Positive Train Control: As Implementation Progresses, Focus Turns to the Complexities of Achieving System Interoperability

Forty-two railroads are currently subject to the statutory mandate to implement PTC, a communications-based system designed to automatically slow or stop a train that is not being operated safely. Railroads were required to implement PTC by December 31, 2018, but would receive extensions up to December 31, 2020, if specific statutory requirements were met.

GAO was asked to review railroads' PTC implementation progress. This statement discusses (1) railroads' implementation progress and any related implementation challenges and (2) FRA's plans for overseeing railroads' implementation. GAO analyzed railroads' most recent quarterly reports covering activities through March 31, 2019; received responses from all 42 railroads on a brief questionnaire; and interviewed officials from FRA and 8 railroads, selected to include variation in implementation status and type of railroad, among other criteria.

Amtrak, commuter railroads, and freight railroads continue to make progress implementing positive train control (PTC), but significant work remains to achieve interoperability among the railroads' individual PTC systems. Since the end of 2018, many railroads reported making progress on testing and implementation of their own PTC systems. Four railroads reported reaching full implementation as of March 31, 2019, the same number in this stage at the end of 2018. However, many railroads remained in earlier stages of implementation, such as the 11 railroads that reported being in field testing. Nearly all railroads plan to complete full PTC implementation in the last quarter of 2020.

Full implementation with interoperability is achieved when the PTC system on the locomotive of a “tenant” railroad and the PTC system of a “host” railroad whose track is being used can successfully communicate, allowing uninterrupted movements over property boundaries. As of March 31, 2019, 11 of the 31 host railroads that must have interoperable PTC systems reported that they had achieved interoperability with at least 1 of their tenant railroads. Collectively, 38 of the 227 unique host-tenant relationships that require interoperability have been completed (17 percent), according to the Federal Railroad Administration (FRA). Most railroads reported to GAO that vendor and software issues were currently major or moderate challenges for PTC implementation. Over half of railroads also reported that interoperability was a major or moderate challenge, and can be complicated by software issues and coordinating host and tenant schedules, among other issues. For example, one railroad said that certain software functionality still had to be developed, tested, and implemented to address reliability issues and facilitate interoperability.

FRA continues to provide assistance and support to railroads on PTC interoperabilty and the testing process, but workload challenges for the agency persist. FRA will continue to face a substantial workload through 2020 as it oversees railroads' PTC implementation and reviews documents, including lengthy safety plans required for railroads to obtain PTC system certification. While FRA officials have described supporting interoperability and testing as areas of focus, they have not demonstrated how, within these broad areas, they are monitoring risk and prioritizing resources, as GAO recommended in March 2018. GAO continues to see value in FRA developing a risk-based approach to allocate its resources to oversee PTC.

In March 2018, GAO recommended FRA take steps to systematically communicate information to railroads and to use a risk-based approach to prioritize agency resources and workload. FRA concurred with these recommendations. FRA has taken actions to systematically communicate information to railroads. GAO will continue to monitor FRA actions with regard to allocating agency resources to oversee PTC.

Congress mandated the implementation of positive train control (PTC)  systems by certain railroads over a decade ago to prevent train-to-train  collisions and other types of accidents. PTC is a communications-based  system designed to automatically slow or stop a train that is not being  operated safely. Forty-two railroads are currently subject to the statutory  mandate to implement PTC, including 30 commuter railroads, Amtrak,  and several freight railroads. Over the years, we have periodically  reported and testified on railroads’ progress implementing PTC, which  has been a complex and lengthy process, involving nearly all major rail  lines and almost every aspect of railroads’ operations. Full  implementation includes but is not limited to equipment installation,  testing, interoperability, and system certification by the Federal Railroad  Administration (FRA). According to a 2018 National Transportation Safety  Board testimony, since the PTC mandate was enacted, 22 rail accidents it  investigated could have been prevented by PTC, including the December  2017 derailment of an Amtrak passenger train near DuPont, Washington,  that killed 3 passengers and injured 57 passengers and crewmembers.

