Comment from Persistence Analytics Group LLC

Comment on FRA-2010-0031 Long Island Rail Road Request to Amend Positive Train Control System Persistence Analytics Group LLC / United Grid submits this comment regarding the Long Island Rail Road request for amendment to its FRA-certified Positive Train Control Safety Plan for the Advanced Civil Speed Enforcement System II. PAG / United Grid does not oppose necessary modernization of rail signal, train-control, or interlocking infrastructure. However, any temporary outage affecting a certified safety-critical system should be approved only with clear implementation controls, named accountability, restoration verification, and post-implementation review. The key issue is not only whether the Queens interlocking modifications are necessary. The key issue is whether the assumptions behind the temporary ACSES II outage are transparent, testable, and accountable before the outage proceeds. FRA should require or confirm the following before approval: 1. Clear outage scope and duration The affected territory, outage window, operating limits, and extension conditions should be clearly identified. 2. Safety-equivalent operating controls Where ACSES II functionality is temporarily unavailable, substitute procedures should provide a documented safety basis, including speed enforcement, dispatcher controls, crew instructions, signal protections, and escalation protocols. 3. Named risk ownership LIRR should identify who owns each operational risk during the outage, including dispatch, train crews, signal personnel, contractors, field supervision, emergency coordination, and restoration authority. 4. Contingency triggers The approval should include triggers for pausing work, reducing operations, restoring protections, or escalating oversight if construction, signal integration, weather, communication, equipment, or operating assumptions fail. 5. Written communication and training Affected personnel should receive written instructions before the outage begins. Safety-critical execution should not rely on informal coordination. 6. Restoration testing Before returning the territory to normal operation, LIRR should complete documented testing and validation of ACSES II functionality, signal additions, interlocking modifications, and related operating rules. 7. Public accountability Because Positive Train Control is safety-critical infrastructure, FRA’s approval record should clearly state why the outage is necessary, how safety will be maintained, and what evidence will confirm successful restoration. 8. Post-implementation review After completion, LIRR should submit a short post-implementation report identifying whether the work was completed as planned, whether any safety or operational issues occurred, whether outage assumptions held, and what corrective actions were required. The broader principle is simple: Safety-critical infrastructure modifications should not proceed only on the assumption that temporary controls will perform as expected. They should proceed with verified outage controls, named risk owners, decision gates, restoration testing, and post-implementation accountability. FRA should approve the amendment only if it is satisfied that the temporary outage can be implemented safely, transparently, and with decision-grade evidence before, during, and after the modification. Respectfully submitted, Neil P. Osnato Founder Persistence Analytics Group LLC | United Grid National Security & Infrastructure Risk Analytics Demand Durability | Grid Stress | Load Integrity SAM.gov registered UEI: D3VYU39H6DX9 D-U-N-S: 142849930 CAGE: 19T34 neil@persistenceanalyticsgroup.com 609-464-9055 https://persistenceanalyticsgroup.com/