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Solving the PTC Deadline Problem

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Posted by dakotafred on Sunday, September 13, 2015 7:55 PM

tommyboy

I think that realistically the likelihood of an industry-wide shutdown is very remote. I suspect, especially with the Senate already having passed legislation to extend the deadline three years (and the House due to hold hearings next month), in part the railroads are using the specter of a nationwide shutdown as a way to put  pressure on Congress. Anyone who was around in the 1970s knows the federal government does not like having the railroad industry shutdown, regardless of the issues involved. A shutdown does incredible damage to the national economy and must be avoided if at all possible. 

 
Sums it up. The PTC legislation was an emotional reaction to one accident that let Congress pretend it can "do something." It could have done the same thing in response to any number of other accidents in the past ... but didn't, because it has, or is supposed to have, bigger fish.
 
This is no urgent national priority. If it were, you can be sure Congress would have been unable to get its act together.
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Posted by BaltACD on Sunday, September 13, 2015 8:33 PM

It seems, for the past decade or more, Congress has prided itself in writing unrealistic and in many cases unenforceable legislation.  Congress (lobbyists) write the bills - they have no idea of the mechanics of applying and enforcing the legislation, let alone what needs to be done for one to comply.

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Posted by Semper Vaporo on Sunday, September 13, 2015 10:12 PM

I remember a single-pane comic in a pocket-sized book of such comics my brother had when I was a kid (60 years ago... just to put it in context).  It was was of two men in pinstriped suits and fedora hats, carrying briefcases, walking away from the Capitol building... one says to the other:

"I'd sure hate to have to go out and make a living under the laws we just passed."

Semper Vaporo

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Posted by Euclid on Monday, September 14, 2015 9:45 AM
tommyboy

I think that realistically the likelihood of an industry-wide shutdown is very remote. I suspect, especially with the Senate already having passed legislation to extend the deadline three years (and the House due to hold hearings next month), in part the railroads are using the specter of a nationwide shutdown as a way to put  pressure on Congress. Anyone who was around in the 1970s knows the federal government does not like having the railroad industry shutdown, regardless of the issues involved. A shutdown does incredible damage to the national economy and must be avoided if at all possible. 

 
I don’t know if a shutdown is remote.  It depends on whether an extension is granted, and Congress seems very reluctant.  I agree that in the past, the government would act to prevent or end a shutdown.  They could prevent one in this case by granting an extension. 
You say the railroads are using the threat of a nationwide shutdown to pressure congress into granting an extension.  While that is likely, the railroads sure don’t want it to seem that way.  They are walking a fine line by taking the moral high ground of abiding by the law as a means to shield themselves from the appearance of threatening Congress.
So far, it is not clear whether congress accepts this point about following the law as a justification for shutting down.  If they feel it is being used to threaten them, they might not accept it.  It is a delicate proposition to threaten Congress just enough to get what you want without going so far as to embarrass them in the eyes of the public. 
If Congress simply is forced to back down and grant an extension, you can bet that they will not admit that the reason is to correct their own mistake.  Instead, they will heap blame upon the industry for not complying with the mandate.  Most of the public will gladly accept that explanation.  So the railroad industry will be left with an extension and a huge black eye. 
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Posted by dehusman on Monday, September 14, 2015 10:02 AM

If Congress simply is forced to back down and grant an extension, you can bet that they will not admit that the reason is to correct their own mistake.  Instead, they will heap blame upon the industry for not complying with the mandate.  Most of the public will gladly accept that explanation.  So the railroad industry will be left with an extension and a huge black eye. 

Congress, more specifically the House, will grant the extension.  Nothing will happen that the public can detect.  It will be a 15 sec update on the evening news, quickly followed by a 5 min piece on the latest bizzare quote from the Donald. The "public" won't understand or care.  Life will go on.  PTC will be delployed later rather than sooner.

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Posted by wanswheel on Monday, September 14, 2015 11:39 AM
The late former Rep. James L. Oberstar of Minnesota
 
 
spoke about PTC on the radio in 2013. (Slide the audio to about the 2 minute mark.)
 
