Trains.com

Solving the PTC Deadline Problem

20609 views
346 replies
1 rating 2 rating 3 rating 4 rating 5 rating
  • Member since
    January 2014
  • 8,221 posts
Posted by Euclid on Sunday, September 20, 2015 1:45 PM
Norm48327
 
Euclid
For those objectives, PTC is the perfect target for nationalization.

 

And it would likely set back implementation 20 years and with huge cost overuns. The federal government isn't noted for getting things done expediently.

 

Who cares about that?  The people don’t seem to mind, and it gets the problem off of the railroads’ back.  I’m sure they would jump for joy.  It also gets Congress and the FRA out of the hot seat.  I think it is a win-win. 
  • Member since
    December 2007
  • From: Southeast Michigan
  • 2,983 posts
Posted by Norm48327 on Sunday, September 20, 2015 1:25 PM

Euclid
For those objectives, PTC is the perfect target for nationalization.

And it would likely set back implementation 20 years and with huge cost overuns. The federal government isn't noted for getting things done expediently.

Norm


  • Member since
    January 2002
  • From: Canterlot
  • 9,575 posts
Posted by zugmann on Sunday, September 20, 2015 11:31 AM

Euclid
For PTC, they tried a mandate and it didn’t work, so the next step is nationalization.

 

Can you find a single policy writer or congress critter that shares the same thought?

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
    January 2014
  • 8,221 posts
Posted by Euclid on Sunday, September 20, 2015 10:52 AM

dehusman
 
Euclid
In the larger perspective, I suspect that the Obama Administration is considering nationalizing the PTC installation under the premise that the job is too big for the railroads.
 

The government could mobilize the forces ....

 

 
... and and provide the nearly unlimited funding that it will take to provide public PTC (PPTC).

There is no budget for it, the government doesn't have the expertise, the government doesn't have the manpower, the government does have the organizational structure, the government doesn't have the infrastructure and even if they did nationalize it they would STILL have to work with the same component deliver schedules from the vendors, they would still have to have a similar installation schedule, they would still have the same testing protocol.

There has been no, none, zero, zippo discussion of any form of nationalization from any person actually involved with the process.

The only person discussing it is you.

 

No, none, zero, zippo discussion of any form of nationalization from any person actually involved with the process?  I think you exaggerate.

Nationalization is called upon for big public problems that need a big solution.  Nationalization is particularly attractive for big public problems that involve public welfare and safety.  For those objectives, PTC is the perfect target for nationalization.  National healthcare is another perfect example. Nationalization is called for when free market systems fail to get the job done.  For PTC, they tried a mandate and it didn’t work, so the next step is nationalization.

 

  • Member since
    September 2003
  • From: Omaha, NE
  • 10,621 posts
Posted by dehusman on Sunday, September 20, 2015 8:47 AM

Euclid
In the larger perspective, I suspect that the Obama Administration is considering nationalizing the PTC installation under the premise that the job is too big for the railroads.

The only person considering that is you. 

The government could mobilize the forces ....

Pray tell where is the government hiding the 20,000+ signal, mechanical and IT personnell that it would take to implement PTC.  Where are all the people hiding with the expertise to interface PTC with all the different railroad information and signal systems, ally of which have different software from different vendors written in different languages?

... and and provide the nearly unlimited funding that it will take to provide public PTC (PPTC).

Where in the US budget is the billion dollars a year it would take to fund the development? 

There is no budget for it, the government doesn't have the expertise, the government doesn't have the manpower, the government does have the organizational structure, the government doesn't have the infrastructure and even if they did nationalize it they would STILL have to work with the same component deliver schedules from the vendors, they would still have to have a similar installation schedule, they would still have the same testing protocol.

There has been no, none, zero, zippo discussion of any form of nationalization from any person actually involved with the process.

The only person discussing it is you.

