Solving the PTC Deadline Problem

[BaltACD]

What I find interesting is the Congress in 2008 decreed implementation by Dec. 31, 2015 - when their plans for upgrading the Air Traffic Control System was concieved 5 years earlier and has a anticipated completion date well beyond 2015.

wikipedia

The Next Generation Air Transportation System (NextGen) is a new National Airspace System due for implementation across the United States in stages between 2012 and 2025.^[1] NextGen proposes to transform America’s air traffic control system from a ground-based system to a satellite-based system. GPS technology will be used to shorten routes, save time and fuel, reduce traffic delays, increase capacity, and permit controllers to monitor and manage aircraft with greater safety margins.^[2] Planes will be able to fly closer together, take more direct routes and avoid delays caused by airport “stacking” as planes wait for an open runway.^[3] To implement this, the Federal Aviation Administration (FAA) will undertake a wide-ranging transformation of the entire United States air transportation system. This transformation has the aim of reducing gridlock, both in the sky and at the airports. In 2003, the U.S. Congress established the Joint Planning and Development Office (JPDO) to plan and coordinate the development of the system.

[wanswheel]

Excerpt from House bill introduced Oct. 20 (page 504)

 

http://transportation.house.gov/uploadedfiles/shuste_044_xml.pdf

Section 20157 of title 49, United States Code, is amended… by striking “18 months after the date of enactment of the Rail Safety Improvement Act of 2008” and inserting “90 days after the date of enactment of the Positive Train Control Enforcement and Implementation Act of 2015”…

 

Excerpt from Politico, Oct. 21

http://www.politico.com/tipsheets/morning-transportation#ixzz3pDdmPjCl

Lawmakers look now for the surest path to the president’s desk for an extension of the positive train control deadline, since House and Senate negotiators just settled on compromise language palatable enough for both chambers. They’re so far undecided, though, on whether to hold out in hopes of moving the PTC fix within a multiyear highway and transit plan or to pass it before then with the short-term patch they’ll need to clear before transportation policy expires on Oct. 29. The variables to consider: how quickly they can actually get a multiyear infrastructure investment proposal through both chambers and whether naysayers will block a short-term policy extension if it includes PTC provisions.

[chutton01]

So this may become the solution, except they plan to attach it to the Transportation bill as opposed to stand alone legislation, so who knows?
Lawmakers agree to extend automated train deadline by 3 years

The agreement calls for moving a Dec. 31 deadline for railroads to install an automated train navigation system known as Positive Train Control (PTC) to the end of 2018 at the earliest
...
Under the new agreement, railroads would have an extra three years to work on the automated train conversion. They will also have the option of requesting an extra two years to work on the installation if they submit plans for doing the work by Dec. 31, 2018. The requests would have to be approved by the Department of Transportation on a case-by-case basis.

 

 

[BaltACD]

Paul_D_North_Jr

blue streak 1 wrote above, plus his 1st 2 paragraphs:

"Guess that this is much of the same problem of programing PTC ?"

Geez, I had no idea that the FAA / ATC problems were so similar to the FRA / PTC ones.

- Paul North.

Never realized that creating something that didn't exist would ever miss a deadline date for industrywide implementation! [/sarcasm]

[Paul_D_North_Jr]

blue streak 1 wrote above, plus his 1st 2 paragraphs:

"Guess that this is much of the same problem of programing PTC ?"

Geez, I had no idea that the FAA / ATC problems were so similar to the FRA / PTC ones.

- Paul North.    

[blue streak 1]

Norm48327

 Typical for the FAA. Like other federal agencies, they grossly underestimate costs and set impractical deadlines. Sound like they're in cahoots with the FRA? From the perspective of someone who made his living in avaition for the last thirty years it sounds plausable.

 

Agree 100% with Norm.  The only project that even came close was the TCAS system  ( aircraft based collision avoidance system ).  It only took about twice as long and the incremental approach by the contractors probably worked the best.  TCAS2 saved my bacon a couple times, once in non radar enviroment where next gen would not have worked.  It scares us very much that all  the eggs are being put into the GPS basket.

Next Gen ATC ( air traffic control ) has tried to do all things as once.  Instead of the incremental approach that has been overlaid the current system which has worked to some extent.  The revision of NEC air routes took over 3 years to completely implement and still has a few gliches handled by very competent air traffic controllers and TCAS.

