Trains.com

Solving the PTC Deadline Problem

20608 views
346 replies
1 rating 2 rating 3 rating 4 rating 5 rating
  • Member since
    September 2010
  • 2,515 posts
Posted by Electroliner 1935 on Wednesday, September 30, 2015 6:19 PM

Posted by Buslist on Wednesday, September 30, 2015 6:06 PM

Debate over?

http://trn.trains.com/news/news-wire/2015/09/30-ptc-bill-makes-houseI'm

 

Link doesn't work. Delete the l'm at the end of the URL or go to trains news wire 

  • Member since
    March 2002
  • 9,265 posts
Posted by edblysard on Wednesday, September 30, 2015 6:13 PM

Embarrassed"Yes, but, what if......?"

23 17 46 11

  • Member since
    November 2013
  • 1,097 posts
Posted by Buslist on Wednesday, September 30, 2015 6:06 PM
  • Member since
    December 2007
  • From: Southeast Michigan
  • 2,983 posts
Posted by Norm48327 on Wednesday, September 30, 2015 5:10 PM

Euclid
It is just a simple change in the terms of the mandate to make it legal for railroads to operate without PTC as they press forward with the installation, driven by the desire to avoid fines.

Simple minds think everything can be done simply.

Norm


  • Member since
    January 2014
  • 8,221 posts
Posted by Euclid on Wednesday, September 30, 2015 4:48 PM
Norm48327
 
Euclid
That solution extends the deadline, but not the fines.

Think that would hold up in court? Fat chance they could be fined for doing something congress just said it's OK to do.

Norm,
No they would not be fined for doing something that congress said it was okay to do.  Congress would say it is okay to operate without PTC, so they would not be fined for operating without PTC. 
What they would be fined for is not having the required PTC installed as of 1/1/16.  It is just a simple change in the terms of the mandate to make it legal for railroads to operate without PTC as they press forward with the installation, driven by the desire to avoid fines. 
Otherwise, as Larry says, the deadlines would just turn into goals.   
As I recall, the fines are not absolute requirements.  I think the language says some to the effect of “may levy fines up to…”  So the fines may be exaggerated in most discussion and news reports.  I would not be surprised if there are no fines levied, but just the threat of fines to provide motivation.  
I would think that the railroads would welcome this because it saves them the loss of shutting down which would probably far exceed any fines, if there are any.   
  • Member since
    May 2003
  • From: US
  • 25,292 posts
Posted by BaltACD on Wednesday, September 30, 2015 4:24 PM

Euclid
With my solution, there is no longer any reason to shut down.  This is because continued operation while non-compliant will not violate the law.  The railroads get to keep operating for the next three years of the extension, and the FRA gets to use fines to hurry things along for the next three years of the extension.

Please talk like you have SOME intellegence!  This 'solution' is a non-starter for anyone with more than two synapse in working order within their skulls.

Never too old to have a happy childhood!

              

  • Member since
    December 2007
  • From: Southeast Michigan
  • 2,983 posts
Posted by Norm48327 on Wednesday, September 30, 2015 4:02 PM

Euclid
That solution extends the deadline, but not the fines.

Think that would hold up in court? Fat chance they could be fined for doing something congress just said it's OK to do. Time to post something fruitful or put your soapbox away.

Norm


  • Member since
    December 2001
  • From: Northern New York
  • 25,021 posts
Posted by tree68 on Wednesday, September 30, 2015 3:42 PM

I'll just wait and see what happens.

I could probably propose a solution, too, but no one would pay attention to that, either.

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

  • Member since
    January 2014
  • 8,221 posts
Posted by Euclid on Wednesday, September 30, 2015 3:39 PM

 

Euclid
 
The way to solve this problem is to impose the fines for operating in non-compliance; without making such operation illegal.  That way the railroads cannot find an exemption to their common carrier obligation, nor can they choose to shut down to avoid breaking the law.  This would keep the railroads boxed into their PTC obligation without this messy public backlash against the government for the interruption of rail service.    
 
Some compain that I offer no solutions.
There is an obvious solution to this problem that I already offered in the original post of this thread on 9/11, as quoted above.  That solution extends the deadline, but not the fines.  That really puts everything back on track to where it was prior to the recent announcements by railroads saying they would shut down if they are not compliant after the deadline.
With my solution, there is no longer any reason to shut down.  This is because continued operation while non-compliant will not violate the law.  The railroads get to keep operating for the next three years of the extension, and the FRA gets to use fines to hurry things along for the next three years of the extension. 