Dave H. Painted side goes up. My website : wnbranch.com

  • Member since
    January 2014
  • 8,221 posts
Posted by Euclid on Sunday, September 20, 2015 8:13 AM
I agree that the liability is a big part of the problem.  Railroads have cited the three basic reasons for shutting down as being liability, fines, and breaking the law.  Fines can be waived by the FRA.  Fixing the problem of breaking the law requires Congress to change the law.  I seem to recall one or more of the railroads saying that the law needs to be changed by the end of October to avoid a service disruption and its impact on the economy.  It is just a guess, but I don’t think they can accomplish that goal by the end of October.
Obama seems capable of doing anything that he wants to, so maybe he can fix the problem in time.  All he has to do is do it, and if nobody objects, it will be done.
One way to solve the liability problem would be for the government to assume the liability for railroad accidents if the law stays in place and railroads are non-compliant.
In the larger perspective, I suspect that the Obama Administration is considering nationalizing the PTC installation under the premise that the job is too big for the railroads.  The government could mobilize the forces and provide the nearly unlimited funding that it will take to provide public PTC (PPTC).
  • Member since
    August 2006
  • From: Suburbs of New York
  • 23 posts
Posted by tommyboy on Sunday, September 20, 2015 5:24 AM

The concern the railroads seem to have is, as spelled out by CSX, is not so much the problem of "breaking the law" but the increased liability they would face. Specifically, if there was a serious accident on a line being operated in defiance of the PTC deadline. CSX CEO Michael Ward has said if that happened the road would be looking at potentially "huge liability." 

I'm not a railroader but having been in private industry for a number of years I agree. I think unless and until the law is amended the railroads would be well-advised not to operate after Dec. 31, 2015 on lines that require but don't have PTC. From a liability standpoint that would be very risky.

  • Member since
    January 2014
  • 8,221 posts
Posted by Euclid on Saturday, September 19, 2015 10:54 PM
As I understand it, the enforcement is not the issue.  In this case, the enforcement would be the fines, and the FRA has the power to decide whether fines will be levied or not.  The law gives the FRA the power to control the fines, but the FRA does not have the power to change the law in any way.  Extending the deadline would require changing the law, and so the FRA does not have the power to extend the deadline. 
As a matter of enforcement, the law could have been written to require all non-compliant operations to cease after the deadline, but they did not write it that way; probably because they realized how disruptive that would have been. 
But now the railroads have said they will shut down anyway if non-compliant, regardless of how disruptive it might be.  It makes no difference if the FRA were to not issue fines.  The position of the railroads is that even with no fines, the non-compliant operations would still be illegal.  And they don’t want to break the law. 
Abiding by the law may seem like a moot point if there is no enforcement of it, but everybody has the right, if not the duty, to abide by the law.  It is a moral principle if nothing else. 
But, in this case, it could also be a ploy to pressure Congress into extending the deadline.  As a personal decision, most people would not cease a profitable business activity just because it is illegal; if the government did not intend to enforce the law.  They would just go ahead and break the law, because there would be no consequence from it.     
  • Member since
    September 2011
  • 6,449 posts
Posted by MidlandMike on Saturday, September 19, 2015 10:08 PM

Euclid
 
Suspending enforcement is a prerogative of the FRA, but doing so would not suspend or change the law.  On the contrary, enforcement measures and discretion could be changed by changing the law; but the law cannot be changed by suspending or changing enforcement.
...
 

Technically they would not suspend enforcement, but they would use different enforcement tools available to regulatory agencies.  When the police stop your car for a burned out tail light, they don't usually impound your car, or even give you a ticket.  They often give you a warning, with a deadline to fix the tail light, the fine suspended unless you miss the deadline.  As I have mentioned before, regulators may use administrative law instruments such as consent agreements/decrees with a schedule to achieve compliance with appropriate deadlines, and stipulated penalties for missing deadlines.  Of course, it would be better if the senate language (less than a page) to extend the PTC ddeadline was approved, which would codify a procedure similar to the above, but as a regulatory procedure rather than an enforcement procedure.

  • Member since
    August 2006
  • From: Suburbs of New York
  • 23 posts
Posted by tommyboy on Saturday, September 19, 2015 1:59 PM

For those of us old enough to have who lived through the 1970s there is a precedent for a President using his powers to keep the trains rolling. President Nixon did it at least twice I think, both times when Penn Central was about to shutdown. Once it was when PC was about to willingly take a strike in order to force some work rule changes and the second time was when PC was out of money and threatening to shut down.