 

It is a matter that the experts who guide and fly aircraft are not top flight programers. So when they speak up to the programers trying to invent a different wheel they are ignored.  The programers know better. They do not realize we are learning something new every day.  As statement made by many of the above is "  I've only been in the flying business  ...  years.  (20+) I have never seen that before ".

 

Guess that this is much of the same problem of programing PTC ?  What happens when there is a GPS failure ?

 

[Norm48327]

BaltACD

Haven't the Feds been trying to 'upgrade' the Air Traffic Control system for the past 20 years or more - with a notable lack of success?

The hurrier they go the behinder they get. Typical for the FAA. Like other federal agencies, they grossly underestimate costs and set impractical deadlines. Sound like they're in cahoots with the FRA? From the perspective of someone who made his living in avaition for the last thirty years it sounds plausable.

[Euclid]

wanswheel

Excerpt from Politico, Oct. 20

Although there’s been no news of a deal, lawmakers and aides in both chambers are said to be trying to negotiate compromise language for extending the deadline that could be added to the multiyear highway and transit bill House T&I is set to mark up on Thursday.

 

So where is the need for compromise in the negotiation of compromise language?

[BaltACD]

Paul_D_North_Jr

Meanwhile, over in the airline industry (following are just excerpts from a considerably longer and more complicated article).  Note the similarities with railroad PTC, esp. in the 2nd paragraph quoted below. 

"FAA to Let Airlines Seek to Delay Navigation Upgrades

The move partly reflects strategy to retain key airline support for more complex, expensive traffic-control improvements

Federal aviation regulators are ready to exempt numerous U.S. airlines from a requirement to make certain satellite-navigation upgrades by 2020, a delay that may further complicate air-traffic control modernization. . . .

Meanwhile, the agency is sticking with the 2020 deadline for a broader and more powerful technology, known as ADS-B Out, intended to provide more accurate and reliable speed, altitude and other position data to ground stations and controllers nationwide."

From the Wall Street Journal, by Andy Pasztor, updated Oct. 16, 2015 [not sure of original print edition date - not more than a day or two before this - PDN], at:

 http://www.wsj.com/articles/faa-to-let-airlines-seek-to-delay-navigation-upgrades-1445017417

Not sure if this article is behind a 'paywall' or not, hence the above quotations. 

Draw you own conclusions.

- Paul North.

Haven't the Feds been trying to 'upgrade' the Air Traffic Control system for the past 20 years or more - with a notable lack of success?

[Paul_D_North_Jr]

Meanwhile, over in the airline industry (following are just excerpts from a considerably longer and more complicated article).  Note the similarities with railroad PTC, esp. in the 2nd paragraph quoted below. 

"FAA to Let Airlines Seek to Delay Navigation Upgrades

The move partly reflects strategy to retain key airline support for more complex, expensive traffic-control improvements

Federal aviation regulators are ready to exempt numerous U.S. airlines from a requirement to make certain satellite-navigation upgrades by 2020, a delay that may further complicate air-traffic control modernization. . . .

Meanwhile, the agency is sticking with the 2020 deadline for a broader and more powerful technology, known as ADS-B Out, intended to provide more accurate and reliable speed, altitude and other position data to ground stations and controllers nationwide."

From the Wall Street Journal, by Andy Pasztor, updated Oct. 16, 2015 [not sure of original print edition date - not more than a day or two before this - PDN], at:

 http://www.wsj.com/articles/faa-to-let-airlines-seek-to-delay-navigation-upgrades-1445017417

Not sure if this article is behind a 'paywall' or not, hence the above quotations. 

Draw you own conclusions.

- Paul North.

[wanswheel]

Excerpt from Politico, Oct. 20

Although there’s been no news of a deal, lawmakers and aides in both chambers are said to be trying to negotiate compromise language for extending the deadline that could be added to the multiyear highway and transit bill House T&I is set to mark up on Thursday.

[blue streak 1]

Septa hits a bump trying to get PTC to work.  Silverliner 4s OK -5s not.

http://www.philly.com/philly/blogs/in-transit/In-Transit-Begins.html

 

 

[Euclid]

Thanks Larry.  That answers my questions.  As I expected, the case by case extension does not apply to the basic three year extension.  Instead, it applies to the additional extension of up to two years after the initial three year extension runs its course. 

The reason I wanted clarification is that I interpreted Midland Mike’s comment to mean that the basic three year extension would be on a case by case basis since that is the extension that would be the issue of Obama stepping in to defuse the shutdown crisis.  Also, he made no distinction between the initial three year extension and the following two one year extensions.  In any case, he was referring to what the Senate sent to the House, and not to Representative Shuster’s bill. 

