Trains.com

Class I railroads looking to shutdown all operations over looming PTC deadline

9457 views
157 replies
1 rating 2 rating 3 rating 4 rating 5 rating
  • Member since
    January 2014
  • 8,221 posts
Posted by Euclid on Tuesday, September 8, 2015 8:13 PM

NKP guy

 The railroads won't be shutting down.

Why do I think this way?  Several reasons:  First, it's not in anyone's interest,...  

Well it is in someone's interest.  It is in the interest of the railroads if they want to abide by the law if they are non-compliant when the deadline arrives.  Not only is it in their interest, it is required if they want to follow the law.  

  • Member since
    December 2007
  • 1,307 posts
Posted by Falcon48 on Tuesday, September 8, 2015 8:29 PM

I agree that the railroads will not likely be "shutting down".  The most likely scenario is that Congress, being the reasonable institution it is, is going to be sensible and extend the PTC mandate (I also still believe in the Tooth Fairy).

But if Congress isn't sensible (imagine that) and doesn't extend the mandate, I still don't think that any railroad is going to "shut down", for the reasons discussed in my earlier note.  Rather, I think that several (perhaps all) railroads will stop providing TIH service and stop providing, or hosting, passenger service.  My impression is that neither of these services are considered particularly desireable by commercial freight railroads, and they wouldn't be crying in their beer if one or both of them had to be discontinued because of the PTC mandate. 

 

  • Member since
    October 2006
  • From: Allentown, PA
  • 9,810 posts
Posted by Paul_D_North_Jr on Tuesday, September 8, 2015 8:33 PM

In response to Falcon48's post above:

Well said - Bow

The only contra argument I can think of is this: Amtrak or such a shipper of hazmat could take the position that the railroad had an obligation to install PTC by the deadline, and that Amtrak/ shipper should not be disadvantaged by the railroad's failure to comply by then.  The PTC mandate trumps any tariff or contract of carriage.  So if the railroad can't actualy perform, then Amtrak/ the shipper is entitled to appropriate monetary damages. 

I too doubt that a court will order "specific performance" (as a court of equity) - i.e., for the railroad to actually move the hazmat or Amtrak train.  Instead, the court will likely act as a "law court" and say that the remedy of monetary damages is sufficient to make the aggrieved party "whole".  (The reasons for this would get us bogged down in a lot of legal theory.)      

If such a shutdown - or even the threat of it - comes to pass, the doctrines of impossibility, commercial impracticality, anticipatory breach of contract, force majeure, 3rd-party (govt.) interference with contract rights, mutual and/ or unilateral "mistake" or assumption/ allocation/ knowledge/ control of the risk of this, etc., will get a major workout in the courts.

- Paul North.     

"This Fascinating Railroad Business" (title of 1943 book by Robert Selph Henry of the AAR)
  • Member since
    July 2006
  • 9,610 posts
Posted by schlimm on Tuesday, September 8, 2015 8:46 PM

BaltACD

 

 
schlimm
BaltACD
schlimm

The rails have resisted this for 40+ years.  They've known the deadline was there for 4 years.  Sometimes threats are needed for foot draggers.

Bovine Excriment

Real professional language.

 

Professional language for a professional troll.

 

Sorry your language is so inadequate that you can only make specious, ad hominem attacks to comments that are not directed at you personally. Perhaps such is the expected response of a disgruntled, embittered worker?

C&NW, CA&E, MILW, CGW and IC fan

  • Member since
    November 2012
  • 105 posts
Posted by ouibejamn on Tuesday, September 8, 2015 8:52 PM

schlimm
Perhaps such is the expected response of a disgruntled, embittered worker?

Naww, just another day on the Geezernet.

  • Member since
    March 2002
  • 9,265 posts
Posted by edblysard on Tuesday, September 8, 2015 8:52 PM
 He's disgruntled and embittered?
All this time I thought he was a miscreant and a malcontent, but now.....

23 17 46 11

  • Member since
    January 2014
  • 8,221 posts
Posted by Euclid on Tuesday, September 8, 2015 9:18 PM
Falcon48

I agree that the railroads will not likely be "shutting down".  The most likely scenario is that Congress, being the reasonable institution it is, is going to be sensible and extend the PTC mandate (I also still believe in the Tooth Fairy).

