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Solving the PTC Deadline Problem

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Posted by oltmannd on Friday, October 2, 2015 8:55 AM

One of the good things in the bill is it allows the FRA to grant phased implementation.  That will help the RRs get the system deployed smoothly.  Broke/fix items, processes, and OTJ training can be worked out in small chunks instead of having to have one, big "ON/OFF" switch.

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Posted by MikeF90 on Saturday, October 3, 2015 3:41 PM

oltmannd
One of the good things in the bill is it allows the FRA to grant phased implementation.  That will help the RRs get the system deployed smoothly.  Broke/fix items, processes, and OTJ training can be worked out in small chunks instead of having to have one, big "ON/OFF" switch.

A big Amen to that. Too bad the congress critters who sponsored RSIA didn't have a clue about that 'technology stuff'. Oh that's right, written by lawyers. Bang Head

BTW the AAR has provided a countdown clock as a reminder.

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Posted by Euclid on Monday, October 5, 2015 2:10 PM
cx500

The only way out is to amend the law and that can only be done by the elected members.  Assuming that happens, you cannot claim "this deadline will not be enforced".  The present deadline will no longer exist so there is nothing to enforce, or not enforce, until 2019. 

You say that by extending the current deadline, it will be voided, and replaced by a new deadline.  So by voiding the current deadline, there will be no deadline to enforce.  Therefore you say that it is incorrect for me to say that the current deadline is unenforceable. 
I don’t see any practical difference between extending a current deadline versus cancelling the current deadline and replacing it with a new deadline.  In either case, it is being done because, as you say, the consequences of enforcing the deadline would be disastrous.
So I will modify my claim that the current deadline is unenforceable as follows:  If the current deadline is enforced, the consequences will be disastrous.  Therefore, to avoid the disastrous consequences, the current deadline will be voided.  It will then be replaced by a new three-year deadline which likewise will be disastrous if enforced, and therefore must be voided before it arrives.      
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Posted by tree68 on Monday, October 5, 2015 2:28 PM

Euclid
I don’t see any practical difference between extending a current deadline versus cancelling the current deadline and replacing it with a new deadline.  

That's because there isn't.  Either way, the new deadline is whatever is set.  Or deadlines, if they exercise common sense and work with the railroads and supporting industries to establish realistic goals based on facts, not hyperbole.

The current deadline is certainly enforceable.  There is nothing to stop the feds from enforcing it except the potential consequences, and those are economic, not legal.

If the feds have the will to force the issue, then perhaps they also have the will to face the consequences.

 

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Posted by Norm48327 on Monday, October 5, 2015 2:37 PM

Euclid
 
cx500

The only way out is to amend the law and that can only be done by the elected members.  Assuming that happens, you cannot claim "this deadline will not be enforced".  The present deadline will no longer exist so there is nothing to enforce, or not enforce, until 2019. 

 
You say that by extending the current deadline, it will be voided, and replaced by a new deadline.  So by voiding the current deadline, there will be no deadline to enforce.  Therefore you say that it is incorrect for me to say that the current deadline is unenforceable. 
I don’t see any practical difference between extending a current deadline versus cancelling the current deadline and replacing it with a new deadline.  In either case, it is being done because, as you say, the consequences of enforcing the deadline would be disastrous.
So I will modify my claim that the current deadline is unenforceable as follows:  If the current deadline is enforced, the consequences will be disastrous.  Therefore, to avoid the disastrous consequences, the current deadline will be voided.  It will then be replaced by a new three-year deadline which likewise will be disastrous if enforced, and therefore must be voided before it arrives.      
 

Sounds like someone running for office. Lots of doublespeak there.

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Posted by Euclid on Monday, October 5, 2015 3:34 PM

tree68
 
Euclid
I don’t see any practical difference between extending a current deadline versus cancelling the current deadline and replacing it with a new deadline.  

 

That's because there isn't.  Either way, the new deadline is whatever is set.  Or deadlines, if they exercise common sense and work with the railroads and supporting industries to establish realistic goals based on facts, not hyperbole.

