Couplets Criteria 1

Brotherhood of Locomotive Engineers and Trainmen
Karl F. Edler III

Chair
Local Committee of Adjustment
726 Upshur St NW
Washington DC 20011
202 494-3848
Division 482
Sept. 20, 2014
Shawn Gordon
Superintendent of Operations
Amtrak Mid Atlantic Subdivision
900 2nd St NE
Washington DC 20002
RE: Road Couplets Criteria
Dear Sir:
As requested, this memorandum summarizes our long standing position regarding Washington Road Couplets,
and reflects how our work has been organized for many years.
All of this must be understood within the context that changing long standing couplets should not be undertaken
without valid reasons which withstand scrutiny by reasonable people. In our recent discussions, the reasons
given for reviewing the long standing couplets worked in Washington Zone 2 have not met that criteria. The
goal of saving $1 million in the NEC may be laudable as a budget item, but it is abstract. No explanation has
been given for why a million, why T&E and why Washington.
As our members are the actual ones who bring in the revenue, we have a responsibility to explain to all
concerned why Amtrak would push the idea that these employees should subsidize the service they perform
with their own standard of living and quality of work life, when this is service the public demands and involves
costs over which those of us on the engines have no control.
Any discussion of couplets must begin and end with sustainability. Those who don't have decades of actually
working these trains regularly don't understand that the problems are in the details. Many if not most of our
trains are different. Those in cubicles may think that a spreadsheet that shows time on duty and time off duty is
the only factor that needs consideration. But anyone who operates with that premise endangers our long term
safety and thus our long term viability.
Of course you can force couplet changes. You have that power. But like every other important discussion, the
question is should it be done and what are the consequences.
Evaluating couplets in a formula that only considers cost makes exactly that mistake by not considering all the
facts. Time and time again such thinking has backfired on the Corporation. It seems the Organizations are
usually the only ones who maintain the history of what works and what really doesn't, because it has all been
tried before.
Sustainability consists not only of cost control and also not only safety and crew contentment. It also consists
of making real world cost analysis. In the real world, as we've seen again and again, the real cost of changing
couplets may be reflected in loss of institutional experience. This comes when jobs are so degraded that the
incumbents bid off and the Corporation has to replace them with less experienced or even new hire employees.
Training them costs money which will be wasted when the resulting couplets are such that the trained
employees will always bid off as soon as the opportunity opens. In Washington, that opportunity never takes
long and there are many choices.

Degrading couplets can also mean, in the real world, that those trains get worked by crews on overtime or more
overtime than would otherwise be the case. Many changes can make it impossible to responsibly couple
couplets together into regular assignments and create extra burdens for the Extra Lists. There are many ways in
which it has been shown in experience that combining runs in couplets that are cheaper on paper are actually
more expensive when they get run.
Having said that, we have held a standard for many years for our regular assignments that has included at least
four basic elements, proven to be essential for quality and safety.
1) No assignment has more than 3 couplets in a work week. Fewer is better and safer.
2) All couplets in a week start within the same time element, generally within an hour.
3) Minimum 90 minute turns on couplets that do not deadhead. This is a minimum real 90 minutes, sign
off to sign up, so from getting off a train in NY to getting back on the next one, would be a minimum
typically of 2 hours and 20 minutes).
4) Couplets that work 12 or more hours a day are a bad idea and should be avoided when possible.
We also have always tested for quick turns from one day to the next. Deadhead trains still require sufficient
time before deadheading to allow for delay in route without forcing crews to go without a chance to refresh
themselves upon arrival in NY.
The main principle of the Hours of Service law and our own CBA rules is that an employee should be able to
plan their rest. This means that trains that are known to be regularly off schedule cannot be treated in the same
way as those who normally are on schedule. It means also that trains that are habitually late should not be
coupled to work back, if that would routinely, in the real world, mean stepping off one train onto the other. It
must also be understood that the employee plans their rest based upon what they know about their assignment.
If that assignment deadheads, then it is completely irresponsible to change that known assignment after the
employee has already come to work expecting to be deadheading instead of operating a train on the return trip.
The practice of CMS pressuring crews to sign up on their rest in an effort to avoid true compliance with
Hours of Service Law must stop and couplets that require that act are not acceptable.
We remind all concerned that the Organizations worked hard and in good faith to create the revised Passenger
Service Hours of Service rules. The new standards were based mainly upon an agreement with the Corporation
that the Organizations would be able to accept couplets proposed without endangering our membership. If that
happens, our support for a separate set of Hours of Service rules from that of the freights will disappear.
Deadheads in all cases exist in couplets for a reason. There is always a reason. If there is some change in that
reason than it might be reasonable to reassess. However, if nothing has changed, then simply deciding it looks
good on paper to go back to whatever the situation was before it was changed to a DH is a waste of Corp
resources, and a failure of due diligence.
For many years, we have had the following understanding regarding sign up and sign off:
40 minute signups for trains that originate in DC or NY.
Sign up for trains that do not originate in WAS or NY have signup times that have been determined to take into
account protecting the dwell time of the inbound as well as whether or not the Engineer is expected to put the
outbound motor on. Agreed upon Sign ups for these trains is 30 minutes before arrival in WAS. In reality, 30
minutes is inadequate for the work of having a crew briefing, getting to the low level, inspecting one or more
locomotives and being prepared to move when the inbound locomotive is cut off.
10 minute signups for DH trains outbound and arrival time signoff time for inbound DH trains
40 minute release times for inbound trains in WAS that go through south of WAS to allow for setting off head
end power if necessary. This is based upon 20 minute standard low level release time plus 20 minutes to set off
the power.
20 minute low level release times for trains that terminate in WAS. 10 minute release times for trains that
terminate on the high line.
These times are not arbitrary. They all reflect real world work that is assigned, and real world issues that
resulted in these resolutions.
Washington has worked most of the trains in it's couplets for so long that as a practical matter, they should
rightfully be considered to belong to this crewbase and should only be assigned to others for reasons of
seniority, as per 6L.
Combining DH runs on weekends makes regular assignments impossible in many cases which means the real
world cost of consolidating weekend work can be adding a large number of extra fills to the Extra List. Every
couplet by necessity affects the others and can make or break the ability to make sustainable regular
assignments.
We believe that there is an unchallenged fallacy at work in many levels of Amtrak management. That fallacy is
that there is great waste and/or excess in the current crew couplets. No one has yet been able to scientifically
back up this mistaken conception with facts that stand real world scrutiny. But it persists, mainly, we believe
because misguided people who don't do the work we do want to direct attention away from scrutiny of parts of
the operation that don't directly bring in the revenue.
As regards our recent experience, it is already abundantly clear that both CMS and MASD are very prepared to
sacrifice everything for what is a paper savings. We can only say in this regard that if neither party sees the
danger in putting paper costs ahead of all other concerns; we stand ready to assist in explaining the pitfalls of
changes but this is really best done on a case by case basis and not based on a spreadsheet or formula which will
never take all the pertinent facts into consideration.
Regards,
Fritz Edler
for
BLE-T Div. 482
Local Committee of Adjustment
Washington DC

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Brotherhood of Locomotive Engineers and Trainmen

Karl F. Edler III

long and there are many choices.

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