In a previous article I asserted that FRA supported the effort to have Congress rollback the implementation date for PTC....
That is incorrect. FRA has made no such suggestion. What FRA has recommended to Congress in its report of August 2012 is the following:
Based on the results of this report, FRA believes that the majority of railroads will not be able to complete PTC implementation by the 2015 deadline. Partial deployment can likely be achieved; however, the extent of which is dependent upon the successful resolution of any
known and emergent issues.
As a result, FRA recommends that if Congress were to consider legislation extending the PTC implementation deadline it should consider several factors, including the extent to which each railroad has demonstrated due diligence in its efforts to successfully implement PTC technologies on its rail system.
In the event that Congress were to make legislative changes, FRA suggests allowing for provisional certification of PTC systems that will allow for the use of installed PTC systems under controlled conditions before final system certification is complete. This will allow for the incremental use of PTC systems and produce an increase in safety as the systems are systematically rolled out.
FRA also suggests that any revisions to a railroad’s PTCIP be subject to FRA approval with sufficient time for FRA to review and significant FRA oversight.
Finally, FRA recommends that it be allowed to approve a railroad to use alternative safety technologies on specified line segments in lieu of PTC, particularly in areas with lower safety risks, if appropriately and properly justified to FRA.
I find that last paragraph a little problematic, since 1) FRA has already exempted entire lines from the mandatory requirement based on its own criteria of "lower safety risks" 2) the law does not designate, specify, or prescribe technologies. It mandate functions.
Nevertheless, FRA has not recommended any rollback on the installation date.
March 15, 2014
10% planning, 90% execution
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