 

On the latter occasion I recall the PC's bankruptcy trustee telling Congress that, "Our employees will not continue to work once they are no longer being paid and, realistically, I don't see why they should." Smile

  • Member since
    November 2005
  • 4,190 posts
Posted by wanswheel on Saturday, September 19, 2015 11:47 AM
Without knowing of particular laws which may give the President power to legalize non-PTC trains by executive order, one thing seems clear enough to me. He has Constitutional power to call Congress back to work if they fail to solve this obvious major problem before they adjourn for the holidays.
“he may, on extraordinary Occasions, convene both Houses, or either of them…”
  • Member since
    August 2006
  • From: Suburbs of New York
  • 23 posts
Posted by tommyboy on Saturday, September 19, 2015 11:31 AM

dehusman
The railroads and the FRA have been discussing the need for an extension and the implications of not having an extension for years. 

That certainly seems to be the case. One of the most contenious issues has been with the required bandwidth to put in PTC. The railroads have had serious difficulties acquiring adequate frequencies and have been criticizing Congress and the FRA for several years for doing little to help the railroads acquire it (or pay for it). This is from the AAR website (and has been up for a while):

To support interoperability, the rail industry is adopting the use of 220 MHz radio channels as a common means of wireless data communication. Specific allocation of channels for PTC has not occurred and railroads have had a difficult time acquiring the necessary amount of spectrum on the open market, particularly in metropolitan areas.

https://www.aar.org/policy/positive-train-control

The AAR also issued a press release Wednesday citing a recent Goverment Accounting Office (GAO) report that supports the rail industry's contention that the December 31, 2015 deadline is not realistic:

 

The GAO review examined the rail industry's PTC implementation progress and challenges, and identified the complexities associated with developing, installing and testing the technology.

"The GAO report reinforces the freight rail industry's contention that PTC is an extremely complex technology that requires more time to install and safely test," Hamberger said. "Freight rail operators have always contended that the Congressionally mandated 2015 deadline for having PTC fully functional and being used coast to coast by passenger and freight rail alike was not realistic.

 

If this conversation was taking place on December 19th -- instead of September 19th -- I'd be worried. There's still plenty of time to resolve this.

 

 

  • Member since
    January 2014
  • 8,221 posts
Posted by Euclid on Saturday, September 19, 2015 9:21 AM
wanswheel
The law would stand unchanged by an FRA decision not to enforce it. The decision needs to be an executive order to disregard the deadline provision, citing the President’s duty to maintain orderly commerce for the good of the country.
 
In watching the Sarah Feinberg confirmation, I noticed that she was repeatedly questioned about what she intended to do about the PTC deadline.  The tone of these questions was somewhat anxious and demanding; with the questioner realizing that the impasse is heading us into an economic crisis.  But Ms. Feinberg repeatedly responded that she does not have the power to do anything about the deadline. 
This is rather revealing of the confusion that exists over why this shutdown crisis has emerged and what needs to be done about it. 
I do not know if Congress has enough time to change the law.  The change seems simple enough; however, the law is not simple.  Thus, even a simple change might take a lot of time to make it compatible with a very complex law.  The simple change sought is to extend the deadline, but there is obvious angst over losing ground in the safety enhancement of PTC. 
So if the deadline has to give, they don’t want to give any more than absolutely necessary.  This leads to plans to deal with each railroad individually on a case by case basis to tailor their extension to just what is needed, and no more.  I cannot imagine that getting done in time to avoid the shutdown crisis.    
I also do not know if Obama could solve the problem with an executive order.  What would such an order say?  It would either have to change the law to extend the deadline, or simply void the law.      
  • Member since
    November 2005
  • 4,190 posts
Posted by wanswheel on Saturday, September 19, 2015 1:59 AM
The law would stand unchanged by an FRA decision not to enforce it. The decision needs to be an executive order to disregard the deadline provision, citing the President’s duty to maintain orderly commerce for the good of the country.
  • Member since
    January 2014
  • 8,221 posts
Posted by Euclid on Friday, September 18, 2015 6:39 PM
wanswheel
All right, the railroads’ fear of lawsuits is not exaggerated and certainly engineers can’t be breaking the law. The law has to be changed. But if it isn’t, wouldn’t a government decision to suspend enforcement effectively suspend the law as well, for purposes of using it to sue a railroad or its employee?
 