[tree68]

Euclid

Is that what the three year extension of the Shuster bill will do? 

Here's two stories that explain the Shuster bill pretty well.

From the American Journal of Transportation:

Shuster-DeFazio offer sensible PTC extension bill

By: AJOT | Oct 01 2015 at 11:26 AM | Intermodal  

Washington, DC - Edward Wytkind, president of the Transportation Trades Department, AFL-CIO (TTD), issued the following statement on a bipartisan bill that extends the deadline for implementation of positive train control (PTC) technology:

“TTD supports bipartisan legislation – introduced today by the leadership of the Transportation and Infrastructure Committee – that extends the statutory deadline for railroads to implement Positive Train Control (PTC) technology on approximately 60,000 miles of track. While we have long called for implementation of this life-saving technology by the December 31st deadline as mandated by Congress in 2008, it has become increasingly clear that the vast majority of railroads will not meet this requirement. Unless Congress takes action to extend the deadline, a number of freight and passenger rail carriers have warned that they will shut down operations on January 1st rather than risk missing a legal deadline.

“The legislation, authored by Rep. Bill Shuster (R-PA), the chairman of the committee, and Rep. Peter DeFazio (D-OR), the committee’s ranking member, provides a three-year extension for the railroads to complete implementation of PTC, with the limited availability of two additional extensions granted on a case-by-case basis. We believe this extension is sensible as it holds the railroads accountable to a hard deadline for implementing PTC and it forces them to demonstrate that extraordinary circumstances exist in any request for additional extensions. The Shuster-DeFazio bill is an improvement over the PTC provisions included in the Senate-passed surface transportation bill which requires initial activation, not implementation, of PTC systems at the end of a three-year extension.

 

“As a PTC extension is enacted, Congress must ensure that commuter railroads receive the federal funding needed to implement this technology. The fact that PTC will be postponed for a minimum of three years on many freight and passenger railroads reinforces the need for Congress and federal regulators to advance long overdue rail safety reforms more broadly. PTC is an important technology that will save lives but there are other sensible measures that will make rail transportation safer across America.”

This one is from Shuster's office:

Committee Leaders Introduce Positive Train Control Deadline Extension

 

Washington, DC, Sep 30 | Jim Billimoria, Justin Harclerode [phone] | 0 comments

f t # e

Transportation and Infrastructure Committee leaders today introduced bipartisan legislation to extend the deadline for U.S. railroads to implement Positive Train Control technology.

Congress mandated that freight railroad lines carrying certain toxic materials, passenger railroads, and commuter railroads implement Positive Train Control technology by December 31, 2015.  However, most freight and commuter railroads have reported that they will not be able to meet the deadline, and require more time to complete implementation.  Recently, a Government Accountability Office study on the issue confirmed that railroads have faced a number of challenges in implementing the complex technology, and most will not be able to meet the deadline.

“Completion of the Positive Train Control mandate by the end of the year is not achievable, and extending the deadline is essential to preventing significant disruptions of both passenger and freight rail service across the country,” saidTransportation and Infrastructure Committee Chairman Bill Shuster (R-PA), one of the sponsors of the Positive Train Control Enforcement and Implementation Act of 2015 (H.R. 3651).  “Railroads must implement this important but complicated safety technology in a responsible manner, and we need to give them the necessary time to do so.”

“This extension will ensure our nation’s railroads can continue to function and hold them accountable to implement necessary safety measures on a public timeline,” said Railroads, Pipelines, and Hazardous Materials Subcommittee Chairman Jeff Denham (R-CA), also a sponsor of the bill.  “Passenger and freight railroads have stated they can’t meet the current deadline and will shut down later this year.  This includes ACE in my district.  We must protect communities across the country from a railroad shutdown, which would damage local economies nationwide.”

Without an extension, freight railroads will be forced to suspend shipments of certain chemicals, including some used in treating drinking water and in fertilizers; commuter railroads will need to cease operations, significantly impacting commutes in major metropolitan regions; and all Amtrak service outside of portions of the Northeast Corridor will be suspended.

The Federal Railroad Administration and the Government Accountability Office have also previously recommended extending the Positive Train Control deadline.