While railroads were required to implement PTC by December 31, 2018,  FRA was required under the statutory mandate to grant railroads an  extension up to December 31, 2020, if they met specific requirements and  requested an alternative schedule and sequence (i.e., an extension).  Four railroads reported that they had fully implemented PTC for all rail  operations on their own track by yearend 2018. FRA approved 36  railroads’ requests for an extension. Consequently, while railroads have  installed all needed PTC equipment on locomotives and along tracks and  met some other statutory requirements, much work—particularly with  respect to interoperability—remains to fully implement PTC. Achieving  interoperability is critical as U.S. railroads often operate some or all of  their trains as “tenants” on the track of another railroad, known as the  “host.” The individual PTC systems of host and tenant railroads must be  interoperable in order for their respective trains to move safely and  seamlessly across others’ track.

My statement today addresses (1) the progress railroads have made to  complete PTC implementation, and any related implementation  challenges, and (2) FRA’s plans to oversee railroads’ PTC  implementation to meet the December 2020 deadline.

To describe railroads’ progress, we analyzed the most recent available  quarterly PTC implementation reports railroads submitted to FRA, that  reflected their progress as of March 31, 2019. We analyzed the reports to  determine the extent to which each railroad has initiated different stages  of testing and different steps to achieve interoperability with other  railroads. To identify the implementation status of tenant-only railroads,  we categorized them based on the furthest stage of implementation their  host(s) railroads have reached. Based on our review of these data for  anomalies, outliers, or missing information and our previous assessment  of such quarterly reports for our March 2018 and September 2018  testimonies, we determined that these data were sufficiently reliable for  our purposes of describing railroads’ progress in PTC implementation. In  addition, we interviewed representatives from Amtrak, two freight  railroads, and five commuter railroads, selected to ensure variation in  PTC implementation status and number of tenant railroads. To describe  railroads’ progress and FRA’s plans to oversee PTC implementation, we  sent the 42 railroads a questionnaire to obtain information on their  implementation progress, including interoperability, as of May 31, 2019;  challenges to implementing PTC; and any guidance or assistance needed  from FRA. We received responses from all 42 railroads. We also  interviewed industry associations for commuter (American Public  Transportation Association) and freight (Association of American  Railroads) railroads. We reviewed applicable laws and FRA regulations,  presentations, reports, and guidance, and we interviewed FRA officials in  headquarters and three of FRA’s nine PTC field specialists who serve as  the technical leads for the PTC systems most commonly used by  railroads. We also reviewed prior GAO products related to PTC.

We conducted this performance audit from May 2019 to July 2019 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

The vast majority of the 42 railroads subject to the statutory mandate to  implement PTC—including 30 commuter railroads, Amtrak, seven Class I  and four Class II and III freight railroads—are implementing one of three  types of PTC systems. These systems include the Interoperable  Electronic Train Management System (I-ETMS), the Advanced Civil  Speed Enforcement System II (ACSES), and Enhanced Automated Train  Control (E-ATC). While these PTC systems are functionally similar, the  technologies they use differ. For example, to determine a train’s location,  ACSES and E-ATC rely on equipment embedded on the track while I- ETMS uses Global Positioning System information. ACSES and E-ATC  both supplement existing train control systems to provide all required PTC  functionality, while I-ETMS was designed as a new system to provide this  functionality.

As noted above, testing is one of the many steps to achieving full  implementation. Through multiple stages of testing, which are  summarized below, railroads must demonstrate that the PTC system  meets functional requirements.

Laboratory testing: locomotive and wayside equipment testing in a  lab environment to verify that individual components function as  designed.

Field testing: includes several different tests of individual  components and the overall system, such as testing each locomotive  type to verify that it meets functional requirements and field integration  testing—a key implementation milestone to verify that each PTC  component is integrated and functioning safely as designed.

Revenue service demonstration (RSD): an advanced form of field  testing in which the railroad operates PTC-equipped trains in regular  service under specific conditions. RSD is intended to validate the  performance of the PTC system as a whole and to test the system  under normal, real-world operations.

Using results from field and RSD testing, combined with other  information, host railroads must then submit a safety plan to FRA for  system certification and approval. We previously reported that these  safety plans have been up to 5,000 pages in length. Once FRA approves  a safety plan, the railroad receives system certification, which is required  for full implementation, and is then authorized to operate the PTC system  in revenue service. According to FRA officials, the FRA may impose  conditions to the PTC safety plan approval as necessary to ensure safety,  resulting in a conditional certification.