But if Congress isn't sensible (imagine that) and doesn't extend the mandate, I still don't think that any railroad is going to "shut down", for the reasons discussed in my earlier note.  Rather, I think that several (perhaps all) railroads will stop providing TIH service and stop providing, or hosting, passenger service.  My impression is that neither of these services are considered particularly desireable by commercial freight railroads, and they wouldn't be crying in their beer if one or both of them had to be discontinued because of the PTC mandate. 

 

 
As I understand it, the railroads may refuse service on non-compliant operations.  The response to my question here seems to be that the issue ends there, and the railroads will probably choose not to refuse service. 
However, it is not just that they have the option to refuse service.  They also are breaking the PTC law if they operate in non-compliance after the deadline.  So to be legal, they have no option but to cease operation and refuse service. 
Is this not correct?
Here is an article with a following quote that confirms that if railroads do not stop service, they will be breaking the law:
 
“Without extension, many passenger and freight railroads will be unable to meet the current unrealistic deadline of Dec. 31, 2015, and would be forced to decide between stopping service and operating in violation of the law.” 
  • Member since
    July 2006
  • 9,610 posts
Posted by schlimm on Tuesday, September 8, 2015 9:56 PM

oltmannd

 

 
schlimm
The UP was in the forefront of developing PTC here.

 

No.  BN and CN took the lead, with CSX pushing from behind.

 

You are right.  However, in the 1990s, UP and GE did work on a moving block system called PTC - Precision Train Control, but abandoned it.

C&NW, CA&E, MILW, CGW and IC fan

  • Member since
    July 2006
  • 9,610 posts
Posted by schlimm on Tuesday, September 8, 2015 10:00 PM

The mandate was passed in the RSIA in 2008, so seven years before the deadline. It was endorsed by the AAR in a written statement by its CEO, Edward Hamberger.

C&NW, CA&E, MILW, CGW and IC fan

  • Member since
    May 2003
  • From: US
  • 25,292 posts
Posted by BaltACD on Tuesday, September 8, 2015 10:28 PM

schlimm

The mandate was passed in the RSIA in 2008, so seven years before the deadline. It was endorsed by the AAR in a written statement by its CEO, Edward Hamberger.

and it was NOT either a designed or purchasable product from any vendor or consortium of vendors and no standards existed for it.

You all know about the 10 minute home repair job - that ends up taking 10 months and $10K to finally accomplish once the real significance of the repair becomes clear and understood.

Never too old to have a happy childhood!

              

  • Member since
    July 2006
  • 9,610 posts
Posted by schlimm on Tuesday, September 8, 2015 10:48 PM

BaltACD

 

 
schlimm

The mandate was passed in the RSIA in 2008, so seven years before the deadline. It was endorsed by the AAR in a written statement by its CEO, Edward Hamberger.

 

and it was NOT either a designed or purchasable product from any vendor or consortium of vendors and no standards existed for it.

You all know about the 10 minute home repair job - that ends up taking 10 months and $10K to finally accomplish once the real significance of the repair becomes clear and understood.

 

I agree.   So why did the AAR endorse the deadline in 2008?   Since they certanily would have known there was no US off-the-shelf system available, why didn't they push for a later deadline at that point?   Or adapt the proven European system which is becoming the world standard?  Or Japanese?

C&NW, CA&E, MILW, CGW and IC fan

  • Member since
    May 2003
  • From: US
  • 25,292 posts
Posted by BaltACD on Tuesday, September 8, 2015 11:04 PM

schlimm
BaltACD
schlimm

The mandate was passed in the RSIA in 2008, so seven years before the deadline. It was endorsed by the AAR in a written statement by its CEO, Edward Hamberger.

and it was NOT either a designed or purchasable product from any vendor or consortium of vendors and no standards existed for it.

You all know about the 10 minute home repair job - that ends up taking 10 months and $10K to finally accomplish once the real significance of the repair becomes clear and understood.