 

  • Member since
    December 2007
  • From: Southeast Michigan
  • 2,983 posts
Posted by Norm48327 on Wednesday, September 30, 2015 3:11 PM

Buslist
An expert? Have you followed the oil train thread? Anything but, always being corrected by someone.

A legend in his own mind?  Devil

Norm


  • Member since
    December 2007
  • From: Georgia USA SW of Atlanta
  • 11,919 posts
Posted by blue streak 1 on Wednesday, September 30, 2015 3:01 PM

Hope am wrong but the house bill if passed by both houses un modified might cause many more problems.  Can RRs now be ordered to operate without defying a law and be fined for operating without PTC ?  The court cases might go on long after PTC is complete ?

  • Member since
    November 2013
  • 1,097 posts
Posted by Buslist on Wednesday, September 30, 2015 3:00 PM

Norm48327

 

 
tree68

 

Take a deep breath.

Virtually all deadlines are actually "goals."  The deadline to file your income tax return is April 15 (barring holidays and weekends).  But if you can't meet that deadline, there are ways to deal with it.

You are, per usual, making a mountain out of a molehill, and until someone agrees with your hysteria, you're going to keep right on crying "Zhomigod, the sky is falling."

Give it a rest.  It'll get sorted out.

 

 

 

Standard procedure, and he has never posted any solution to the problem. Bang Head And we were lead to believe he's an expert. Zzz

 

 

An expert? Have you followed the oil train thread? Anything but, always being corrected by someone.

  • Member since
    July 2006
  • 9,610 posts
Posted by schlimm on Wednesday, September 30, 2015 2:47 PM

Norm48327

 

 
tree68

 

Take a deep breath.

Virtually all deadlines are actually "goals."  The deadline to file your income tax return is April 15 (barring holidays and weekends).  But if you can't meet that deadline, there are ways to deal with it.

You are, per usual, making a mountain out of a molehill, and until someone agrees with your hysteria, you're going to keep right on crying "Zhomigod, the sky is falling."

Give it a rest.  It'll get sorted out.

 

 

 

Standard procedure, and he has never posted any solution to the problem. Bang Head And we were lead to believe he's an expert. Zzz

 

 

++1

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

  • Member since
    December 2007
  • From: Southeast Michigan
  • 2,983 posts
Posted by Norm48327 on Wednesday, September 30, 2015 2:37 PM

tree68

 

Take a deep breath.

Virtually all deadlines are actually "goals."  The deadline to file your income tax return is April 15 (barring holidays and weekends).  But if you can't meet that deadline, there are ways to deal with it.

You are, per usual, making a mountain out of a molehill, and until someone agrees with your hysteria, you're going to keep right on crying "Zhomigod, the sky is falling."

Give it a rest.  It'll get sorted out.

 

Standard procedure, and he has never posted any solution to the problem. Bang Head And we were lead to believe he's an expert. Zzz

Norm


  • Member since
    January 2001
  • From: Atlanta
  • 11,971 posts
Posted by oltmannd on Wednesday, September 30, 2015 2:06 PM

Buslist

 

 
Euclid

 

 
Buslist
For those thinking that a shutdown might be lengthy due to congress wanting the railroads to loose revenue need to consider a basic fact.

 

I don't know of anybody here who has said that a shutdown might be lengthy because congress wants the railroads to loose revenue.  Can you please explain?

 

 

 

someone in another forum said 

"In my previous post, I was talking about a case where Congress fails to grant an extension by the deadline, and the railroads shut down a large amount of operations as they have announced they will do.  I can see how fuel and crews would be cheaper during a shutdown, as you say, but what about the loss of revenue?  How long could the railroads stand that loss?  In other words, what will the railroads do if Congress persists in not extending the deadline after it passes?" 

 

Why would they refuse to pass it if they didn't think that the loss of revenue wasn't a way to get the railroads running again? 

 

 

 

 

The difference between the lost revenue and costs saved is likely small enough that the RRs could weather a shutdown for several months, at least.  That's longer than the economy could weather a shutdown....

Not all "lost revenue" would be lost.  Some would just be deferred.  Most bulk commodities, for example.

