Definitely, absolutely, rock-solid, nothing can dissuade me, except advancing years and short-term memory loss. What was the topic again?
Right, right... PTC. How could I ever forget? OK, my mind's made up and here's what I think. I think regarding PTC, FRA holds all the cards, both of them. FRA has 1) the mandate from Congress 2) a record of requiring safety improvements when rail operations absent those safety requirements have been shown to present an unacceptable risk to the public.
That's all FRA needs. That's all anyone should need to support the installation of PTC. There's more if you want it. There's the whole tradition of installing safety improvements on public carriers because they are public carriers. There's the tradition in transportation of doing things first for safety and then finding out that it actually makes "business sense." There's the tradition of deploying new technologies that improve safety simply because they are new technologies that improve safety.
Now I think FRA made certain compromises, worried that meeting the 2015 deadline was at risk if every line with annual traffic greater than 5 MGT and with 1 or more PIH tank car being transported was included in the mandate.
My mind's made up. FRA made its exceptions based on its sense of urgency to get PTC in operation by 2015. It made those exceptions, I think/guess, in the hope that the Class 1s would roll out PTC pilot corridors for evaluation and testing within a year or two of the law's passage, while preparing for full deployment.
After making the exceptions, FRA might have expected that railroads would still not meet the full deployment by the 2015 target date, but that the areas of greatest risk, like interlockings, like routes with shared passenger and freight access would be equipped, and then FRA could address the remaining issues with a certain amount of leeway.
Clearly, at least clearly to me from the NTSB forum held in DC at the end of February, the Class 1s weren't, back then, or now, thinking along the same lines as FRA.
Lesson here? Sometimes you shouldn't compromise, you shouldn't accommodate. It won't get you what you want, it can't get you what need, it doesn't get you what you can use.
March 24, 2013