Revenue service demonstration (RSD): an advanced form of field  testing in which the railroad operates PTC-equipped trains in regular  service under specific conditions. Almost  all of the 40 railroads currently required to implement PTC must  demonstrate interoperability with at least one other railroad’s PTC  system. Railroads may receive a maximum 2-year extension from FRA past the  December 31, 2018, deadline if they meet six criteria set forth in statute. Specifically, railroads must demonstrate, to the satisfaction of FRA, that  they have: (1) installed all PTC system hardware consistent with the total  amounts identified in the railroad’s implementation plan; (2) acquired all  necessary spectrum consistent with the implementation plan; (3)  completed required employee training; (4) included in a revised  implementation plan an alternative schedule and sequence for  implementing the PTC system as soon as practicable but no later than  December 31, 2020; (5) certified to FRA that they will be in full  compliance with PTC statutory requirements by the date provided in the  alternative schedule and sequence; and (6) for Class I railroads and  Amtrak, initiated RSD or implemented a PTC system on more than 50  percent of the track they own or control that is required to have PTC. For example, we found in March 2018 that FRA  had not systematically communicated information or used a risk-based  approach to help commuter railroads prepare for the 2018 deadline or to  qualify for an extension. Many Passenger Railroads Remain in Early Stages of PTC Implementation and FRA Has Clarified Extension Requirements Passenger Railroads Continue to Install and to Test PTC Systems, and Report Previously Identified Implementation Challenges

As of June 30, 2018, many passenger railroads reported that they remain  in the equipment installation and field-testing stages, which are early  stages of PTC implementation. Specifically, 20 of the  29 passenger railroads reported being more than 90 percent complete  with locomotive equipment installation. One-third of passenger railroads are among those  designated by FRA as at-risk of both not meeting the end of 2018  implementation deadline and not completing the requirements necessary  to qualify for an extension. Since we reported in March 2018, Amtrak reported that it has initiated  both field testing and RSD, but most commuter railroads reported slower  progress with testing, especially with RSD. For example:
Laboratory and initial field testing: 19 of 28 commuter railroads  reported having initiated this testing as of June 30, 2018; this number  represents six more commuter railroads than the 13 we previously  reported as having initiated field testing as of September 30, 2017. Passenger railroad representatives reported that they continued to face  many of the same challenges we have previously identified, including  limited industry-wide availability of vendors and expertise and software  defects. FRA’s June 2018 symposium covered information  consistent with our March 2018 recommendation that the agency adopt a  method for systematically communicating information related to the  requirements and process for an extension to railroads. FRA also  clarified that for commuter railroads, initiating field testing was one  approach that could potentially qualify as substitute criteria, rather than  initiating RSD. Passenger Railroads and FRA Are Working toward Extensions, Leaving Substantial Work to Be Completed Beyond 2018 Most Passenger Railroads Anticipate Needing an Extension, and Many Plan to Start RSD Testing Beyond 2018

Almost three-quarters of passenger railroads (21 of 29) reported to us  that they plan to apply for an extension. Moreover, two-thirds of the commuter railroads (8 of  12) that plan to use substitute criteria intend to apply to use their initiation  of field integration or functional testing as substitute criteria, and many of  these will apply to begin field testing on only a portion of their track. Although FRA has recently made clear that it is authorized to grant  extensions based on initiating field testing or other FRA-approved  substitute criteria, this approach defers time-intensive RSD testing into  2019 and beyond. FRA’s Substantial Workload Remains a Concern

FRA’s already substantial workload is expected to increase as railroads  continue to submit documentation necessary for extensions and continue  PTC implementation activities. While FRA officials report that they  anticipate almost all railroads will likely request an extension, only one  passenger railroad had submitted an application for an extension as of  September 21, 2018. In addition, three passenger railroads  reported that they would complete all the requirements for full PTC  implementation by the December 31, 2018, deadline, but planned to  apply for an extension due to concerns that FRA would not be able to  review and certify their safety plans to enable them to reach full  implementation prior to the deadline. Although FRA has taken steps to provide key extension information to  railroads and to help ensure railroads’ compliance with PTC deadlines,  uncertainty remains, particularly in regard to FRA’s enforcement strategy  if railroads are noncompliant with the PTC implementation requirements,  such as if railroads were to fail to apply for an extension by the deadline. These issues—combined  with the ongoing implementation, testing, and interoperability challenges  that a number of railroads reported to us—raise questions as to the extent  FRA and the nation's passenger railroads are poised for full PTC  implementation by December 31, 2020.
Why GAO Did This Study

