RAIL TRANSIT STATE SAFETY OVERSIGHT (SSO) PROGRAM 2019 ANNUAL PROGRAM STATUS REPORT
Calendar Year 2019 As of December 31, 2019
ODOT SSO 2019 Program Status Report
Introduction
This 2019 Annual Program Status Report highlights activities and accomplishments from the Ohio Department of Transportation (ODOT) Rail Transit State Safety Oversight (SSO) program, focused on calendar year 2019. This annual report is required by the Federal Transit Administration (FTA) SSO Rule, 49 Code of Federal Regulations (CFR) Part 674.13(a)(7):
At least once a year, the SSOA [state safety oversight agency] reports the status of the safety of each rail fixed guideway public transportation system to the Governor, the FTA, and the board of directors, or equivalent entity, of the rail fixed guideway public transportation system.
The Ohio rail transit agencies (RTAs) included in this SSO program are the Greater Cleveland Regional Transit Authority (GCRTA) – heavy and light rail systems, and the City of Cincinnati and Southwest Ohio Regional Transit Authority (SORTA) – the Cincinnati Bell Connector streetcar system.
In Ohio, the designated state safety oversight agency (SSOA) is the ODOT Office of Transit. This office provides financial and technical assistance to public transit systems, local governments, and human service agencies throughout the state for the planning, establishment, and operation of those public transit systems. The ODOT SSO program has provided safety oversight for GCRTA since the beginning of the program (1996) and now for the Cincinnati Bell Connector Streetcar since 2012.
FTA’s New Safety Program Updates
The SSO program regulation (49 CFR Part 674) became effective April 15, 2016 and each of the 31 state programs was required to be Certified by FTA as compliant within three years or by April 15, 2019. The Ohio SSO program was the first state Certified in August 2017. The last three SSO programs were Certified in February and March 2019 prior to the deadline. If any of the state programs had not been Certified by the deadline, FTA would have been required to discontinue all transit grant funding for that state until the program was Certified.
The Public Transportation Agency Safety Plan (PTASP) regulation (49 CFR Part 673) was finalized in July 2018 with a requirement that all applicable transit agencies be required to complete development of their Agency Safety Plans and all approvals (Accountable Executive approval, Board of Directors or equivalent approval, and SSO program approval, if an RTA) no later than July 20, 2020. FTA started providing a significant number of guidance documents starting with their SSO Program Workshop in Washington, DC during September 2019. At about the same time, FTA added their PTASP Technical Assistance Center website making these guidance documents available and the ability to contact FTA for review and guidance of PTASP documents being developed. FTA also completed several webinars that are also available on the website.
• https://www.transit.dot.gov/PTASP-TAC
The ODOT SSO program has worked with both Ohio RTAs to assure that their PTASPs are in development and making progress towards the deadline. The GCRTA PTASP was completed and approved in early 2020. The Cincinnati Streetcar PTASP has been developed and approved as an interim PTASP awaiting required approvals prior to the regulatory deadline.
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ODOT SSO Program Standard Update
The ODOT SSO Program Standard was updated to Version 5.0 with all signatures completed in February 2019 and then a minor update in December 2019 based on discussions during the FTA audit (http://www.dot.state.oh.us/Divisions/Planning/Transit/Pages/RailSafety.aspx). The February 2019 set of updates was focused on changes based on being Certified to the new SSO regulation (49 CFR Part 674). The December 2019 update was focused on a minor change in Section 8. Corrective Action Plans (CAPs). Another full version update is planned in 2020 to add the PTASP and safety management system (SMS) requirements based on guidance now available from FTA on their PTASP TAC website.
FTA Audit of the ODOT SSO Program
The ODOT SSO program was notified via letter by the FTA on October 18, 2019 of an upcoming three- year or triennial audit, with the on-site activities planned for December 17-19, 2019. As part of the letter, a number of documents and records were requested to be provided within 20 business days, and this was completed on time. The on-site portion of this audit was completed with one day in Columbus at ODOT and a day and a half in Cleveland at GCRTA. The next steps for this activity include receiving the draft audit report for comment and then the final report. After the final report, any findings and recommendations are to be developed into corrective actions for approval by FTA. This is expected to be completed in early to mid-2020.
Greater Cleveland Regional Transit Authority (GCRTA)
The ODOT SSO program provides safety oversight for the GCRTA (www.riderta.com) heavy and light rail systems shown in Figure 1, which include 37 miles of double track and catenary power system. Figure 1 also shows GCRTA’s three bus rapid transit (BRT) lines, but the bus operations are not a part of the SSO program. Figure 2 shows one of the light rail vehicles in Tower City.