The current deadline is certainly enforceable.  There is nothing to stop the feds from enforcing it except the potential consequences, and those are economic, not legal.

If the feds have the will to force the issue, then perhaps they also have the will to face the consequences.

 

 

That is true.  We don't yet know what they will decide between now and 12/31/15. 

I agree with your point that the consequences of enforcement are economic and not legal.  Certainly the legal means of enforcement is fully in place and workable.  My main point is that the economic case for enforcement, in effect, finds the deadline unenforceable because enforcing it is not worth the economic cost. 

Regarding your quote of me:  I agree that there is not any difference between extending a deadline or canceling it and replacing it.  It has been suggested there is a difference, however. 

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Posted by Murphy Siding on Monday, October 5, 2015 4:36 PM

Norm48327
  
 

 

 

Sounds like someone running for office. Lots of doublespeak there.

 

  Norm- With all due respect, since euclid started this thread, it seems only fair that euclid should be able add to it without being graded, even if it does make him sound like... um... how he sounds. Stick out tongue

Thanks to Chris / CopCarSS for my avatar.

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Posted by Norm48327 on Monday, October 5, 2015 4:50 PM

Murphy Siding
Norm- With all due respect, since euclid started this thread, it seems only fair that euclid should be able add to it without being graded, even if it does make him sound like... um... how he sounds. Stick out tongue

Objection noted.

Norm


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Posted by MidlandMike on Monday, October 5, 2015 7:18 PM

Euclid

 

 
tree68
 
The current deadline is certainly enforceable.  There is nothing to stop the feds from enforcing it except the potential consequences, and those are economic, not legal.  ...

 

 

 

 

 

That is true.  We don't yet know what they will decide between now and 12/31/15. 

I agree with your point that the consequences of enforcement are economic and not legal.  ...

 

Actually NS (there may be others) is mounting a legal defense if the PTC deadline is enforced rather than extended.  The GAO and other government agencies have already said that the deadline can not possibly be met.  So at this time, enforcing the deadline would seem arbitrary and capricious.  Of course neither side would want to go to court since it is hard to predict who will win/lose.  Both sides want to avoid a showdown to avoid a big legal mess, in addition to the economic consequences.

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Posted by edblysard on Tuesday, October 6, 2015 5:27 AM

Norm48327
 
Euclid
 
cx500

The only way out is to amend the law and that can only be done by the elected members.  Assuming that happens, you cannot claim "this deadline will not be enforced".  The present deadline will no longer exist so there is nothing to enforce, or not enforce, until 2019. 

 
You say that by extending the current deadline, it will be voided, and replaced by a new deadline.  So by voiding the current deadline, there will be no deadline to enforce.  Therefore you say that it is incorrect for me to say that the current deadline is unenforceable. 
I don’t see any practical difference between extending a current deadline versus cancelling the current deadline and replacing it with a new deadline.  In either case, it is being done because, as you say, the consequences of enforcing the deadline would be disastrous.
So I will modify my claim that the current deadline is unenforceable as follows:  If the current deadline is enforced, the consequences will be disastrous.  Therefore, to avoid the disastrous consequences, the current deadline will be voided.  It will then be replaced by a new three-year deadline which likewise will be disastrous if enforced, and therefore must be voided before it arrives.      
 

 

 

Sounds like someone running for office. Lots of doublespeak there.

 

I think it might be a written form of Tourette's.

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Posted by schlimm on Tuesday, October 6, 2015 6:53 AM

edblysard

 

 
Norm48327
 
Euclid
 
cx500

The only way out is to amend the law and that can only be done by the elected members.  Assuming that happens, you cannot claim "this deadline will not be enforced".  The present deadline will no longer exist so there is nothing to enforce, or not enforce, until 2019. 