I agree.   So why did the AAR endorse the deadline in 2008?   Since they certanily would have known there was no US off-the-shelf system available, why didn't they push for a later deadline at that point?   Or adapt the proven European system which is becoming the world standard?  Or Japanese?

because the AAR is a mouthpiece and was parroting the belief that it was a 10 minute home repair - seriously underestimating the size of the undertaking for the RAILROAD INDUSTRY, not just a individual carrier that could probably kluge together something that would operate on their property alone (like Amtrak has done with the NEC - with the NEC being electric their locomotives won't be operating on the rest of the railroads and thus don't have to have interoperatability).  

Never too old to have a happy childhood!

              

  • Member since
    November 2005
  • 4,190 posts
Posted by wanswheel on Wednesday, September 9, 2015 2:20 AM

Excerpt from the Reuters article

In a July 24 letter provided to Reuters by BNSF, railroad president and chief executive Carl Ice informed Elliott that BNSF is analyzing the possibility of a service shutdown and actively consulting with customers.  

Excerpt from Carl Ice’s letter to Daniel Elliott

Dear Chairman Elliott:
 
I write in response to your letter of July 13, 2015, requesting our assessment of fall peak expectations and our ability to meet expected demand, as well as specific questions surrounding network performance...
 
Ongoing PTC installation and testing also potentially decreases velocity as track windows are required for this work as well. As you know, BNSF will not be able to meet the yearend deadline for PTC installation. While legislation to extend the deadline is under active consideration in Congress, it remains unclear at the moment what the consequences of noncompliance will be postdeadline. Customers are beginning to seek clarification on what impacts they may face and how it will affect the operation of the network. BNSF is currently evaluating its legal and contractual duties and obligations, and we are communicating with our customers. Our review includes analysis of the possibility that, if Congress has not extended the deadline for PTC operations, as of January 1, 2016, neither passenger nor freight traffic would operate on BNSF lines that are required by federal law and regulation to have an interoperable PTC system as of that date…
 
  • Member since
    October 2006
  • From: Allentown, PA
  • 9,810 posts
Posted by Paul_D_North_Jr on Wednesday, September 9, 2015 5:07 AM

Further on my post above:

"Courts of equity will not act when there is adequate remedy at law."

Courts generally prefer to order someone to not do something; they are extremely reluctant to order someone to actually do something, because of the difficulty of monitoring, supervising and enforcing the performance of said acts.   

(Thank goodness Mrs. Palsgraf vs. Long Island RR is not involved in any of this [inside joke, goes to the "forseeability" of the chain of results of and hence damages from the wrongful act] ).

- Paul North.

"This Fascinating Railroad Business" (title of 1943 book by Robert Selph Henry of the AAR)
  • Member since
    July 2006
  • 9,610 posts
Posted by schlimm on Wednesday, September 9, 2015 7:45 AM

BaltACD
because the AAR is a mouthpiece and was parroting the belief that it was a 10 minute home repair - seriously underestimating the size of the undertaking for the RAILROAD INDUSTRY

[from the AAR website]:  "AAR is the world's leading railroad policy, research and technology organization focusing on the safety and productivity of rail carriers."  

The AAR also owns the Transportation Technology Center, Inc. which manages/operates the FRA's facility in Pueblo.   Doesn't sound like a just another DC mouthpiece, i/e., lobbyist.   http://www.aar.com/ 

So I guess from your perspective, they are just liars (or trolls).

C&NW, CA&E, MILW, CGW and IC fan

  • Member since
    January 2014
  • 8,221 posts
Posted by Euclid on Wednesday, September 9, 2015 8:29 AM
In reading articles, it seems to me that the prospect of shutdown is being offered by the industry as a threat to the government to disrupt public service and thereby put pressure on the government to extend the deadline.  In this context, the shutdown is seen as an option of the industry.
But there is no such option of behalf of the industry.  A shutdown is mandated as a part of the PTC mandate.  Therefore, the shutdown and disruption of public service has to happen, and the resulting pressure on the government will be solely the result of the government, as opposed to a chosen tactic of the industry.  The industry has no choice in the matter. 
The ball is in the government’s court, and they have two options.  Either they extend the deadline or they take over the operation of the railroads.
  • Member since
    July 2006
  • 9,610 posts
Posted by schlimm on Wednesday, September 9, 2015 8:52 AM

I am not aware of anything in the mandate tht would impose fines for most traffic, only on lines running passenger trains and hazardous materials.  If there were a embargo on that traffic for a few days, it would not be cataclysmic.