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

  • Member since
    January 2001
  • From: Atlanta
  • 11,971 posts
Posted by oltmannd on Wednesday, September 30, 2015 2:02 PM

The bill coming out of committee to extend the "deadline" is for three year with another two at the discretion of the FRA.

I suspect it would give the FRA the power to fine while granting the extension.

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

  • Member since
    December 2006
  • 1,754 posts
Posted by diningcar on Wednesday, September 30, 2015 1:00 PM

AMEN TREE

  • Member since
    December 2001
  • From: Northern New York
  • 25,021 posts
Posted by tree68 on Wednesday, September 30, 2015 12:35 PM

Euclid
On the contrary, the problem with all deadlines going forward is that they cannot be deadlines at all.  They can only be deadlines if the railroads meet them, which is not a deadline at all.  If the railroads cannot meet them, they must be extended, which is not a deadline at all.  A so called extended deadline will not be a deadline.  Instead, it will be a status reporting point with no ability to enforce progress.  It cannot possibly be a deadline according to its definition: “The time by which something must be finished.” 

Take a deep breath.

Virtually all deadlines are actually "goals."  The deadline to file your income tax return is April 15 (barring holidays and weekends).  But if you can't meet that deadline, there are ways to deal with it.

You are, per usual, making a mountain out of a molehill, and until someone agrees with your hysteria, you're going to keep right on crying "Zhomigod, the sky is falling."

Give it a rest.  It'll get sorted out.

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

  • Member since
    November 2005
  • 4,190 posts
Posted by wanswheel on Wednesday, September 30, 2015 12:26 PM

ruderunner

Seems the house is bringing a 3year extension to the table on its own. Hopefully the Senate will OK it all by itself instead of packed into their transportation bill.

 

 

Excerpt from House transportation committee press release, Sept. 30

http://transportation.house.gov/news/documentsingle.aspx?DocumentID=399332

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.

Excerpt from Reuters, Sept. 30

http://www.reuters.com/article/2015/09/30/usa-trains-safety-idUSL1N12018O20150930

U.S. Representative Peter DeFazio of Oregon, the House panel's leading Democrat, said the PTC extension was necessary but expressed disappointment that the change would not be part of a larger bill that could have included other rail safety enhancements.

There was no immediate word on when the House might vote on the new legislation...

"We look forward to working with both the House and Senate bipartisan leadership to quickly get the PTC extension across the finish line," said Edward Hamberger, president and chief executive of the Association of American Railroads, an industry lobbying group.

  • Member since
    March 2008
  • 773 posts
Posted by ruderunner on Wednesday, September 30, 2015 11:40 AM

Seems the house is bringing a 3year extension to the table on its own. Hopefully the Senate will OK it all by itself instead of packed into their transportation bill.

Modeling the Cleveland and Pittsburgh during the PennCentral era starting on the Cleveland lakefront and ending in Mingo junction

  • Member since
    January 2014
  • 8,221 posts
Posted by Euclid on Tuesday, September 29, 2015 11:07 PM
Deggesty
 
tree68

 

 
Euclid
You say that the solution is more reasonable deadlines.  How reasonable do they have to be? 

 

The deadline(s) should take into consideration variables over which the railroad has no control.  Things like necessary technology, required equipment that hasn't been invented/purpose built yet, acquisition of land and frequencies, and the like.  If a manufacturer tells you he can't have the part you need for a year, how can you meet a deadline that's three months away?

 

 
Euclid
You say that with reasonable deadlines, some railroads will move faster than others.  What if, on the whole, they all slow way down because they think that is reasonable?   ...  If the only acceptable deadline is what the railroads feel is reasonable, why have a deadline?

 

While the railroads will likely have a say in any new deadlines, they probably won't be the ones setting them - that will come down to Congress and/or the FRA.  

That said - if a new blanket deadline is set (as opposed to deadlines for each railroad, based on how they are coming along on the project), then perhaps a railroad that is currently ahead of the curve might "slow down."  In reality, that simply means that they will redirect some of the resources currently being used on PTC to other projects.  They will continue to work toward meeting the new deadline, but perhaps not as fast as they could otherwise.

If individual deadlines are set, then it will depend on how "good faith" a given railroad's estimated completion date is.  And all the other variables...