The Positive Train Control Enforcement and Implementation Act of 2015 extends the deadline to fully implement the technology to the end of 2018, provides limited authority for the U.S. Department of Transportation Secretary to extend the deadline beyond 2018 if railroads demonstrate they are facing continued difficulties in completing the mandate, but have made every effort to install Positive Train Control as soon as possible, and requires railroads to complete progress reports on implementation.

Click here to read the Positive Train Control Enforcement and Implementation Act of 2015.

I think these will answer your questions.

[Euclid]

MidlandMike

 

Euclid

 

For the prospect of breaking the PTC logjam with an executive order, I have no idea which side President Obama would come down on.  Would he order a deadline extension in agreement with the railroad industry?  Or would he hold their feet to the fire and order that the current deadline be enforced when it arrives?

 

 

 

 

 

As I have said a couple of times previously, the White House asked the Senate to create legislation to give DOT the ability to extend the deadline on a case by case basis, which the Senate has done and sent to the House.

 

Is that what the three year extension of the Shuster bill will do?  Will that three year extension be granted on a case by case basis?  If so, considering that this case by case review will take time, how does this work with the 12/31/15 deadline? 

Will all of the railroads shut down after the deadline; and then one by one resume operation weeks or months after they have been individually reviewed and granted an extension on a case by case basis?  

What happens if a railroad shuts down on 1/1/16 and is never granted an extension because their case does not warrant it?

[MidlandMike]

Euclid

 

For the prospect of breaking the PTC logjam with an executive order, I have no idea which side President Obama would come down on.  Would he order a deadline extension in agreement with the railroad industry?  Or would he hold their feet to the fire and order that the current deadline be enforced when it arrives?

 

 

As I have said a couple of times previously, the White House asked the Senate to create legislation to give DOT the ability to extend the deadline on a case by case basis, which the Senate has done and sent to the House.

[Deggesty]

wanswheel

Excerpt from Reuters, Oct. 16

http://www.reuters.com/article/2015/10/16/us-usa-trains-safety-idUSKCN0SA2HV20151016

The U.S. House and Senate are "very close" to reaching bipartisan agreement to extend the Dec. 31 federal deadline for passenger and freight railroads to implement new safety technology for avoiding major accidents, an aide said on Friday.

 

Mike, you're slipping--researching in the present and not in the past.

Thanks for the update on the matter.

[wanswheel]

Excerpt from Reuters, Oct. 16

http://www.reuters.com/article/2015/10/16/us-usa-trains-safety-idUSKCN0SA2HV20151016

The U.S. House and Senate are "very close" to reaching bipartisan agreement to extend the Dec. 31 federal deadline for passenger and freight railroads to implement new safety technology for avoiding major accidents, an aide said on Friday.

[Euclid]

rdamon

Maybe this will help ..

 

 

For the prospect of breaking the PTC logjam with an executive order, I have no idea which side President Obama would come down on.  Would he order a deadline extension in agreement with the railroad industry?  Or would he hold their feet to the fire and order that the current deadline be enforced when it arrives?

 

[BaltACD]

Notice to employees -

PTC Status Update
October 16, 2015
By congressional mandate, railroads over which passenger trains operate and Class I freight railroads that handle toxic by inhalation (TIH) materials must have PTC fully implemented by December 31, 2015, on the lines over which those operations are conducted.
 
CSX and other freight railroads will not meet this deadline, and have acknowledged that publicly since 2012. The challenges we face include technology development, supplier capacity to meet railroad PTC needs, and construction delays associated with federal reviews of PTC implementation.
 
With limited exceptions, passenger railroads also will not meet the deadline, which will affect all CSX freight shipments (TIH and non-TIH) over those lines.
 
CSX has made significant progress, and will fully deploy PTC by 2020. Recently, we began operating PTC-equipped trains over our Wilmington (North Carolina) Subdivision in our first FRA-approved Revenue Service Demonstration (RSD). A feature about the RSD is available here on the Employee Gateway.
 
CSX has partially equipped nearly 2,700 locomotives, and 4,700 miles of rail signal system have been replaced to enable PTC integration. Investment for development and installation to date totals $1.3 billion, and will ultimately reach at least $1.9 billion.
 
PTC is first-generation technology, and as such we need adequate time to allow for field testing, evaluation, and re-testing. Only by doing so can CSX ensure a safe, effective PTC rollout that does not compromise the safe, reliable operation of passenger and freight trains.
 
We are considering a range of options should Congress not grant an extension, and those options include suspending passenger service as well as TIH shipments. In addition, all freight operations (TIH and non-TIH) may have to be suspended over non-compliant passenger railroads.
 