C&NW, CA&E, MILW, CGW and IC fan

  • Member since
    June 2009
  • From: Dallas, TX
  • 6,952 posts
Posted by CMStPnP on Wednesday, September 9, 2015 8:54 AM

I think some of you that are posting here that a shutdown will not happen should look at the amount of the daily fines for non-compliance that the government will levy FOR EACH INCIDENT OF VIOLATION.    It's well above pocket change.

  • Member since
    December 2004
  • 707 posts
Posted by tdmidget on Wednesday, September 9, 2015 8:59 AM

Since almost all Amtrak operations outside of the NEC lose money, there would be no monetary damages to Amtrak. Long shot, but maybe passengers could claim damages but only if no other transportation means was available. The TIH volume is small enough to pay to make it go away as they tried to get rid of it before.

  • Member since
    May 2003
  • From: US
  • 25,292 posts
Posted by BaltACD on Wednesday, September 9, 2015 9:13 AM

schlimm
BaltACD

[from the AAR website]:  "AAR is the world's leading railroad policy, research and technology organization focusing on the safety and productivity of rail carriers."  

The AAR also owns the Transportation Technology Center, Inc. which manages/operates the FRA's facility in Pueblo.   Doesn't sound like a just another DC mouthpiece, i/e., lobbyist.   http://www.aar.com/ 

So I guess from your perspective, they are just liars (or trolls).

They SERIOUSLY UNDERESTIMATED the size and complexity of the undertaking.

Never too old to have a happy childhood!

              

  • Member since
    July 2006
  • 9,610 posts
Posted by schlimm on Wednesday, September 9, 2015 9:19 AM

CMStPnP

I think some of you that are posting here that a shutdown will not happen should look at the amount of the daily fines for non-compliance that the government will levy FOR EACH INCIDENT OF VIOLATION.    It's well above pocket change.

 

I posted that before.  Each vioation per day is $10-30K, fairly costly.   But that seems to only apply to running hazardous cargo and passenger trains.  If an extension has not been passed by Congress by Jan. 1 (I believe it will), embargo them (running Amtrak passenger trains cost the freight lines money), run everything else and wait a few days for Congress to act.  It's really a lot of hysteria.

An extension to Dec. 31, 2018 should suffice.  Ten years is a long time since the mandate was passed in 2008.  It took less time to send men to the moon, build an atom bomb, etc.  

C&NW, CA&E, MILW, CGW and IC fan

  • Member since
    May 2003
  • From: US
  • 25,292 posts
Posted by BaltACD on Wednesday, September 9, 2015 9:34 AM

schlimm

An extension to Dec. 31, 2018 should suffice.  Ten years is a long time since the mandate was passed in 2008.  It took less time to send men to the moon, build an atom bomb, etc. 

Neither of which was privately funded.

Never too old to have a happy childhood!

              

  • Member since
    January 2002
  • From: Canterlot
  • 9,575 posts
Posted by zugmann on Wednesday, September 9, 2015 11:28 AM

We have the best government money can buy.  The date will be pushed back.

It's been fun.  But it isn't much fun anymore.   Signing off for now. 


  

The opinions expressed here represent my own and not those of my employer, any other railroad, company, or person.t fun any

  • Member since
    July 2006
  • 9,610 posts
Posted by schlimm on Wednesday, September 9, 2015 11:52 AM

BaltACD

 

 
schlimm

An extension to Dec. 31, 2018 should suffice.  Ten years is a long time since the mandate was passed in 2008.  It took less time to send men to the moon, build an atom bomb, etc. 

 

Neither of which was privately funded.

 

So what?  PTC is not rocket science or nuclear physics.   Why did the US rails elect to go with an entirely new design?   Why didn't they buy the products from Siemens (ECTS-Trainguard) or Hitachi (ATACS)?

C&NW, CA&E, MILW, CGW and IC fan

  • Member since
    December 2001
  • From: Northern New York
  • 25,022 posts
Posted by tree68 on Wednesday, September 9, 2015 12:26 PM

schlimm
So what?  PTC is not rocket science or nuclear physics.   Why did the US rails elect to go with an entirely new design?   Why didn't they buy the products from Siemens (ECTS-Trainguard) or Hitachi (ATACS)?