Forty railroads are currently required by statute to implement PTC, a communications-based system designed to slow or stop a train that is not being operated safely. Of these, 29 passenger railroads collectively provide over 500 million passenger trips annually. Although the deadline for PTC implementation is December 31, 2018, railroads may receive a maximum 2-year extension to December 31, 2020, if they meet certain statutory criteria.
GAO was asked to review passenger railroads' progress toward PTC implementation. This statement discusses (1) passenger railroads' PTC progress and FRA's steps to assist them, and (2) how passenger railroads and FRA plan to approach the 2018 and 2020 deadlines. GAO analyzed railroads' most recent quarterly reports covering activities through June 30, 2018; sent a brief questionnaire to all 40 railroads; and interviewed officials from FRA and 16 railroads, selected in part based on those identified as at-risk by FRA.

What GAO Found

As of June 30, 2018, passenger railroads (28 commuter railroads and Amtrak) generally remained in the early stages of positive train control (PTC) implementation—including equipment installation and early field testing. However, many passenger railroads are nearing completion of the equipment installation stage. For example, two-thirds of passenger railroads reported being more than 90 percent complete with equipment installation. With regard to testing, Amtrak has reported that it has initiated both field testing and revenue service demonstration (RSD), an advanced form of field testing that is required to fully implement PTC. However, most commuter railroads reported slower progress with testing. Of the 28 commuter railroads required to implement PTC, 19 reported initiating field testing, but only eight reported initiating RSD. The Federal Railroad Administration (FRA) recently clarified the criteria railroads must meet to qualify for a 2-year extension past the December 31, 2018, PTC implementation deadline. To receive an extension, railroads must meet six statutory criteria. For the sixth criterion, commuter railroads are authorized to either initiate RSD on at least one track segment or use FRA-approved substitute criteria. FRA clarified these and other requirements at three PTC symposiums hosted for railroads in summer 2018. For example, FRA officials said that initiating field testing instead of RSD was one approach that commuter railroads could potentially take to receive FRA's approval of substitute criteria. FRA's actions are consistent with GAO's March 2018 recommendation that the agency communicate to railroads the requirements and process for an extension.
Challenges related to PTC implementation and FRA's resources raise questions as to the extent FRA and the passenger railroad industry are poised for full PTC implementation by December 31, 2020. Most passenger railroads anticipate needing an extension, leaving substantial work for both railroads and FRA to complete before the end of 2020. Almost three-quarters of passenger railroads (21 of 29) reported that they, or the railroad which owns the track on which they operate, will apply for an extension. More than half of these railroads reported planning to apply for an extension using substitute criteria, and of these, eight intend to apply for substitute criteria based on field testing. Though use of substitute criteria is authorized in law, this approach defers time-intensive RSD testing into 2019 and beyond. In addition, passenger railroads reported that they continue to face many of the same challenges GAO previously identified, such as software defects and limited industry-wide availability of vendors. Further, passenger railroads expressed concern that FRA's workload will markedly increase as railroads submit requests for extension approvals. FRA has acknowledged concerns about the pending surge of submissions and agency officials said they have taken recent steps to help manage the forthcoming influx of documentation, such as reallocating resources. However, as of September 21, 2018, only one passenger railroad had applied for an extension. It remains unclear how many extension requests FRA will receive or what FRA's enforcement strategy will be for noncompliance with the statute, such as for railroads that fail to apply for an extension by the deadline.

What GAO Recommends

In March 2018, GAO recommended FRA take steps to systematically communicate extension information to railroads and to use a risk-based approach to prioritize agency resources and workload. FRA has taken some steps to address these recommendations, such as recently communicating and clarifying extension requirements to all railroads during three symposiums. GAO will continue to monitor FRA's progress.