Suspending enforcement is a prerogative of the FRA, but doing so would not suspend or change the law.  On the contrary, enforcement measures and discretion could be changed by changing the law; but the law cannot be changed by suspending or changing enforcement.
So the law would stand and would be violated even if the FRA decided to not fine the railroads for operating out of compliance after the deadline.  Also, such operation would still be deemed more dangerous than necessary even if no fines were levied.  I speculate that the relative increase in danger would drive up liability in the case of an accident.  If so, that would include the higher cost of liability in addition to violating the law as two reasons why railroads will shut down despite an FRA decision to not levy fines.  
  • Member since
    May 2003
  • From: US
  • 25,292 posts
Posted by BaltACD on Friday, September 18, 2015 6:16 PM

diningcar

BS, just change the law. Why is this so fifficult?????

It's Congress and they make everything fifficult, which is even worse than difficult!

Never too old to have a happy childhood!

              

  • Member since
    December 2006
  • 1,754 posts
Posted by diningcar on Friday, September 18, 2015 5:25 PM

BS, just change the law. Why is this so fifficult?????

  • Member since
    November 2005
  • 4,190 posts
Posted by wanswheel on Friday, September 18, 2015 3:52 PM
All right, the railroads’ fear of lawsuits is not exaggerated and certainly engineers can’t be breaking the law. The law has to be changed. But if it isn’t, wouldn’t a government decision to suspend enforcement effectively suspend the law as well, for purposes of using it to sue a railroad or its employee?
  • Member since
    January 2014
  • 8,221 posts
Posted by Euclid on Friday, September 18, 2015 2:57 PM

dehusman
 
Euclid
I do believe that the FRA was indeed blindsided by the sudden development that the railroads intend to shut down because the law requires it.

 

You tend to think everything is a "surprise" to other groups because its a surprise to you.  The railroads and the FRA have been discussing the need for an extension and the implications of not having an extension for years.  The vast majority of people who work for the FRA have worked for the railroads.  Even if they didn't talk, the FRA would have an idea of how railroads think and would know what the options the railroads would have.  There is no advantage to the railroads or the FRA to engage in "gotcha". 

 

It has nothing to do with me.  I am not sure to what extent the FRA was blindsided.  It may be more accurate to say that Congress was.  In any case, while the government and railroads may have been discussing this for years, the government is in the hot seat now, and I doubt they would be there had they seen it coming. 

I have no idea what you mean when you say there is no advantage to the railroads or the FRA to engage in "gothcha."

  • Member since
    September 2003
  • From: Omaha, NE
  • 10,621 posts
Posted by dehusman on Friday, September 18, 2015 2:44 PM

Euclid
I do believe that the FRA was indeed blindsided by the sudden development that the railroads intend to shut down because the law requires it.

You tend to think everything is a "surprise" to other groups because its a surprise to you.  The railroads and the FRA have been discussing the need for an extension and the implications of not having an extension for years.  The vast majority of people who work for the FRA have worked for the railroads.  Even if they didn't talk, the FRA would have an idea of how railroads think and would know what the options the railroads would have.  There is no advantage to the railroads or the FRA to engage in "gotcha". 

Dave H. Painted side goes up. My website : wnbranch.com

  • Member since
    January 2001
  • From: Atlanta
  • 11,971 posts
Posted by oltmannd on Friday, September 18, 2015 2:08 PM

wanswheel
 Railroads crave revenue more than they fear lawsuits. 
 

I don't think so.  Fear of lawsuits is pretty large...

-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 Friday, September 18, 2015 2:05 PM

Euclid
 
wanswheel
There’s no question the fines are at the discretion of the Secretary of Transportation, in the language of the law. “The Secretary is authorized to assess civil penalties…” Without the fines, obeying to the letter the 2008 law just to prove it’s their policy would be senseless. In the immortal words of Deep Throat, follow the money. Railroads crave revenue more than they fear lawsuits. 
 
 
Well, there are three possible reasons to shut down non-compliant operations after the deadline.

1)   To avoid the fines.

2)   To avoid the extra liability in case of an accident with non-compliant operations.

3)   To avoid breaking the law.

 
Railroads have cited all three reasons for their intent to shut down.  Are you saying that waiving the fines would be sufficient to convince the railroads to not shut down?
If that were sufficient, what are they waiting for?  Obama has said that he is in favor of extending the deadline because it cannot be met.  If the FRA has the sole discretion as to whether to levy fines, but will announce an intent to not levy fines; why would railroads go ahead and operate under the default presumption that they will be fined?
 

#1 is the smallest problem.  It's #2 and #3 that are the real sticking points.  