We are hopeful that Congress will address this matter in a timely manner, and CSX has taken several steps to encourage action. Efforts include a recent letter from Michael Ward to Senator John Thune of South Dakota, who is the chairman of the Senate Committee on Commerce, Science and Transportation, as well as frequent communication with other members of Congress on committees with jurisdiction on the issue.
 
Legislation that would extend the deadline has been introduced in both the Senate and the House of Representatives. Additional action is required to achieve passage, which remains to be scheduled.
 
CSX needs to prepare for the possibility that a bill that includes an extension is not passed by Congress in the next several weeks. If so, CSX regrettably will have to begin to take actions to ensure that no passenger, commuter or TIH freight operations occur on our railroad after December 31.
 
CSX currently estimates that it will take 30 days to purge loaded and empty TIH cars from our system. Without the certainty of a PTC extension in the very near future, CSX will need to begin actions no later than November 1 to suspend TIH traffic on December 1 and have all TIH cars off the CSX system by December 31.
 
In addition, in late December, CSX would suspend passenger operations on CSX tracks, and suspend CSX operations over passenger tracks.
 
CSX will continue to provide updates to employees and customers as progress is made on PTC-related issues.

[rdamon]

Maybe this will help ..

[Euclid]

What is the anticipated fate of the new Shuster bill in the house?  Is it expected to pass?  I have called his office three different occasions, but they tell me that they will not discuss the matter with the public. 

Congress watchers surely must be on top of this and have the latest insight as to the likely fate of the bill and the day it is expected to pass.  How long does it take to pass an extension?  Can it just be written out in a couple paragraphs and voted on inside of an hour or two?  Or does it require 10,000 hours of process time by staff?

The lack of news on this point seems odd considering the urgency.  We are only 14 days away from the start of curtailment of service on the railroads.

[Deggesty]

I would not be at all astounded if, now that the horse has been flayed, the flesh would be stripped from the bones and soup made from the bones after the matter is resolved by law.

[Norm48327]

schlimm

Makes one wonder if this thread will still be sputtering around in crazy circles after the House passes its bill, it goes to conference and is then passed by both houses and signed by the president.

Years later. Some posters don't know when to stop.

[schlimm]

MidlandMike

 

 

BaltACD

 

 

Euclid

MidlandMike

A fine is a penalty for breaking a law.  The railoads are not goint to pay a fine unless there is a judgement against them for breaking a law.

If you read what I was suggesting, you can see that the fine I am proposing would be for breaking the law.  But the law would only require the installation of PTC.  It would not prohibit operating without PTC.

 

 

The fact that one would be knowingly breaking the law blows up any liability defense if a carrier continued to operate without PTC where it is required.  Breaking the law is breaking the law - no matter what forms any penalty may take.  No law prohibits anyone from breaking it, IF THEY SO DESIRE.  The carriers do not desire to knowingly break the PTC law.

 

 

 

 

BaltACD, thanks for answering this one for me.  Euclid is sticking by his convoluted solution, despite being shown a number of real world alternatives that work, one of which has beeen passed and advanced by the Senate.

 

Makes one wonder if this thread will still be sputtering around in crazy circles after the House passes its bill, it goes to conference and is then passed by both houses and signed by the president.

[MidlandMike]

BaltACD

 

 

Euclid

MidlandMike

A fine is a penalty for breaking a law.  The railoads are not goint to pay a fine unless there is a judgement against them for breaking a law.

If you read what I was suggesting, you can see that the fine I am proposing would be for breaking the law.  But the law would only require the installation of PTC.  It would not prohibit operating without PTC.

 

 

The fact that one would be knowingly breaking the law blows up any liability defense if a carrier continued to operate without PTC where it is required.  Breaking the law is breaking the law - no matter what forms any penalty may take.  No law prohibits anyone from breaking it, IF THEY SO DESIRE.  The carriers do not desire to knowingly break the PTC law.

 

BaltACD, thanks for answering this one for me.  Euclid is sticking by his convoluted solution, despite being shown a number of real world alternatives that work, one of which has beeen passed and advanced by the Senate.

[Paul_D_North_Jr]

It's one thing to voluntarily accept by contract those risks that Larry / tree68 listed above.  That's what businesses do all the time, relying on themselves (or subcontractors, etc.) so that they'll have a way - or will figure out and make a way - to meet those obligations by the required time for performance, or accept the consequences (damages for delay, etc.). 