Significant changes in management at GCRTA have occurred in 2019. The long-time Chief Executive Officer retired and left the organization. In addition, the Safety Director left and was replaced with the long-time Safety Manager. The current safety program related management staff are the following:
• Ms. India Birdsong, General Manager and CEO (Accountable Executive) • Dr. Floun’say Caver, Chief Operating Officer, and Interim Secretary-Treasurer • Ms. Sheryl King Benford, General Counsel, Deputy General Manager, Legal Affairs and Chief Safety Officer • Mr. Anthony Garofoli, Executive Director, Internal Audit • Mr. Michael Schipper, Deputy General Manager, Engineering & Project Management • Mr. Steven Peganoff, Director, Safety • Mr. Sean Thompson, Director, Rail District • Chief John Joyce, Transit Police • Mr. Anthony Richardson, Acting Director Service Quality
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Figure 1. GCRTA Heavy and Light Rail Systems
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Figure 2. Light Rail System in Tower City
Communications with GCRTA occur daily with email or phone calls, usually with the Safety Department. GCRTA provides monthly status reports for all investigations, internal audits, and corrective actions. In addition, the ODOT SSO program and GCRTA have quarterly meetings at GCRTA with executive and department management staff to go over status of corrective actions and to share presentations about current safety related activities for the ODOT SSO program. Quarterly meetings for 2019 occurred on January 23rd, April 4th, August 9th, and October 24th. Along with ODOT SSO program staff, Mr. Peganoff attended the FTA joint State Safety Oversight and Rail Transit Agency Workshop in Washington D.C. on September 23-26, 2019.
GCRTA and the ODOT SSO program have actively worked together completing investigations and internal audits, using these as an opportunity to enhance safety capabilities related to the rail systems. As shown in Figure 3, the number of reportable event investigations over the last thirteen years have been steady at an average of 15 per year, except in 2017 and 2018. The ODOT SSO program has started to require additional, less severe, safety events that were already being investigated to also be included in the ODOT SSO program. Note the significant increase of ODOT reportable events starting in 2012 is a part of the new requirements for the enhanced SSO program. It is our position that the focus and attention on the less severe safety events has driven down the number of the more severe/significant safety events.
With the Certification of the ODOT SSO program in August 2017, the FTA reportable safety event criteria and thresholds changed in calendar year 2018 to the new SSO Rule.
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30
25
20
15
10
5
0 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019
FTA Reportable ODOT Reportable
Figure 3. Number of FTA and ODOT Required Investigations by Year
The ODOT SSO program assigns GCRTA to complete these investigations, and the ODOT SSO program adopts and approves all the investigations and corrective action plans (CAPs). The ODOT SSO program staff carefully and independently review the investigations (the new regulation includes requirements for a review for sufficiency, thoroughness, and agreement with findings of causation) and CAPs to assess whether or not all of the causes and contributing factors for the events were fully investigated and appropriately mitigated/controlled. Any changes needed are discussed and negotiated between the ODOT SSO program and GCRTA staff. During 2019, the ODOT SSO program added a more formal process of responding to CAP closure evidence through a form/record of acceptance of the CAP closure evidence.
Figure 4 shows all CAPs from investigations, internal audits, and ODOT SSO program Triennial Reviews at GCRTA during the thirteen-year period. All of these CAPs have been approved by and included in the ODOT SSO program. The CAPs represent action items to improve safety performance on the rail system including training, additional maintenance, or adding new/improving existing capabilities. Over the thirteen-year period, the number of total CAPs averages 125 CAPs per year, except for the much lower number of CAPs in 2017 and 2018.
GCRTA’s internal audits are coordinated with the ODOT SSO program and GCRTA’s Safety and Internal Audit Departments. Each year, approximately one-third of the system safety program plan (SSPP) elements and system security plan (SSP) sections are audited in order to cover the entire safety program over a three-year period, as required. For each internal audit, the ODOT SSO program is included for review of the audit plan both for information and in case the ODOT SSO program staff decide to participate in those internal audits. Several meetings during the year are completed with Safety and the Internal Audit Departments to accomplish this coordination and inclusion in the ODOT SSO program.
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120
100
80
60
40
20
0 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019
Investigations Audits
Figure 4. Number of Corrective Actions for Investigations and Audits by Year
The ODOT SSO program and GCRTA have been working together to ensure that safety certification training is being planned and completed for both organizations. The ODOT SSO program developed an FTA-required Safety Certification Training Plan (current version is Rev 7 dated February 2019, included in the program standard as Appendix C) to manage the required safety training activities. In addition, the GCRTA Training Department has developed an awareness training curriculum for the ODOT SSO program Technical Training Plan. Training for the current ODOT SSO Program Manager was completed in July 2019 and included shadowing multiple rail maintenance groups in the field. The entire SSO program group completed additional field training in September 2019 covering power outage procedures (in the work zone and at the substation), rail tie replacement equipment and process, and a walk-through of the Brookpark Yard and Shop. In addition, the GCRTA Safety Department staff have also been active in completing their required FTA Safety Certification Training.