Interoperability is achieved when the locomotives of any host railroad and  tenant railroad operating over the same track segment can successfully  communicate with and respond to the other railroad’s PTC system,  allowing uninterrupted movements over property boundaries. For  example, when a locomotive enters another railroad’s territory as a  tenant, it immediately needs information about the upcoming track—such  as any temporary speed restrictions in place due to track work (see fig.  1).

To achieve interoperability, railroads have to complete a series of steps  including (1) additional installation work (such as installing equipment on  a tenant railroad’s locomotives) and scheduling (such as coordinating with  the relevant railroad to reach any needed agreements and identify dates  for testing), (2) laboratory testing, (3) field testing, and (4) RSD or  revenue service operations. Many railroads will complete much of the  implementation for their own PTC systems, such as starting RSD on  some or most of their track, before they begin to take steps to achieve  interoperability with other railroads. However, a railroad can take steps to  achieve interoperability with other railroads while simultaneously  completing field testing or other stages of testing on its own PTC system.

FRA is responsible for overseeing railroads’ implementation of PTC, and  the agency monitors progress and provides direct assistance to railroads  implementing PTC. For example, each railroad had to develop an FRA- approved PTC implementation plan that includes project schedules and  milestones for certain activities, and a railroad is required to report  quarterly and annually to FRA on its PTC implementation status relative  to its implementation plan. FRA also provides technical assistance to  railroads, addresses questions, and reviews and approves railroads’  documentation, including test and safety plans. FRA has a national PTC  project manager, designated PTC specialists in the eight FRA regions,  and approximately a dozen engineers, test monitors, and other staff  responsible for overseeing technical aspects of implementation. FRA also  has oversight tools, which includes authority to impose civil penalties  when a railroad fails to meet certain statutory PTC requirements. Since  2017, FRA reports that it has assessed nearly $400,000 in civil penalties  against railroads that failed to comply with their implementation plan  milestones or reporting requirements.

Railroads Continue to Make Progress Implementing PTC, but Significant Work Remains to Achieve Interoperability

Railroads’ Implementation of Their Own Systems Has Advanced, but Some Commuter and Smaller Freight Railroads Remain in the Early Stages of Testing

Since the end of 2018, some railroads have reported making progress on  testing and implementation of their own PTC systems. Figure 2 shows the  42 railroads’ reported progress by PTC implementation stage.

Six railroads—two Class Is and four commuters—reported to FRA that  they had implemented PTC on all of their own territories but had not  completed interoperability as of March 31, 2019, and almost all these  railroads reported being in this stage at the end of 2018. In addition, as  of March 31, 2019, no additional railroads beyond the four that were  complete at the end of 2018 reported reaching full implementation. Nearly  all railroads still implementing PTC plan to reach full implementation in  the last quarter of 2020, based on our analysis of railroads’ extension  requests.

Few railroads reported moving into RSD during the first quarter of 2019,  and the extent of RSD testing being conducted by railroads in this stage  varied considerably. Of the 19 railroads that reported RSD testing on  some portion of their own track as of March 31, about half (9 of 19)  reported RSD testing on more than 75 percent of their total route miles,  while about a quarter (5 of 19) reported RSD testing on less than 25  percent of their total route miles. RSD testing also varied between Class I  railroads and commuter railroads. On average, the 5 Class I railroads in  this stage reported RSD on 86 percent of route miles, while commuter  railroads reported an average of 39 percent of route miles in RSD.

Moreover, based on our analysis, 11 railroads—7 commuters and 4 Class  II and III railroads—reported that they remained in field testing as of  March 31, 2019. Similar to railroads in RSD testing, the extent of field  testing reported by railroads varied. Of the 11 railroads in field testing,  most (7) reported field testing on the majority or all of their route miles,  whereas 4 railroads—all commuters—reported conducting field testing on  less than half of their route miles. Based on railroads’ responses to our  questionnaire, railroads’ PTC implementation status did not change  significantly as of May 31, 2019; two additional railroads—both  commuters—began RSD testing on some portion of their track, and one  commuter railroad began field testing.