Given the ways of US bureacracy, neither probably met the requirements for some reason or another.

LarryWhistling
Resident Microferroequinologist (at least at my house) 
Everyone goes home; Safety begins with you
My Opinion. Standard Disclaimers Apply. No Expiration Date
Come ride the rails with me!
There's one thing about humility - the moment you think you've got it, you've lost it...

  • Member since
    July 2006
  • 9,610 posts
Posted by schlimm on Wednesday, September 9, 2015 12:38 PM

tree68

 

 
schlimm
So what?  PTC is not rocket science or nuclear physics.   Why did the US rails elect to go with an entirely new design?   Why didn't they buy the products from Siemens (ECTS-Trainguard) or Hitachi (ATACS)?

 

Given the ways of US bureacracy, neither probably met the requirements for some reason or another.

 

 

Could be but I don't recall the mandate gave any specs.  More likely other reasons within the rail's bureaucracy.  Purchasing managers tend to seek business from folks they have a history with.

C&NW, CA&E, MILW, CGW and IC fan

  • Member since
    January 2001
  • From: Atlanta
  • 11,971 posts
Posted by oltmannd on Wednesday, September 9, 2015 1:02 PM

zugmann

 

 
oltmannd
Meh. Had the RRs been more active in exanding train control technology over the past 40 years, they probably could have headed off PTC legislation at the pass and built out a system to their own specs at their own pace.

 

Exactly.  I feel not one bit of sorrow for these railroad companies.  They knew this stuff was coming years ago.  Is safety first more than a slogan?

 

They've been doing it with ECP braking, too. Those chickens are just starting to roost.

-Don (Random stuff, mostly about trains - what else? http://blerfblog.blogspot.com/

  • Member since
    January 2001
  • From: Atlanta
  • 11,971 posts
Posted by oltmannd on Wednesday, September 9, 2015 1:04 PM

schlimm

 

 
BaltACD

 

 
schlimm

An extension to Dec. 31, 2018 should suffice.  Ten years is a long time since the mandate was passed in 2008.  It took less time to send men to the moon, build an atom bomb, etc. 

 

Neither of which was privately funded.

 

 

 

So what?  PTC is not rocket science or nuclear physics.   Why did the US rails elect to go with an entirely new design?   Why didn't they buy the products from Siemens (ECTS-Trainguard) or Hitachi (ATACS)?

 

Because those aren't off-the-shelf ready for US freight railroading, either.

-Don (Random stuff, mostly about trains - what else? http://blerfblog.blogspot.com/

  • Member since
    January 2001
  • From: Atlanta
  • 11,971 posts
Posted by oltmannd on Wednesday, September 9, 2015 1:06 PM

schlimm

 

 
BaltACD
because the AAR is a mouthpiece and was parroting the belief that it was a 10 minute home repair - seriously underestimating the size of the undertaking for the RAILROAD INDUSTRY

 

[from the AAR website]:  "AAR is the world's leading railroad policy, research and technology organization focusing on the safety and productivity of rail carriers."  

The AAR also owns the Transportation Technology Center, Inc. which manages/operates the FRA's facility in Pueblo.   Doesn't sound like a just another DC mouthpiece, i/e., lobbyist.   http://www.aar.com/ 

So I guess from your perspective, they are just liars (or trolls).

 

The AAR doesn't own TTCI.  They are just leasing it.  Uncle Sam still owns it.

-Don (Random stuff, mostly about trains - what else? http://blerfblog.blogspot.com/

  • Member since
    January 2014
  • 8,221 posts
Posted by Euclid on Wednesday, September 9, 2015 1:56 PM
Fred Frailey has a great blog on this topic.  It does confirm that, aside from the issue of whether railroads have a common carrier obligation, BNSF will shut down rather than violate the law.

Join our Community!

Our community is FREE to join. To participate you must either login or register for an account.

Search the Community

Newsletter Sign-Up

By signing up you may also receive occasional reader surveys and special offers from Trains magazine.Please view our privacy policy