Highlights from GCRTA Rail in 2019. Calendar year 2019 was busy for GCRTA. A few highlights are mentioned here, including for all of GCRTA and some for just the Rail related departments.
• The GCRTA Board of Trustees approved the 2020 Public Transportation Agency Safety Plan February 18, 2020 and the ODOT SSO Program approved on March 24, 2020. • Significant effort to complete a major refresh of the Rail Operators Rule Book (RORB), Train Control standard operating procedures (SOPs), and related documents, procedures and training were all completed. Multiple departments at GCRTA assured this activity was successfully completed – Rail, Service Quality, Engineering, Safety, Training, and Internal Audit. These updates are now being completed on an annual basis. • Significant capital projects for the rail systems and infrastructure continued including Tower City, multiple stations, and track and power system projects. • GCRTA completed significant work to begin their process to purchase new rail vehicles including interviews with potential suppliers, developing the request for proposal for technical support, and building and sourcing the significant capital funds needed. • Significant technical projects to replace the microprocessor for heavy rail vehicles and the pre- exciter for the light rail vehicles have been completed. These were critical projects that allowed the older rail vehicles to be maintainable and available for full service. • GCRTA has been working to assess and repair the signaling systems across the rail systems. There were significant issues found with the old light rail block signal systems through the 2018
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assessment activities. GCRTA and ODOT SSO program staff have had multiple meetings and completed a field review of work being done on the light rail system during June 11-12, 2019. Since this time, the light rail block signal system went back into service in August 2019. • In May 2019, GCRTA realized that a retaining wall on the Red Line near a busy freight line appeared to be in the process of failing. Emergency actions were taken, and the s-curve section of track was taken out of service on May 30, 2019, disrupting heavy rail service between the airport and downtown Cleveland. GCRTA worked with their capital projects consultants to develop an innovative solution to this extreme problem. Emergency repairs were developed and made, as shown in Figure 5. The s-curve and Red Line were back in service on August 26, 2019.
Figure 5. Construction of the S-Curve and Red Line
GCRTA Rail Safety Program Status. From the ODOT SSO program perspective, the GCRTA rail system safety program is being managed properly and all deadlines for annual certification continue to be completed on time. The working relationship with GCRTA executive management, department management, and staff continues to be excellent. GCRTA’s challenges from a safety performance perspective continue to be managing aging infrastructure and rail vehicles, as well as succession planning for turnover of middle management and technical staff. GCRTA has been working to complete specification and purchase of new rail vehicles. GCRTA has also invested significantly into training and capabilities for the technical staff in rail-related departments. These activities require a tremendous amount of effort and discipline, and significant progress continues to be made.
Cincinnati Bell Connector Streetcar
The ODOT SSO program also provides safety program oversight for the Cincinnati Bell Connector Streetcar (http://www.cincinnati- oh.gov/streetcar/), which includes a route of 3.6 miles of single track and catenary power system. This streetcar system went into service on time September 9, 2016, and ridership at approximately 1.8 million through December 2019. The City of Cincinnati began presenting streetcar ridership and related operational data on a publicly available website: https://www.cincinnati- oh.gov/streetcar/about-the-streetcar/ridership-and-reports/
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One of the modern streetcar vehicles is shown in Figure 6 and the route map is shown in Figure 7. The route runs between the Banks through downtown up to the Over the Rhine neighborhood. This has been a joint operation between the City of Cincinnati and the Southwest Ohio Regional Transit Authority (SORTA). The City of Cincinnati owns the assets for the Cincinnati Streetcar and through an intergovernmental agreement has had SORTA responsible for operations and maintenance. Transdev started in August 2015 as the operations and maintenance contractor to SORTA for the Cincinnati Streetcar, including management and staff to operate and maintain the streetcar services. Figure 8 shows one of the streetcar vehicles at the maintenance and operating facility (MOF).
