According to a recent FRA presentation,  completing key activities within this phase is the near-term focus for many  commuter railroads. Railroads are required to report  annually to FRA certain information on their implementation progress. Commuter railroads that will not be able to implement a PTC system by  December 31, 2018, may receive a maximum 2-year extension if they  meet six criteria set forth in statute. Specifically, commuter railroads must  demonstrate, to the satisfaction of the Secretary of Transportation, that  they have: (1) installed all PTC system hardware; (2) acquired all  necessary spectrum; (3) completed required employee training; (4)  included in a revised implementation plan an alternative schedule and  sequence for implementing their PTC system as soon as practicable; (5)  certified to FRA that they will be in full compliance with PTC requirements  by the date provided in the alternative schedule and sequence; and (6)  either initiated RSD on at least one territory required to have operations  governed by a PTC system or “met any other criteria established by the  Secretary.”

	Progress Reported in Some Implementation Areas, but Significant Work Remains

Most of the 29 commuter railroads have reported progress in some of the  key areas of PTC implementation that FRA monitors, such as locomotive  and wayside equipment installation, but the amount of progress reported  varies across individual railroads (see fig. Over Half of Commuter Railroads May Be at Risk of Not Meeting the 2018 Deadline or Criteria for RSD-based Extension, Though Numerous Factors Create Uncertainty

Based on our analysis of the PTC schedules of the 29 commuter  railroads, over half may not have sufficient time to complete activities  needed to implement PTC by the end of 2018 or to qualify for an  extension of that deadline by meeting criteria based on initiating RSD— for the purposes of this statement, referred to as an RSD-based  extension. Our analysis found that at least one quarter, and potentially up to  approximately two thirds, of commuter railroads may not have sufficient  time to enter RSD and, thus, may not meet the 2018 PTC implementation  deadline or qualify for an RSD-based extension. When we applied the lower end of FRA’s estimate, we found  that it further increases the potential risk for 14 railroads that plan to  start field testing less than a year prior to the 2018 deadline. Furthermore, a  number of factors can affect commuter railroads’ planned and future  progress, including unexpected setbacks installing PTC components and  resources and capacity issues. These tenant-only commuter railroads, however, have to coordinate field  testing and RSD with the host railroads. Information Sharing: FRA officials said that they have primarily used  informal assistance and participation in group meetings to convey  information related to the implementation process and specific  milestones necessary to meet the 2018 deadline or qualify for an  extension. FRA Has Not Systematically Communicated Information to Help Railroads Prepare for the 2018 Deadline or to Qualify for Extensions

While the majority of the railroad representatives we met with said FRA  officials were consistently available to discuss issues that arise during  day-to-day PTC implementation activities, the information conveyed by  these officials has sometimes been inconsistent. Representatives from some commuter railroads we met with were  likewise unclear about the agency’s approach to reviewing and granting  extension requests. Representatives from three commuter railroads said  clarification of FRA’s planned approach would be helpful as the deadline  approaches. Absent systematic communication articulating  the agency’s planned approach for the extension process, railroads may  not have the information they need to effectively prepare for the deadline  or seek an extension. While FRA has  used its data to identify at-risk railroads, it has not used this information to  prioritize how to allocate its resources or address risks. FRA cannot expect to provide information and  guidance to railroads individually, and therefore, adopting a risk-based  communication strategy could help it more efficiently share information in  the coming year. DOT also provided technical comments, which we  incorporated as appropriate. Appendix I: Objectives, Scope, and Methodology

This statement examines commuter railroads’ implementation of positive  train control (PTC). Specifically, this report addresses:  commuter railroads’ progress in implementing PTC; how many, if any, commuter railroads may be at risk of not meeting  the mandated PTC deadline or certain extension criteria, and what  factors may be affecting implementation progress; and  the extent to which FRA’s management and oversight approach has  helped ensure that commuter railroads either meet the deadline or  qualify for an extension. We also reviewed previous GAO work on PTC and  applied Standards for Internal Control in the Federal Government to  FRA’s role overseeing PTC implementation, including the principles that  management should externally communicate the necessary quality  information to achieve the entity’s objectives and that management  should identify, analyze, and respond to risks. Finally, to determine which railroads anticipate completing implementation  before the December 31, 2018 deadline and which plan to seek any RSD- based extension, we obtained information from all 29 commuter railroads  to identify which railroads plan to implement PTC by the 2018 deadline  and which plan to submit an alternative schedule (that is, a request for an  extension) to implement PTC after the December 31, 2018 deadline.
Why GAO Did This Study