As practical matter (only) it's something else to have those obligations forced on them by the government, and still be faced with roughly the same kinds and amounts of consequences.

- Paul North.  

[Euclid]

tree68

 

Euclid

Never was it agreed that if the deadline was not met, that proves that the deadline was too short, and therefore must be extended.  Yet that is the current and highly convenient, self-serving interpretation by the railroads and their boosters. 

 

 

Really?  

If the necessary resources are not available to complete the task, it's the railroad's fault?  

How does that work?  

 

 

 

I understand all of that.  I disagree with the mandate and the idea that the railroads should be forced to install PTC.  I am not pushing PTC.  I think the PTC mandate was an emotional overreach and a mistake.  I am only concerned with the chess game of the standoff over the mandate and how it plays out. 

Without a mandate to push the process, there could be a million excuses why it would never get done, especially if the railroads disagree with the premise that it needs to get done and they should pay for it.  What large project has there even been where unforeseen circumstances have not arisen and made life harder?

So you can’t have it both ways.  Either there is a need to push to completion or there isn’t.  Without the push, we are back to pre-2008 where PTC was always under development with no endpoint ever known.

As I recall (correct me if I am wrong), the fines are not automatic.  If that is true, the fines are at the discretion of the FRA.  Given that there is now a realization by all sides that the project has been underestimated, I suspect that the FRA would be very lenient and issue few if any fines going forward without an extension.  But the threat of the fines would still be there as a motivator. 

I speculate that that was the developing view of both Congress and the FRA a couple months ago, prior to the railroads announcing their threat to shut down.  I suspect that Congress and the FRA did not expect the shutdown threat.  I think they expected work on the mandate to simply continue, and few if any fines would have been levied.  I think they were aware of the basic sense of unfairness to fine the railroads for something that was largely out of their control. 

So, I conclude that the railroads overplayed their hand with the threat of a shutdown.       

[Deggesty]

tree68

 

 

Euclid

Never was it agreed that if the deadline was not met, that proves that the deadline was too short, and therefore must be extended.  Yet that is the current and highly convenient, self-serving interpretation by the railroads and their boosters. 

 

 

Really?  

If the necessary resources are not available to complete the task, it's the railroad's fault?  

How does that work?  

If you're building a personal project, and a necessary part won't be available at the hardware store until next Tuesday, is it your fault that you couldn't have the project complete by this Saturday?

Yeah, yeah, I know - they've had some eight years for this.

You can't just go to the PTC store and pick up what you need for this project.  

Equipment has to be designed, and/or built, frequencies acquired, land acquired, and all of that equipment has to be installed, and tested.  

UP has over 10,000 locomotives, most of which I'd bet are in use most of the time.  That over 1,200 per year to get installed (about six per day) IF the equipment was ready and available on day one, which it wasn't.

We're putting in a new public service radio system in my county.  It's a five year project, and that involves established technologies and just one county.  And acquiring land and frequencies has been a part of the process as well.

Maybe instead of fining the railroads, we should be fining the equipment manufacturers for not having the equipment ready, the Native Americans with whom it has been necessary to negotiate some of the resources, and everyone else in the supply chain...

 

 

Larry, perhaps you should be fined for pointing out that the equipment has not been available nor has there been enough time to get it all installed?

[tree68]

Euclid

Never was it agreed that if the deadline was not met, that proves that the deadline was too short, and therefore must be extended.  Yet that is the current and highly convenient, self-serving interpretation by the railroads and their boosters. 

Really?  

If the necessary resources are not available to complete the task, it's the railroad's fault?  

How does that work?  

If you're building a personal project, and a necessary part won't be available at the hardware store until next Tuesday, is it your fault that you couldn't have the project complete by this Saturday?

Yeah, yeah, I know - they've had some eight years for this.

You can't just go to the PTC store and pick up what you need for this project.  

Equipment has to be designed, and/or built, frequencies acquired, land acquired, and all of that equipment has to be installed, and tested.  

UP has over 10,000 locomotives, most of which I'd bet are in use most of the time.  That over 1,200 per year to get installed (about six per day) IF the equipment was ready and available on day one, which it wasn't.

We're putting in a new public service radio system in my county.  It's a five year project, and that involves established technologies and just one county.  And acquiring land and frequencies has been a part of the process as well.

Maybe instead of fining the railroads, we should be fining the equipment manufacturers for not having the equipment ready, the Native Americans with whom it has been necessary to negotiate some of the resources, and everyone else in the supply chain...