Think of the position you'd put an engineer in telling him to take a non-PTC equipped train out on "day one".  Locomotive engineers can be liable for their negligence in an accident.  Managment can't order people to break the law.  

The legal deadline has to be extended somehow and the "fine" has to become some sort of non-compliance fee or tax, or a fine for "lack of progress".    

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

  • Member since
    January 2014
  • 8,221 posts
Posted by Euclid on Friday, September 18, 2015 12:57 PM
wanswheel
There’s no question the fines are at the discretion of the Secretary of Transportation, in the language of the law. “The Secretary is authorized to assess civil penalties…” Without the fines, obeying to the letter the 2008 law just to prove it’s their policy would be senseless. In the immortal words of Deep Throat, follow the money. Railroads crave revenue more than they fear lawsuits. 
 
Well, there are three possible reasons to shut down non-compliant operations after the deadline.

1)   To avoid the fines.

2)   To avoid the extra liability in case of an accident with non-compliant operations.

3)   To avoid breaking the law.

 
Railroads have cited all three reasons for their intent to shut down.  Are you saying that waiving the fines would be sufficient to convince the railroads to not shut down?
If that were sufficient, what are they waiting for?  Obama has said that he is in favor of extending the deadline because it cannot be met.  If the FRA has the sole discretion as to whether to levy fines, but will announce an intent to not levy fines; why would railroads go ahead and operate under the default presumption that they will be fined?
  • Member since
    November 2005
  • 4,190 posts
Posted by wanswheel on Friday, September 18, 2015 12:18 PM
There’s no question the fines are at the discretion of the Secretary of Transportation, in the language of the law. “The Secretary is authorized to assess civil penalties…” Without the fines, obeying to the letter the 2008 law just to prove it’s their policy would be senseless. In the immortal words of Deep Throat, follow the money. Railroads crave revenue more than they fear lawsuits. 
  • Member since
    January 2014
  • 8,221 posts
Posted by Euclid on Friday, September 18, 2015 11:23 AM
wanswheel
 In the absence of an extension it’s still entirely up to the President whether railroads will be fined or not. There's no way he's so dumb he's going to allow a railroad crisis to ruin his last year in office.
So what will he do about that?  What can he do?  He may have the authority to withhold the fines, but the railroads are indicating that they will shut down due to the need to abide by the law, and not necessarily to avoid the fines.  Obama cannot change the law, so what can he do to prevent a railroad crisis from ruining his last year in office?
  • Member since
    January 2014
  • 8,221 posts
Posted by Euclid on Friday, September 18, 2015 11:16 AM

Randy,

I do believe that the FRA was indeed blindsided by the sudden development that the railroads intend to shut down because the law requires it.  The FRA was looking at the law too narrowly and focused only on the fact that the law allows fines.  The FRA thought that had the railroads in a box, but the sudden prospect of the mandate forcing a shutdown has placed the FRA into the same box they have the railroads in. 

 

  • Member since
    November 2005
  • 4,190 posts
Posted by wanswheel on Friday, September 18, 2015 10:59 AM
It’s a poker game with 3 players, the Democratic Administration, the Republican Congress and the apolitical railroads. Sarah is playing Obama’s hand, insisting she intends to issue fines Jan. 1, but she doesn’t really know because her boss hasn’t told her yet. She’s gladly unaware of his plans, the easier to testify under oath without spilling any beans. In the absence of an extension it’s still entirely up to the President whether railroads will be fined or not. There's no way he's so dumb he's going to allow a railroad crisis to ruin his last year in office.
  • Member since
    June 2004
  • From: roundhouse
  • 2,747 posts
Posted by Randy Stahl on Friday, September 18, 2015 10:39 AM

The FRA is staffed with more than just Sara. Does she not speak to her staff ?

  • Member since
    December 2006
  • 1,754 posts
Posted by diningcar on Friday, September 18, 2015 10:28 AM

Why bother this political appointee who has absolutely no clue with these questions?

 

You, both houses of Congress wrote the law. So instead why not say to her that we will fix it and relieve you of any stress. If we did that you, political appointee, may go on with more simple things.

  • Member since
    June 2004
  • From: roundhouse
  • 2,747 posts
Posted by Randy Stahl on Friday, September 18, 2015 10:21 AM

I cannot imagine the FRA being that stupid not being able to predict possible outcome. Blind sided by the possibility ?? WTF !

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