 

 

 

Well said, Larry, especially the first paragraph.Thumbs Up

 

 

I agree that the railroads cannot meet a deadline that needs more time due to factors out of their control.  However, the problem with all possible deadlines going forward is not whether they will be unreasonable. 
On the contrary, the problem with all deadlines going forward is that they cannot be deadlines at all.  They can only be deadlines if the railroads meet them, which is not a deadline at all.  If the railroads cannot meet them, they must be extended, which is not a deadline at all.  A so called extended deadline will not be a deadline.  Instead, it will be a status reporting point with no ability to enforce progress.  It cannot possibly be a deadline according to its definition: “The time by which something must be finished.” 
  • Member since
    August 2005
  • From: At the Crossroads of the West
  • 11,013 posts
Posted by Deggesty on Tuesday, September 29, 2015 10:24 PM

tree68

 

 
Euclid
You say that the solution is more reasonable deadlines.  How reasonable do they have to be? 

 

The deadline(s) should take into consideration variables over which the railroad has no control.  Things like necessary technology, required equipment that hasn't been invented/purpose built yet, acquisition of land and frequencies, and the like.  If a manufacturer tells you he can't have the part you need for a year, how can you meet a deadline that's three months away?

 

 
Euclid
You say that with reasonable deadlines, some railroads will move faster than others.  What if, on the whole, they all slow way down because they think that is reasonable?   ...  If the only acceptable deadline is what the railroads feel is reasonable, why have a deadline?

 

While the railroads will likely have a say in any new deadlines, they probably won't be the ones setting them - that will come down to Congress and/or the FRA.  

That said - if a new blanket deadline is set (as opposed to deadlines for each railroad, based on how they are coming along on the project), then perhaps a railroad that is currently ahead of the curve might "slow down."  In reality, that simply means that they will redirect some of the resources currently being used on PTC to other projects.  They will continue to work toward meeting the new deadline, but perhaps not as fast as they could otherwise.

If individual deadlines are set, then it will depend on how "good faith" a given railroad's estimated completion date is.  And all the other variables...

 

Well said, Larry, especially the first paragraph.Thumbs Up

Johnny

  • Member since
    December 2001
  • From: Northern New York
  • 25,021 posts
Posted by tree68 on Tuesday, September 29, 2015 9:56 PM

Euclid
You say that the solution is more reasonable deadlines.  How reasonable do they have to be? 

The deadline(s) should take into consideration variables over which the railroad has no control.  Things like necessary technology, required equipment that hasn't been invented/purpose built yet, acquisition of land and frequencies, and the like.  If a manufacturer tells you he can't have the part you need for a year, how can you meet a deadline that's three months away?

Euclid
You say that with reasonable deadlines, some railroads will move faster than others.  What if, on the whole, they all slow way down because they think that is reasonable?   ...  If the only acceptable deadline is what the railroads feel is reasonable, why have a deadline?

While the railroads will likely have a say in any new deadlines, they probably won't be the ones setting them - that will come down to Congress and/or the FRA.  

That said - if a new blanket deadline is set (as opposed to deadlines for each railroad, based on how they are coming along on the project), then perhaps a railroad that is currently ahead of the curve might "slow down."  In reality, that simply means that they will redirect some of the resources currently being used on PTC to other projects.  They will continue to work toward meeting the new deadline, but perhaps not as fast as they could otherwise.

If individual deadlines are set, then it will depend on how "good faith" a given railroad's estimated completion date is.  And all the other variables...

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

  • Member since
    January 2014
  • 8,221 posts
Posted by Euclid on Tuesday, September 29, 2015 8:30 PM
MidlandMike
 
Euclid

 

 

 

Well yes the deadline is enforceable in the practice of the enforcement mechanism.  But if that leads to the ruin of the economy and of the railroads, the deadline is not enforceable in any practical sense.  You say they will just delay enforcement.  What happens after the delay? They are back to the same problem of ruining the economy.       

  

 

 

The RRs have spent $6 billion so far on PTC.  Do you think that after investing so much they are just going to quit if the deadline is delayed?  They will continue to implement the system under more reasonable extended deadlines.  Some will move faster than others.  When some have completed, while others trail behind, the slower ones will have to justify why they can't meet new deadlines.  If a few RRs have been less than diligent, and enforcement action needs to be taken on them, it will not be an economic catastrophy, as their competitors will take the business.