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Posted by ALEXANDER WOOD on Monday, September 14, 2015 5:18 PM

tommyboy
That was Helena Williams' point: the technology is not off-the-shelf, it can't be just 'ordered.' It has to be custom designed for each carrier. There is an immense amount of work that goes into designing positive train control systems and, unlike one-hundred years ago, most railroads (especially LIRR) no longer have the engineering staff available to do this. The work has to be bid out and there is a lengthy procurement process that must be followed. There has to be testing and it has not always gone smoothly. I've been following LIRR's efforts via the monthly meeting minutes they post on the MTA website and they have been working at implementing PTC for several years now. It's very complex.

Lame. That's a valid argument for the freight railroads, where no system existed that would work for them at scale. For LIRR, maybe no one was actually making ACSES equipment in 2008, but the system existed, and it's proven to work. I see trains operating under it almost every day. Changing a few signal aspects for LIRR's bizarre non-standard signalling system, that, like everything else on the railroad, is arse-backwards, shouldn't be THAT hard.

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Posted by tommyboy on Monday, September 14, 2015 5:28 PM

One idea I would like to correct is, that there is a possibility that the railroad industry as a whole (or a big part of it) may still get PTC in place before the December 31, 2015 deadline. That's not going to happen. In discussing this on another message board two months ago, a member of Amtrak's engineering staff said, only three carriers are currently on schedule to be fully PTC-compliant by the year end deadline.

One is Amtrak:

We remain on schedule to complete the full activation of PTC in the Northeast Corridor—including Frankford Junction—in accordance with the federal deadline of December 31, 2015.

http://blog.amtrak.com/2015/05/commitment-passengers-employees-safety-positive-train-control/

Another is southern California's MetroLink (which is already PTC-compliant and has been since this past June):

Metrolink launched Positive Train Control (PTC) in Revenue Service Demonstration (RSD) across the entire 341-mile network the agency owns earlier this month [June 2015]. With this latest accomplishment, Metrolink becomes the first railroad in the nation to have PTC running during regular service on all of its hosted lines and remains on track to become the nation’s first passenger rail system to have a fully operational, interoperable, and certified PTC system in place.

  http://www.metrolinktrains.com/news/news_item/news_id/983.html

 And Septa. From their website:

SEPTA is positioned to successfully implement PTC in compliance with the law, barring any unforeseen technical challenges or concerns that arise during testing.

http://www.septa.org/media/short/2015/07-08.html

If any other railroads or commuter agencies are predicting they will meet the federal deadline I'd be interested in knowing it, but I don't think there are any others.

 

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Posted by MidlandMike on Monday, September 14, 2015 8:58 PM

The PTC "extension" passed by the Senate was to give the administration the ability to extend the deadline by up to 3 years.  It was done at the request of the administration.  That would be the appropriate place for it, as the FRA could work out a timetable with each RR for PTC initiation.  Each side could sign consent agreements with stipulated penalties for missing the agreed upon deadlines.  This would also get the legislatures off the hook.  The problem is that the PTC issue was just a small part of the Senate bill which was a transportation package.  They sent it to the House, but Congress has not passed a transportation bill in many years, choosing instead to pass continuing resolutions to keep current laws in effect.

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Posted by tommyboy on Tuesday, September 15, 2015 4:12 PM

Are we sure the bill to extend the PTC deadline to at least 2018 is part of a major transportation bill? My understanding is that it is not. The bill the Senate passed, S. 650, introduced by Sen. Roy Blunt (R. MO), is specific to the Positive Train Control deadline. This is how the bill reads (in part):

- S. 650: Railroad Safety and Positive Train Control Extension Act-
Revises the railroad safety risk reduction program.
Extends from December 31, 2015, to December 31, 2020, the deadline for submission to the Secretary of Transportation by each Class I railroad carrier and each entity providing regularly scheduled intercity or commuter rail passenger transportation of a plan for implementing a positive train control (PTC) system on certain of its tracks.

 
The Association of American Railroads explains it this way:
Congress should provide a responsible deadline extension to 2018 to deploy all the necessary equipment and outfit the locomotive fleet. Then, an additional two years are needed for testing and validation that the nationwide system is properly working in all regions. The adjusted timeline would give railroads the critical time needed to test, approve and install the highly complex system necessary for the safe and correct use of this sophsticated technology.​
 
It sounds like there are some semantics at work; the "deadline" is extended to Dec. 31, 2018 but then there will be a two year period of testing and validation and THEN PTC will be fully in place. Confusing? Remember this is Congress!
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Posted by MidlandMike on Tuesday, September 15, 2015 9:26 PM

tommyboy

Are we sure the bill to extend the PTC deadline to at least 2018 is part of a major transportation bill? My understanding is that it is not. The bill the Senate passed, S. 650, introduced by Sen. Roy Blunt (R. MO), is specific to the Positive Train Control deadline...