Host Railroads Have Achieved Interoperability with Less Than 20 Percent of Tenants, but Nearly All Railroads Have Started Interoperability Planning

As of March 31, 2019, 11 of the 31 host railroads that must have  interoperable PTC systems reported to FRA that they had achieved  interoperability with at least 1 of their tenant railroads. Collectively, of  the 227 unique host-tenant relationships that require interoperability, FRA  reported that railroads had achieved interoperability for 38 (17 percent) of  these relationships. The number of tenants each railroad must work to  achieve interoperability with ranges from 1 to 31 railroads, based on  railroad reports to FRA. For example, Class I railroads, as host railroads,  average about 18 tenants, while commuter railroads average about 3  tenants. A railroad does not generally start work to achieve  interoperability with all the railroads it interoperates with at once,  according to FRA; instead a railroad will prioritize its interoperability work.  For example, representatives from one Class I railroad we interviewed  said it prioritized achieving interoperability in the following sequence: first  with commuter-railroad tenants given the need to ensure passenger  safety; second with other Class I railroads given the high total miles of  track they share; and finally with smaller Class III railroads. In addition, a  railroad may be in multiple interoperability steps (e.g., installing, testing)  with different tenants at the same time.

FRA counts a relationship as having achieved interoperability if the tenant  is operating PTC on all of the host’s track miles. This binary measure for  interoperability—that is, achieved or not—does not describe the extent to  which railroads have started work on interoperability or, according to  representatives from two railroads we interviewed, reflect when  interoperability has been achieved along most but not all of its host’s  track. Railroads reported to FRA that they had begun work on  interoperability for more than 90 percent of the remaining host-tenant  relationships that need to achieve interoperability. In particular, based on  their quarterly reports, railroads were installing for 82 host-tenant  relationships and testing for 89 host-tenant relationships as of March 31,  2019. Overall, the status of interoperability work did not vary much among  Class I, commuter, and Class II and III railroads.

FRA officials and others we spoke with could not provide an estimate of  how long it takes on average for two railroads to complete the individual  steps to achieve interoperability. Representatives from industry  associations we interviewed said that it can vary. An FRA specialist we  interviewed agreed, explaining that interoperability field testing, for  example, varies based on track availability. One railroad might complete  testing in 4 days while another railroad might need weeks because it can  only test at specific times. In its quarterly reports, FRA asks host railroads  to provide the scheduled date for completing interoperability testing with  each tenant railroad. As of March 31, 2019, seven railroads reported that  they did not anticipate completing interoperability testing with at least one  tenant until the last quarter of 2020.

Railroads Continue to Report Challenges with Vendors and Software, and Face New Interoperability Challenges

In responding to our May 2019 questionnaire, most railroads reported that  vendor and software issues remain major or moderate challenges for  PTC implementation. As part of our ongoing work related to PTC, we  have reported that railroads have faced challenges associated with the  limited number of vendors that design PTC systems, provide the software  and hardware, and conduct testing. However, as representatives of half  of the railroads we interviewed emphasized, vendor and software issues  are more acute now because as the 2020 deadline nears, less time  remains to address these issues and associated delays. Software and vendor issues can be interrelated as a small pool of vendors develop and  update the software that supports railroads’ PTC systems.  Representatives from several railroads and FRA specialists we  interviewed said that software issues routinely arise in lab testing, field  testing, and RSD that require vendor revisions before a railroad’s PTC  implementation can continue. For example, representatives from one  railroad said that existing software defects affecting its PTC system must  be addressed and a new version of the software is needed before they  can start RSD. They added that they had no control over this process, as  they must rely on the vendor to provide reliable software. Representatives  from this railroad also noted that resolving software issues is often not  entirely within a railroad’s control due to the need for vendor support, in  contrast to some earlier challenges leading up to the 2018 deadline,  where, for example, the railroad itself had more control as it was installing  equipment and could more clearly track progress.

Moreover, the limited supply of vendors and high demand for services as  railroads work simultaneously to implement PTC by the 2020 deadline  continue to pose problems. For example, representatives from one  railroad said their vendor has consistently had issues meeting milestones  and delivering on its commitments. Representatives from a small railroad  said they had limited internal resources to implement PTC, making the  railroad’s progress heavily reliant on its vendor. Representatives from two  other railroads and FRA officials also highlighted implementation delays  caused by recalls for some locomotive equipment, which has caused  additional work for railroads as well as the vendor. Specifically, the  equipment had to be removed, sent in for repair, and then re-installed.