In the meantime, I previously asked you to identify a majority (republican) caucus who opposes extending PTC.  You seem to have tried to deflect, while repeating the same "yeah but's".

 

Hey, I am just giving my opinions and making some observations.  I have no stake in the outcome.  If you want to believe in the most rosy scenario, that’s fine with me.  But I am under no obligation to prove otherwise to you.  I have stated my reasoning.  The rest is up to you.
You say that the solution is more reasonable deadlines.  How reasonable do they have to be?  If they can’t be enforced, what is the point of having a deadline?  
You say that with reasonable deadlines, some railroads will move faster than others.  What if, on the whole, they all slow way down because they think that is reasonable?   
You say the railroads have spent $6 billion so far, and ask if I think they will quit if the deadline is extended.  I have no idea what they would do going forward if this deadline is extended.  If the only acceptable deadline is what the railroads feel is reasonable, why have a deadline?  Without a deadline, you don’t have a mandate.  Would the railroads have spent that $6 billion without the mandate?    
I am not dodging your question about who opposes extending PTC in Congress.  I don’t know the answer, and I don’t care.  I certainly would not predict the outcome based on what the answer appears to be.  If there is enough support, there will be an extension.  I have never ruled that out.
  • Member since
    September 2011
  • 6,449 posts
Posted by MidlandMike on Tuesday, September 29, 2015 7:34 PM

Euclid

 

 

 

Well yes the deadline is enforceable in the practice of the enforcement mechanism.  But if that leads to the ruin of the economy and of the railroads, the deadline is not enforceable in any practical sense.  You say they will just delay enforcement.  What happens after the delay? They are back to the same problem of ruining the economy.       

  

The RRs have spent $6 billion so far on PTC.  Do you think that after investing so much they are just going to quit if the deadline is delayed?  They will continue to implement the system under more reasonable extended deadlines.  Some will move faster than others.  When some have completed, while others trail behind, the slower ones will have to justify why they can't meet new deadlines.  If a few RRs have been less than diligent, and enforcement action needs to be taken on them, it will not be an economic catastrophy, as their competitors will take the business.

In the meantime, I previously asked you to identify a majority (republican) caucus who opposes extending PTC.  You seem to have tried to deflect, while repeating the same "yeah but's".

  • Member since
    May 2003
  • From: US
  • 25,292 posts
Posted by BaltACD on Tuesday, September 29, 2015 2:28 PM

While Congress may be a body, it's actions over past decades demonstrates that it is many petaflops short of having a functioning brain.

Never too old to have a happy childhood!

              

  • Member since
    January 2014
  • 8,221 posts
Posted by Euclid on Tuesday, September 29, 2015 1:10 PM
I don’t consider Congress to be a "body with a brain."  I only refer to it as a single entity because it will make a decision speaking as a single entity.  I realize that it is a bunch of people with differing and shifting views and a whole lot of procedural rigmarole.  But at the end of the day, it speaks with one voice as the legislative body. 
  • Member since
    November 2005
  • 4,190 posts
Posted by wanswheel on Tuesday, September 29, 2015 12:59 PM
Have to stop thinking of Congress as a body with a brain, it’s a bunch of individuals. Gradually, gradually by osmosis, its least interested members are learning of the existence of this PTC deadline thing, probably thanks to Sen. John Thune.  I see the NY Times article is on page 16, meaning, the sky isn’t falling yet but pay attention. That’s good news, everybody important keeps an eye on the Times.
  • Member since
    January 2014
  • 8,221 posts
Posted by Euclid on Tuesday, September 29, 2015 11:22 AM
I can see the following three outcomes:
 

1)   Congress wants to extend the deadline, and they will have enough time to change the law and extend the deadline before it arrives.

 

2)   Congress wants to extend the deadline, but will not have enough time to change the law and extend the deadline before it arrives.  So they will extend the deadline sometime after 1/1/15.

 

3)   Congress will refuse to extend the deadline because they want the deadline to remain in place. 

  • Member since
    January 2002
  • From: Canterlot
  • 9,575 posts
Posted by zugmann on Tuesday, September 29, 2015 10:59 AM

Don't worry, the house leadership is busy on this subject.....by.....discussing planned... parenthood....?

 

We're screwed.

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

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