Forty-one railroads including 29 commuter railroads are required by statute to implement PTC. Commuter railroads unable to implement a PTC system by December 31, 2018, may receive a maximum 2-year extension if they meet certain statutory criteria.
GAO was asked to review commuter railroads' PTC implementation. Among other objectives, this statement discusses (1) commuter railroads that may not be positioned to meet the PTC deadline or to qualify for an extension, and factors affecting their progress, and (2) the extent to which FRA's management and oversight approach has helped ensure that commuter railroads meet the deadline or qualify for an extension.
GAO analyzed commuter railroads' most recently available quarterly progress reports and collected information on planned implementation schedules, interviewed 19 commuter railroads—including 14 FRA identified as at-risk and 5 others further ahead with implementation—and interviewed FRA officials.

What GAO Found

The Federal Railroad Administration (FRA) is responsible for overseeing railroads' (including commuter railroads') implementation of positive train control (PTC) by December 31, 2018. PTC is a communications-based train control system designed to prevent certain types of accidents and involves the installation, integration, and testing of hardware and software components. For example, railroads must install equipment on locomotives and along the track, and complete field testing, including revenue service demonstration (RSD)—an advanced form of testing that occurs while trains operate in regular service.
GAO's analysis of commuter railroads' PTC scheduled milestones for two key activities necessary to meet the 2018 deadline or qualify for an RSD-based extension (one of the statutory options) found that as many as two-thirds of the 29 commuter railroads may not have allocated sufficient time to complete these milestones. Specifically, in comparing the commuter railroads' schedules to FRA's estimates of the time required to complete these milestones and the experiences of railroads that have already completed them, GAO's analysis found that from 7 to 19 commuter railroads may not complete the milestones before the 2018 implementation deadline or qualify for an RSD-based extension. For example, FRA estimates that field testing (one of the milestones) takes at least one year, but GAO found that 14 commuter railroads plan to start this testing less than a year before the 2018 deadline, increasing the potential risk that this milestone will not be completed. However, FRA has the authority to establish alternative criteria for an extension not based on RSD, and several other factors can affect commuter railroads' planned and future progress. As a result, the number of commuter railroads at risk of not meeting the deadline or qualifying for an extension could increase or decrease in the coming year.
FRA's PTC management and oversight includes monitoring commuter railroads' progress, reviewing documentation, and sharing information with them, but the agency has not systematically communicated information or used a risk-based approach to help these railroads prepare for the 2018 deadline or qualify for an extension. GAO found that FRA has primarily used informal assistance, meetings with individual railroads, and participation in industry-convened groups to share information with commuter railroads, and in some cases the information conveyed has been inconsistent according to industry representatives. Some commuter railroads also told GAO that clarification about the agency's planned process for reviewing and approving extension requests would be helpful. Federal internal control standards state that management should externally communicate the necessary quality information to achieve its objectives. While FRA officials have said they are working to identify additional ways to convey extension-related information, they have not yet done so. Moreover, although FRA receives information from commuter railroads on their progress in implementing PTC, it has not used this information to prioritize resources using a risk-based approach. With the year-end 2018 deadline approaching, and an anticipated significant increase in FRA's workload, targeting resources to the greatest risk can help better ensure that FRA effectively fulfills its oversight responsibilities and provides commuter railroads the information they need to prepare for the 2018 deadline or seek an extension.

What GAO Recommends

GAO recommends FRA identify and adopt a method for systematically communicating information to railroads and use a risk-based approach to prioritize its resources and workload.
DOT concurred with the recommendations. The agency also provided technical comments, which were incorporated as appropriate.