More than half of the railroads implementing PTC also responded to our  questionnaire that interoperability was a major or moderate challenge.  Railroads said that interoperability can be complicated by software issues  and coordinating host and tenant railroad schedules, when asked to  describe the biggest challenges to achieving interoperability. Fifteen railroads specifically mentioned software issues, and representatives from  several railroads noted that interoperability will require reliable software.  For example, one railroad reported that certain software functionality  remains to be developed, tested, and implemented to facilitate  interoperability and to address software reliability issues that have caused  system disruptions. Also, 14 railroads noted that scheduling time with  other railroads to begin interoperability testing can be cumbersome and  time consuming. For example, several railroads that we interviewed and  that responded to our questionnaire said that scheduling can be  complicated by whether other railroads have made enough progress on  their own PTC implementation to begin work on interoperability.

According to FRA officials, interoperability challenges also differ across  PTC systems and geographic areas. Below, we use the Northeast  Corridor and the Chicago metropolitan area—where most railroads are  implementing ACSES and I-ETMS, respectively—to illustrate the  challenges faced in working to achieve interoperability. However,  railroads in other areas or implementing other PTC systems may face  some of these same challenges or face additional different challenges.

Over a dozen railroads operating on the Northeast Corridor and in the  surrounding area are required to implement PTC. The Northeast Corridor  runs from Washington, D.C., to Boston, Massachusetts, and Amtrak  predominantly owns track on the corridor. Eight commuter railroads,  Amtrak, and most freight railroads are implementing a form of the ACSES  system on at least a portion of their equipment and track. In some cases,  railroads in the Northeast will be operating two different PTC systems  concurrently on the same track, which will add to the complexity of  interoperability, according to FRA. Examples of interoperability  challenges faced in the Northeast include:

Software issues. PTC software presents particular challenges in the  Northeast because software is being supplied by multiple vendors and  has been developed to accommodate railroads’ existing systems that  have different configurations. Therefore, according to FRA officials,  ACSES does not have a common set of requirements or  specifications. Also, even if two railroads use the same vendor for  their locomotive equipment or software, each railroad may use a  different version of software. In addition, representatives from two  railroads that operate in the Northeast told us they built different  software functionality into their PTC systems to accommodate their  own operations, so additional work is needed to resolve such  differences to achieve interoperability. In light of these software  issues, representatives from one industry association and one railroad  we interviewed said that Northeast Corridor railroads are discussing  creating a software management process to aid interoperability.

Boundary issues. A train needs to seamlessly operate PTC when it  crosses the boundary between two railroads’ territories, as previously  described. According to a rail industry association, as of June 2019,  there are about 20 boundaries on the Northeast Corridor where more  work is needed to ensure seamless operation. FRA officials and one  industry association said boundary issues are complex and time- consuming to resolve but not insurmountable. For example, FRA  officials said a railroad could install its own equipment such as  transponders and wayside devices across the boundary to create an  overlap between their system and that of the other railroad.

Securing PTC wireless communication. FRA requires that PTC  wireless railroad communications be encrypted. However, a solution  that aims to encrypt all PTC wireless communication and data  transmittal among railroads operating ACSES in the Northeast is  currently in lab development. In August 2016, Amtrak received a grant  from FRA to create this solution for ACSES. Amtrak originally planned  to implement this solution in December 2018, but Amtrak has  experienced delays and currently estimates that it will implement the  solution by January 2020. However, Amtrak has reported several risks  that it will need to overcome to meet this implementation deadline.  Further delays could affect railroads’ ability to fully implement PTC in  the Northeast by the December 2020 deadline. FRA noted it will  continue to monitor and support the railroads as they implement  security measures in the Northeast.

Ten I-ETMS railroads that operate in the greater Chicago metropolitan  area received extensions to implement PTC. Throughout PTC  implementation, FRA, industry associations, and railroads have identified  Chicago as a place where interoperability would be challenging due to the  dense freight, passenger, and commuter operations in the area.  Examples of such challenges include:

Software issues. According to FRA and railroads we interviewed,  software issues have slowed interoperability work by railroads  implementing I-ETMS. The underlying problem is the memory  available on the locomotive equipment, which is needed to store its  railroad’s track data, according to FRA and railroads we interviewed.  To be interoperable, the locomotive equipment also needs to store  and exchange multiple railroads’ track data, causing the memory to fill  up very quickly. According to railroad representatives, memory  limitations for I-ETMS locomotive equipment prohibited railroads with  large track data files—mainly the Class I freight railroads—from being  able to interoperate. The vendor for this equipment has been working  on a software solution for this problem, and according to a few  railroads we interviewed, the vendor delivered an interim software  solution in March 2019 that allowed the four largest Class I railroads  to achieve interoperability. However, this software was delivered 7  months later than initially planned, and an additional software solution  is still needed to allow the locomotive equipment’s memory to store  the data of all railroads operating I-ETMS, according to  representatives from two railroads and an industry association we  interviewed.