Apparently that bill was folded into the 1000 page transportation bill:

http://www.nytimes.com/2015/07/24/us/senate-to-consider-delaying-rail-safety-mandate.html?_r=0

The bill also includes things like continuing the Export Import Bank, which is opposed by many in Congress.  Plus Congress has many other critical bills in the final months of 2015.

http://www.csmonitor.com/USA/2015/0730/Senate-passes-transportation-bill

 

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Posted by tree68 on Tuesday, September 15, 2015 10:39 PM

And  that's a problem with Congress any more.  They can't seem to act on a bill on its own merits - they have to try to load unpopular items in with popular items in hopes the unpopular stuff will pass along with the popular stuff.  

Taken by itself, and on its own merits, extending PTC would seem to be a no-brainer, given what's been related here regarding the difficulties the project is facing.   But, no...

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Posted by oltmannd on Wednesday, September 16, 2015 6:53 AM

tommyboy
Are we sure the bill to extend the PTC deadline to at least 2018 is part of a major transportation bill? My understanding is that it is not.

http://www.politico.com/tipsheets/morning-transportation/2015/09/150915-pro-morning-transpo-210209

It's a bit of a mess....

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Posted by tommyboy on Thursday, September 17, 2015 7:33 PM

Don I appreciate the link you provided. Very interesting. A couple of quotes:

Our Lauren Gardner and Pro Agriculture’s Bill Tomson report that “lawmakers' preferred solution — sticking an extension into a long-term transportation bill — won't happen in time...Senate Commerce Chairman John Thune didn't dismiss adding an extension to a short-term highway and transit bill, which is due by the end of October.

Thune said, "Because otherwise, if we don't get this addressed before the end of the year, we're going to have a pretty big disaster on our hands."...Railroads have tried hard in recent days to convey just how sizable that disaster would be.

 

One way or another I guess we'll find out.

 
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Posted by BaltACD on Thursday, September 17, 2015 8:39 PM

Congress has had a history of snatching defeat from the jaws of victory.

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Posted by tree68 on Thursday, September 17, 2015 10:19 PM

Hey, Congress.  We need one little law passed (or resolution, or whatever it takes).  Doesn't need to be part of another law, or resolution, or anything else.

Just a little ditty with the appropriate verbiage to extend the deadline.  Might be all of one page - easy reading.

Probably take five minutes in each house.

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Posted by BaltACD on Friday, September 18, 2015 7:57 AM

tree68

Hey, Congress.  We need one little law passed (or resolution, or whatever it takes).  Doesn't need to be part of another law, or resolution, or anything else.

Just a little ditty with the appropriate verbiage to extend the deadline.  Might be all of one page - easy reading.

Probably take five minutes in each house.

Nothing takes 5 minutes in Congress.  Can you imagine how long it would take for them to agree to a place to go for lunch?

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Posted by Euclid on Friday, September 18, 2015 9:20 AM
I have been watching the video of the Sarah Feinberg confirmation in which a lot of time is devoted to the discussion of the PTC mandate.
Ms. Feinberg cites both the failure to achieve the desired safety improvement of PTC by the deadline and the shutdown of service as being two equally bad outcomes of failing to meet the deadline.
She seems somewhat ambivalent on whether the law requires railroads to shutdown service if not compliant after the deadline.  She refers to the railroads making the “choice” of whether or not to comply with the law by shutting down.  This indicates to me that the FRA did not anticipate a shutdown, and is justifying that lack of anticipation by the premise that a shutdown is a choice of the railroads, and so there was no reason to anticipate it.    
I have not watched the whole thing yet, so maybe there is more on this point of why the FRA seems blindsided by the prospect of a shutdown.  
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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 !

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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.

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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 ?

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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.
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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. 

 

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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?
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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. 
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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?
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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".    

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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...

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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". 

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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."

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