Morning Buddy, I worked on this over the weekend and this was the end result. Initially I started working on that checklist that I had from TEXRail, but about 20 pages into it I realized that the checklist was really just an audit that the plan meets the requirements of a plan…not an assessment of the three things the regulation asked for when doing an assessment: • The extent to which the plan is fully implemented • Compliance with the elements that are implemented • Did the railroad meet the goals they described? The checklist doesn’t do that so I went in the direction of addressing these three specific items. I also stayed with the approved plan rather than try to merge the new plan into an assessment. There were several elements that Stephanie Paiz claimed were fully implemented when she submitted her plan for approval, so I described those to cover the first bullet point. For the second bullet point I reviewed our compliance with those implemented items and found a few defects…the most significant being that we didn’t have any safety meetings. For the third bullet point I had no choice but to say we didn’t meet any of those goals, and I set a new timeline to complete those goals. It doesn’t look great, but they can’t violate us for not meeting goals. We have an obligation to be fully implemented within 36 months of approval, so any interim failures (other than not complying with something we say is fully implemented) are just something for us to work on. Liz will be here at 10. We think Robert will sign this as is and then she’ll submit it today.
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