Other technical issues. Railroads in the Chicago area conducted  modeling to help ensure that sufficient communications capacity (e.g.,  spectrum and radio capacity) would be available to support PTC  interoperability in the region. According to one industry association,  while actual PTC operations in the area are minimal right now relative  to full expected operations, railroads must continue to monitor the  communications capacity as more railroads progress with their own  PTC implementation and start to interoperate. For example, railroads  may have to re-engineer their radio networks, such as re-routing  certain communications through different radio towers and other  network connections, if issues are subsequently identified.

Scheduling interoperability work with other railroads. Within the  Chicago area, the total number of railroads and the number of  railroads that have to be interoperable on a single line complicates  interoperability. Chicago is the busiest rail hub in North America and  handles one-fourth of the nation’s freight rail traffic. Nearly 500 freight  trains and over 700 passenger trains travel through the area on tracks  owned by several different railroads every day. For example, one  commuter railroad, for one of its lines, operates over track owned by  four host railroads that alternates with its own track. Achieving  interoperability for this line will involve sequencing and scheduling  with multiple railroads to activate PTC along the entire line, including  across the numerous boundaries between different railroads’  territories, according to representatives from that railroad. According  to one FRA specialist, work to achieve interoperability in the Chicago  area will ramp up in late 2019 or early 2020. As a result, many  railroads will have to coordinate schedules to sequence  interoperability work across the dozens of host-tenant relationships in  the area.

FRA Is Assisting Railroads with Testing and Interoperability while PTC Workload Challenges Persist

FRA officials told us that the agency continues to provide assistance to  railroads on interoperability and to support railroads through the testing  process. In summer 2019, FRA began an effort to meet with all freight,  non-Class I tenant railroads that have to be interoperable with host  railroads required to implement PTC. FRA officials said they will use  meetings with these 72 individual tenant railroads to discuss PTC  requirements and review the railroads’ plans for implementing PTC with  their host railroads. FRA officials said they have also continued to meet  regularly with railroads still in field testing or starting RSD on their own  PTC systems. For example, FRA officials said the agency meets weekly  or monthly with each railroad that has not yet initiated RSD to provide  targeted technical assistance to resolve any issues. FRA and  representatives from one railroad also told us that FRA has met with  vendors to discuss specific equipment or software issues and to stress  the importance of resolving these issues. FRA also participates in  meetings held by the railroad industry’s PTC working groups, including  those focused on the Northeast Corridor and Chicago area, as needed.

In addition, FRA officials told us that they are working with industry to  improve the safety plan review process. Specifically, according to a June  FRA presentation, FRA is working with two railroads and an industry  association to create templates for streamlined, more consistent safety  plans for two types of PTC systems—I-ETMS and E-ATC. The goal of the  template is to reduce the burden on both railroads and FRA by using a  shorter format and, where possible, relying on standardized system  documents. FRA officials anticipate that the templates will be ready for  other railroads to use in fall 2019. In addition, FRA has contracted for  help in reviewing safety plans. However, representatives from four  railroads and two industry associations we interviewed noted that they  remained concerned about the amount of time it has taken FRA to review  safety plans. FRA reported in February 2019 that it took on average 331  days to review a safety plan.

While it is too early to determine the effect of FRA’s efforts to improve the  safety plan review process, much work remains for FRA in the next 18  months. According to FRA, 23 railroads will be submitting safety plans in  the next 12 months. While FRA has conditionally certified 13 PTC  systems as of March 31, 2019, these railroads, too, are required to  continue to work with FRA to provide additional documents to respond to  FRA’s conditions. Some of these railroads also plan to resubmit safety  plans for FRA to review, hoping to receive an unconditional certification  before the December 2020 deadline.