Figure 6: Cincinnati Bell Connector Streetcar
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Figure 7: Cincinnati Streetcar Route Map
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Figure 8. Cincinnati Streetcar Maintenance and Operating Facility (MOF)
In July 2018, the City of Cincinnati started a formal inquiry into removing SORTA from the management team for the Cincinnati Streetcar. In August 2018, the ODOT SSO program offered the City of Cincinnati and SORTA a description of the documents and processes that would need to be addressed in order to make this transition. The idea and intent to transition the operations and maintenance away from SORTA and to the City of Cincinnati was a work in progress through most of 2019. As of the end of 2019, SORTA and the City of Cincinnati have updated their agreements and processes, but the full transition will occur in 2020 pursuant to their executed Mutual Termination Agreement.
As of the end of 2019 and for the Annual Certification, the safety program management of record for the Cincinnati Streetcar from the ODOT SSO program point of view is the following:
• Mr. Darryl Haley, Chief Executive Officer, SORTA (Accountable Executive) • Mr. TJ Thorn, Vice President, Safety and Security, SORTA (Chief Safety Officer) • Mr. Travis Jeric, Streetcar Director, City of Cincinnati • Mr. Paul Conway, Transit Coordinator, City of Cincinnati
As the City of Cincinnati and SORTA complete this transition, the City of Cincinnati has worked to complete the following activities:
• Hire a new Chief Safety Officer • Complete transition of the streetcar FTA grant (including becoming recertified as a grant recipient) • Complete revision of all relevant safety program documentation as agreed to with the ODOT SSO Program • Complete transition of Transdev’s operations and maintenance contract to the City of Cincinnati.
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Once the transition is complete in early 2020, the safety program management of record for Cincinnati Streetcar will become the following:
• Mr. Patrick Duhaney, City Manager, City of Cincinnati (Accountable Executive) • Mr. Travis Jeric, Streetcar Director, City of Cincinnati • Mr. Paul Conway, Transit Coordinator and Interim Chief Safety Officer, City of Cincinnati • New Hire, Chief Safety Officer, City of Cincinnati
Along with ODOT SSO program staff, Mr. Jeric and Mr. Conway attended the FTA joint State Safety Oversight and Rail Transit Agency Workshop in Washington D.C. on September 23-26, 2019. Safety program documentation updates will need to be completed, including completion and approval of a City of Cincinnati specific Public Transportation Agency Safety Plan (PTASP) prior to the regulatory deadline of July 20, 2020.
Communications with the project team occurs daily with email or phone calls. SORTA provides monthly status reports, including logs for daily incidents, blocking vehicles (or construction equipment), and CAPs (from Transdev and as agreed to by SORTA). The ODOT SSO program participates in the Safety and Security Review Committee (SSRC) meetings, which also includes configuration management committee duties. The ODOT SSO program and City of Cincinnati, SORTA, and Transdev have completed 2019 quarterly meetings (February 21st, May 17th, August 23rd and November 19th) in Cincinnati to go over status of the operations, maintenance, development of procedures, and development of related safety and security program processes and documents, as well as investigations and CAPs.
Figure 9 shows investigations completed by the Cincinnati Streetcar team for the ODOT SSO program including FTA required and State only required investigations. Revenue service in 2016 included nearly four months of operation and the chart includes all of 2017 through 2019. The FTA reportable event investigations changed in 2018 to a lower number based on the change of safety event criteria and threshold from the new SSO Rule (49 CFR Part 674). From the beginning of 2018 on, note that streetcar collisions with motor vehicles in street running or at intersections are no longer automatically reportable unless substantial damage is established from the safety event.
Figure 10 shows corrective actions developed for audits and inspections by year. For operating years 2016 and 2017, there were a number of audits included to assure proper and safe transition into revenue service for the Streetcar system. The number of corrective actions from investigations increased through 2018 as processes, procedures, and training requirements were improved based on experience in revenue service. The number of corrective actions were significantly lower in 2019.
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30
25
20
15
10
5
0 2016 2017 2018 2019
FTA Reportable ODOT Reportable
Figure 9. Number of FTA and ODOT Required Investigations by Year
90 80 70 60 50 40 30 20 10 0 2016 2017 2018 2019
Investigations Audits
Figure 10. Number of Corrective Actions for Investigations and Audits by Year
The Cincinnati Streetcar safety program completed their third year of internal audits in 2019, covering the third seven safety plan elements and workplace safety at the maintenance and operating facility. These audits resulted in 2 corrective actions.
In 2019, the ODOT SSO program has participated in Cincinnati Streetcar training activities and worked together to set up awareness training for the streetcar operation. A training session for reviewing investigation processes has been completed. In addition, SORTA safety and security staff and Transdev staff have worked towards completing their FTA Safety Certification Training Program requirements. With the City of Cincinnati staff preparing for the transition, they have also started completion of the FTA required safety training.
Highlights from Cincinnati Streetcar in 2019. Calendar year 2019 was busy for the Cincinnati Streetcar team. A few highlights are mentioned here.