 
You say that by extending the current deadline, it will be voided, and replaced by a new deadline.  So by voiding the current deadline, there will be no deadline to enforce.  Therefore you say that it is incorrect for me to say that the current deadline is unenforceable. 
I don’t see any practical difference between extending a current deadline versus cancelling the current deadline and replacing it with a new deadline.  In either case, it is being done because, as you say, the consequences of enforcing the deadline would be disastrous.
So I will modify my claim that the current deadline is unenforceable as follows:  If the current deadline is enforced, the consequences will be disastrous.  Therefore, to avoid the disastrous consequences, the current deadline will be voided.  It will then be replaced by a new three-year deadline which likewise will be disastrous if enforced, and therefore must be voided before it arrives.      
 

 

 

Sounds like someone running for office. Lots of doublespeak there.

 

 

 

I think it might be a written form of Tourette's.

 

 

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Posted by CSSHEGEWISCH on Tuesday, October 6, 2015 7:06 AM

I've been diagnosed with this from time to time so I think it's more likely to be a form of pedantry.

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Posted by Deggesty on Tuesday, October 6, 2015 8:23 AM

Paul, perhaps you are right, though Houston Ed may have hit it--he can't help it. My thought was of the explanation why the upper berth is lower than the lower--Paul North and Jeff Hergert should catch on to this quickly.

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Posted by wanswheel on Tuesday, October 6, 2015 10:25 AM
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Posted by tree68 on Tuesday, October 6, 2015 11:29 AM

wanswheel

More like a PTC story with a Vermonter derailment mention.

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Posted by BaltACD on Tuesday, October 6, 2015 12:13 PM

tree68
wanswheel

More like a PTC story with a Vermonter derailment mention.

With McClatchy trying to spin PTC as being the magic bullet that will stop every railroad accident everywhere - even where it is not mandated.

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Posted by Paul of Covington on Tuesday, October 6, 2015 2:46 PM

Hmm     Balt, are you claiming that PTC would NOT have prevented this accident?

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Posted by dehusman on Tuesday, October 6, 2015 4:12 PM

Paul of Covington

Hmm     Balt, are you claiming that PTC would NOT have prevented this accident?

 
PTC wouldn't have done a single thing to prevent this derailment.
 
PTC prevents trains from exceeding their main track authority or exceeding the authorized speed.
 
The Vermonter accident has absolutely NOTHING to do with main track authority limits or excessive speed.

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Posted by Deggesty on Tuesday, October 6, 2015 4:51 PM

dehusman

 

 
Paul of Covington

Hmm     Balt, are you claiming that PTC would NOT have prevented this accident?

 

 

 
PTC wouldn't have done a single thing to prevent this derailment.
 
PTC prevents trains from exceeding their main track authority or exceeding the authorized speed.
 
The Vermonter accident has absolutely NOTHING to do with main track authority limits or excessive speed.
 

Remember that the area where the rock fell is dark territory. Also, considering that the New England Central and its predecessors have had little trouble with rock slides there has been no acknowledged necessity to install slide fences which could have linked to a warning system, and it is improbable that such will be installed.

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Posted by tree68 on Tuesday, October 6, 2015 4:56 PM

Deggesty
Remember that the area where the rock fell is dark territory.

Dark territory or no, unless there was some method of detecting the rock slide, PTC would have been useless here.  

As Deggesty notes, the area doesn't have a history of such slides.  

PTC is not a "magic bullet."  Which has already been noted, as well.  But some people seem to think it is.

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Posted by wanswheel on Tuesday, October 6, 2015 9:21 PM
Joe Boardman took the train to Vermont, and a question about PTC.
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Posted by Paul of Covington on Wednesday, October 7, 2015 12:37 PM

    We need a tongue-in-cheek emoticon.   The closest I could find was the Hmm.   Several times I have made tongue-in cheek comments and received serious answers.

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Posted by tree68 on Wednesday, October 7, 2015 12:47 PM

Paul of Covington
We need a tongue-in-cheek emoticon.   The closest I could find was the Hmm.   Several times I have made tongue-in cheek comments and received serious answers.