In March 2018, we reported that railroads had expressed a need for  additional clarification about applying for an extension and that FRA could  provide more consistent information to railroads. We recommended that  FRA identify and adopt a method for systematically communicating  extension-related information to railroads. In 2018, FRA held three  symposiums for railroads to consistently communicate information to help  railroads prepare to qualify for an extension and to understand what was  required to have a fully implemented PTC system. FRA held two similar  sessions in February and June 2019. Representatives from most of the  railroads we interviewed (six of eight) said they have been happy with the  communication with FRA, via these sessions as well as regular meetings  with FRA’s PTC field specialists and other staff. For example,  representatives of two railroads said it was helpful to have the FRA  Administrator attend the sessions with railroads and talk directly to  railroad representatives. In addition, clarity of information from FRA was  the lowest rated challenge in response to our questionnaire, with 29  railroads reporting this as a minor challenge or not at all a challenge.

While FRA has made improvements, the extended 2020 deadline for full  PTC implementation is less than 18 months away, and FRA and railroads  have substantial work to complete and challenges to address before that  deadline. Moreover, unlike the 2018 deadline, no additional extensions  are available beyond December 2020. In March 2018, we  recommended that FRA develop an approach to use the information it  gathers on railroads’ PTC implementation progress to prioritize the  allocation of resources to address the greatest risk. FRA agreed with  this recommendation, and while FRA officials have described testing and  interoperability as areas of focus in 2018 and 2019, they have not  articulated or demonstrated how, within these broad areas, they are  monitoring risk and prioritizing resources. For instance, FRA plans to  meet with all 72 tenant railroads in over 30 meetings rather than use the  data it collects from host railroads to target this outreach. In addition,  while FRA will have to review dozens of new and resubmitted safety  plans in the coming months, FRA officials have not identified how they will  prioritize these reviews relative to other reviews (e.g., other  documentation that railroads submit as they continue testing on their own  systems and for interoperability).

According to FRA, it has communicated to railroads in industry-wide  meetings that conditional certification for a PTC system is generally  sufficient to meet the statutory requirement for full implementation; FRA  noted this would only not be sufficient if a railroad’s PTC system did not  otherwise meet the technical requirements in regulations and one or more  of the conditions related to such non-compliance. However,  representatives from two railroads we interviewed also said it was unclear  whether conditional certification would be enough for a railroad to comply  with the 2020 deadline, and uncertainty remains about which conditions  must be addressed to meet the statutory requirement for full  implementation.

Related to system certification, representatives from three railroads and  one industry association we interviewed also said FRA still needed to  clarify how it would handle situations where a host or tenant railroad is not  fully implemented by the 2020 deadline. Although the FRA Administrator  has publicly said he will enforce the implementation deadline (which is  December 31, 2020, for most railroads) and recommend assessing the  maximum civil penalty against a railroad that did not meet its deadline,  FRA has not clarified if this would apply in situations where a host or  tenant relationship affects another railroad’s implementation. We continue  to see value in FRA developing a risk-based approach to allocating its  limited resources and will continue to monitor FRA’s actions on this  recommendation.

Going forward, FRA will also need to transition to overseeing PTC as a  routine part of railroad operations after the 2020 deadline. Similarly,  railroads will need to transition from implementation—largely done by  contractors—to operating and maintaining their own PTC systems.  Several railroads, in response to our questionnaire, said that they  anticipate difficulties funding ongoing operations and maintenance as well  as managing software and other updates. Therefore, December 31, 2020,  represents not only the deadline for full PTC implementation but also a  point after which railroads and FRA will face a new operational and  oversight environment.

Chairman Wicker, Ranking Member Cantwell, and Members of the  Committee, this concludes my prepared statement. I would be pleased to  respond to any questions that you may have at this time.

If you or your staff have any questions about this testimony, please  contact Susan Fleming, Director, Physical Infrastructure at (202) 512- 2834 or FlemingS@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this statement. GAO staff who made key contributions to this testimony  are Susan Zimmerman (Assistant Director); Katherine Blair Raymond;  Delwen Jones; Emily Larson; Joanie Lofgren; Shannin G. O’Neill; Josh  Ormond; Madhav Panwar; Marcus Robinson; Maria Wallace; Crystal  Wesco; and Elizabeth Wood.

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Forty-two railroads, including Amtrak, commuter, and freight railroads, are required to implement positive train control (PTC)—a communications-based system designed to slow or stop a train that is not being operated safely. The deadline for PTC implementation was December 31, 2018, but railroads that meet certain criteria were able to ask for a maximum 2-year extension.

We testified that railroads continue to make progress implementing PTC but face challenges—including vendor and software issues—to completing full implementation by December 2020.