All Railroads With PTC Requirements Claim to Meet Dec. 31 Deadline

January 3, 2019

All 41 railroads with positive train control (PTC) requirements submitted by Dec. 31, 2018 documentation claiming they fully implemented PTC or else qualified for an “alternative schedule,” the Federal Railroad Administration (FRA) announced on New Year’s Eve.

Four Class I railroads have self-reported that they fully implemented an FRA-certified and interoperable PTC system on all of their required main lines: the Port Authority Trans-Hudson (PATH), North County Transit District, Portland & Western Railroad, and the Southern California Regional Rail Authority (Metrolink).

Of the remaining 37, 33 have submitted a written notification requesting FRA’s review and approval of an alternative schedule, which would give them up to two years to finish testing their systems and entering them into revenue service, as well as ensuring their systems’ interoperability with other railroads’ systems. The FRA has approved nine of these requests already and must review the other 24 within 90 days.

To qualify for an alternative schedule, railroads must meet six criteria:

  1. Installed all PTC system hardware necessary for implementation
  2. Acquired all spectrum necessary for implementation
  3. Completed the employee training for all applicable personnel where the PTC system is currently in field testing or being operated in revenue service demonstration or revenue service
  4. Made sufficient progress on advanced testing or implementation (for Amtrak and Class I railroads, that means implementing a PTC system or initiating FRA-approved RSD on the majority of territories or route miles that the railroad owns or controls; for all other railroads, it means initiating FRA-approved RSD on at least one territory)
  5. Included in its implementation plan an alternative schedule for implementing the system as soon as practicable, but not later than Dec. 31, 2020
  6. Certified to FRA in writing that it will be in full compliance with the law on or before the deadline in the proposed alternative schedule

Of the remaining four, three are tenant-only railroads that submitted supporting documentation along with their host railroads’ alternative schedule requests: Northstar Commuter Rail and Sound Transit for BNSF Railway, and Connecticut DOT for Amtrak.

The last one, New Mexico Rail Runner Express (NMRX), received a temporary exception for its main line for unique legal reasons; Its implementation plan establishes that the railroad will fully implement a PTC system by Dec. 31, 2020. The railroad has made no progress yet towards implementing PTC according to its Q4 2018 progress report.

What comes next?

While every railroad has presumably installed all hardware, acquired all spectrum, trained all necessary employees, and at least begun revenue service demonstration (assuming all of the alternative schedule requests are approved), most of them still have a lot of work to do—particularly those with territories not yet in RSD.

According to Susan A. Fleming, Director of the Physical Infrastructure Team at the Government Accountability Office (GAO), it took railroads an average of two years to move from initial field testing to revenue service. That means all of the railroads applying for an alternative schedule may need the full two-year extension before their PTC systems are fully implemented.

But the biggest challenge post-2018 will be the interoperability of different railroads’ PTC systems. Almost all of the railroads with PTC requirements share tracks with at least one other railroad, and interoperability is critical to ensuring trains using one PTC system can communicate with trains and infrastructure using a different PTC system.

The interoperability component had created a dilemma for railroads that were further along with implementation than others; even if they had otherwise finished implementing their systems, the fact that they could not demonstrate interoperability with other railroads meant they could not be FRA-certified and would have to apply for an alternative schedule.

“You can’t test interoperability with a tenant that isn’t ready to test with,” Scott Naparstek, Executive Vice President and Chief Operating Officer of Amtrak, told Congress back in September. “I can’t prove Amtrak’s system’s 100 percent interoperability.”

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