Unfortunately, sometimes the tongue-in-cheek posts border on the realm of possibility, at least to some portion of the audience.  I usually use the wink.

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Posted by Euclid on Wednesday, October 7, 2015 12:53 PM
I have spoken to the office of Senator Richard Blumenthal, and asked when the railroads and Congress first concluded that the railroads must shut down if not compliant after the PTC deadline.  The railroads cite three reasons for this conclusion:

1)   It would be illegal to operate out of compliance with the PTC law.

 

2)   It would increase their liability in case of accidents while operating out of compliance with the PTC law.

 

3)   Their common carrier obligation is suspended if they are out of compliance with the PTC law. 

 
I was told the following by Senator Blumenthal’s office:

1)   Congress does not agree with the railroads’ conclusions about any of the three points listed above. 

 

2)   Congress sees no reason for the railroads to shut down if not compliant after the PTC deadline.

 

3)   There is nothing in the PTC law that requires the railroads to shut down if not compliant after the PTC deadline. 

 

4)   Congress has not determined what enforcement action they will take if the railroads shut down.

 

5)   Senator Blumenthal believes that the railroads are using their claim that they must shut down as a tactic to pressure Congress into granting a PTC extension because the railroads know that Congress will not want the economy to be damaged by a shutdown.

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Posted by tree68 on Wednesday, October 7, 2015 1:05 PM

One has to wonder what his answer would have been if it had been a high-mucky-muck from a railroad that asked...

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Posted by wanswheel on Wednesday, October 7, 2015 1:40 PM
Excerpt from Reuters, Oct. 6
Amtrak has told U.S. lawmakers that it will suspend service on its national network in mid-December unless Congress extends a Dec. 31 deadline for implementing advanced safety technology, according to an Oct. 5 letter from Amtrak reviewed by Reuters.
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Posted by oltmannd on Wednesday, October 7, 2015 2:36 PM

Euclid
I have spoken to the office of Senator Richard Blumenthal, and asked when the railroads and Congress first concluded that the railroads must shut down if not compliant after the PTC deadline.  The railroads cite three reasons for this conclusion:

1)   It would be illegal to operate out of compliance with the PTC law.

 

2)   It would increase their liability in case of accidents while operating out of compliance with the PTC law.

 

3)   Their common carrier obligation is suspended if they are out of compliance with the PTC law. 

 
I was told the following by Senator Blumenthal’s office:

1)   Congress does not agree with the railroads’ conclusions about any of the three points listed above. 

 

2)   Congress sees no reason for the railroads to shut down if not compliant after the PTC deadline.

 

3)   There is nothing in the PTC law that requires the railroads to shut down if not compliant after the PTC deadline. 

 

4)   Congress has not determined what enforcement action they will take if the railroads shut down.

 

5)   Senator Blumenthal believes that the railroads are using their claim that they must shut down as a tactic to pressure Congress into granting a PTC extension because the railroads know that Congress will not want the economy to be damaged by a shutdown.

 

Senator Blumenthal is free to believe in the Easter Bunny, too.

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Posted by Norm48327 on Wednesday, October 7, 2015 2:36 PM

tree68

One has to wonder what his answer would have been if it had been a high-mucky-muck from a railroad that asked...

 

One also has to wonder why a mere railfan would be calling a senator's office for information on the PTC law. Could it professional interest for future reference?

Norm


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Posted by oltmannd on Wednesday, October 7, 2015 2:38 PM

Euclid
2)   Congress sees no reason for the railroads to shut down if not compliant after the PTC deadline.

This one is the funniest.  In effect, the RRs are free to violate this particular law?  Maybe the Senator can provide a list of which laws the RRs are free to violate.

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Posted by oltmannd on Wednesday, October 7, 2015 2:39 PM

Euclid
4)   Congress has not determined what enforcement action they will take if the railroads shut down.

Although this one is pretty funny, too.  Congress doesn't do enforcement.  Does Blumenthal need remedial Civics?

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

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