the following early conclusions are reached.
- The existing tracks were installed when there was little or nothing in the way of construction codes and standards.
- Adding a third track through the center of town means that the existing tracks would have to be upgraded to meet current code.
- The spacing required for this upgrade would be substantial and the impact on the town would be greater than previously anticipated.
This post started with a request. If anyone can provide insights regarding the engineering or construction of railroad tracks please let me know. In particular, I invite professional comments to do with the engineering discussions and assumptions that this post has initiated.
Next week we will probably glance at the topic of Cognitive Dissonance.
American Railway Engineering and Maintenance-of-Way Association (AREMA). 2016 Manual for Railway Engineering. 2016.
Shalf, Roseanne Groat. Ashland, Ashland. Brunswick Publishing Corporation. 1994.
Virginia Department of Rail and Public Transportation (DRPT). Basis of Design. Technical Criteria for Concept & Preliminary Engineering. Final Report. February 24, 2015.