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• The Cincinnati Streetcar interim Agency Safety Plan was completed in December 2019 for review by the ODOT SSO program and then the approvals were completed in early 2020 on time for the Annual Submission to FTA. The Agency Safety Plan has continued the approval process in early 2020, well ahead of the July 20, 2020 deadline. • SORTA supported the City of Cincinnati in revising all of the safety program related control documents in preparation for the transition. These documents are still the process of being finalized in early 2020. • Ridership for the Cincinnati Streetcar was approximately 531,000 during 2019, and more than 1.8 million since beginning service in September 2016 through December 2019. • A technical study of the traffic signals in downtown Cincinnati was completed in 2019 with several improvement to signal timing along the streetcar alignment. Signal timing changes have been completed and will be monitored to assure the results continue to allow for improved streetcar on-time performance. • Work has continued in 2019 to keep the streetcar vehicles operating in service: o Air compressor issues in cold weather o Completion of warranty work from the manufacturer (field modifications) o Assuring vehicle configuration control and software maintainability o Issues with wheels and maintenance wheels o Assuring access to spare parts and special tools • The ODOT SSO program staff and Cincinnati Streetcar staff met on multiple occasions to review corrective actions status, closure evidence, and completed quality assurance of the closure evidence, as appropriate. With the number of corrective actions developed early in operations and a number of management changes at Transdev during the first couple of years in operation, there was a need to assure proper processes, communication, and coordination. This activity included 10 meetings during 2019, including the quarterly meetings in Cincinnati. The objective was to assure that these processes were improved and resolved by the time FTA completed their audit of the ODOT SSO program in December 2019. These objectives were met through these focused activities.
Cincinnati Streetcar Rail Safety Program Status. From the ODOT SSO program perspective, the Cincinnati Streetcar rail system safety program are being managed properly and all deadlines for developing documentation for the safety program are being met. The working relationship with the City of Cincinnati, SORTA, and Transdev management and staff continues to be excellent.
ODOT SSO Program Plans for 2020
The 2020 calendar year is expected to be busy with planned (and already completed) activities for the ODOT SSO program as follows:
• ODOT SSO program staff are preparing to receive and respond to the FTA headquarters audit of the program, with a draft audit report expected in early to mid-2020. • The ODOT SSO program continues to monitor GCRTA’s process for specifying and purchasing new rail cars for the heavy and light rail systems. At the same time, the existing aging infrastructure continues to be a high priority for safety risk monitoring. • The ODOT SSO program continues to monitor the transition activities that need to be completed in order for the City of Cincinnati to take over direct operations and maintenance of the Cincinnati Bell Connector with the contracted services of Transdev. SORTA will be transitioned out of the management role as soon as all of the action items have been completed.
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• The ODOT SSO program is scheduled to complete a Triennial Safety Program Audit of the Cincinnati Streetcar system in late 2020. This will be an opportunity to assure proper and complete transition from the SORTA managed operation to the City of Cincinnati managed operation. • FTA and the ODOT SSO program continue conference calls to coordinate updates and information requested from FTA. A new version of the Program Standard is expected by mid-2020. • Required completion of Annual Reports and Certification from GCRTA and Cincinnati Streetcar by January 31st and Approval from the ODOT SSO program has been completed. Required annual data and information submission and annual certification by the ODOT SSO program to FTA has been completed in March 2020, as required. • Quarterly meetings continue, as scheduled. o GCRTA – January, April, July, and October o City of Cincinnati/Transdev – February, May, August, and November • ODOT SSO program staff and RTA staff continue to attend required FTA SSO program workshops, typically in the Washington, DC area. • ODOT SSO program staff continues to attend required FTA safety certification training classes and to develop and implement the technical training plan with Cincinnati Bell Connector streetcar. • Both Ohio RTAs (GCRTA and SORTA) staff supporting the safety program continue to work towards completing FTA-required safety certification training.
Conclusion
Calendar year 2019 was busy and all programmatic requirements, objectives, and deliverables were met. Safety performance at both rail properties continues to exceed planned targets. Expectations for calendar year 2020 are high with changes to the electronic data submission system – FTA’s State Safety Oversight Reporting (SSOR) tool. The SSO program data collection is now directly advised by the transit agency’s reporting to the National Transit Database (NTD). Activities for 2020 focus on the transitions at both rail properties with staffing and responsibilities, along with the triennial safety program audit for Cincinnati Streetcar later in the year. The SSO program staff remain busy with audits and examinations of rail system safety at each rail property, and FTA has high expectations for those field activities with the transit agencies. The SSO program continues to work with both rail properties and promotes focus on safety performance.
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