In much of the  country, Class I railroads function as hosts for Amtrak and commuter  railroads. Revenue service demonstration (RSD): an advanced form of field  testing in which the railroad operates PTC-equipped trains in regular  service under specific conditions. Interoperability testing: host and tenant railroads that operate on the  same track must work together to test interoperability to ensure each  railroad can operate seamlessly across property boundaries. 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, FRA officials provide technical  assistance to railroads, address questions, and review railroad-submitted  documentation. Most recently, we found in March 2018 that  FRA had not systematically communicated information or used a risk- based approach to help railroads prepare for the 2018 deadline or to  qualify for an extension. Many Railroads Remain in Early Stages of PTC Implementation and FRA Has Clarified Extension Requirements Railroads Continue to Install and to Test PTC Systems, and Report Previously Identified Implementation Challenges

As of June 30, 2018, many railroads reported that they remain in the  equipment installation and field-testing stages, which are early stages of  PTC implementation. Based on our  analysis of the 40 railroads’ reported status as of June 30, 2018, about  half of the railroads have completed equipment installation, and many  others are nearing completion of this stage. As  noted earlier, unless a commuter or Class II/III railroad receives  approval for using substitute criteria, the railroad must initiate RSD, a  final stage of PTC testing, on at least one territory by December 31,  2018, to qualify for an extension. 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 railroads eligible to use substitute criteria, initiating field  testing was one approach that could potentially qualify as substitute  criteria, rather than initiating RSD. Railroads and FRA Are Working toward Extensions, Leaving Substantial Work to Be Completed Beyond 2018

		Most Railroads Anticipate Needing an Extension, and Many Plan to Start RSD Testing Beyond 2018

More than three-quarters of railroads (32 of 40) reported to us that they  plan to apply for an extension. 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. For example,  representatives from one commuter railroad said they hope to reach RSD  before the December 31, 2018, deadline, but that it would be difficult to  meet the extension requirements, apply for, and receive an extension  given the volume of paperwork FRA will be receiving at the end of the  year. Additionally, for some railroads further along in PTC implementation,  particularly Class I freight railroads, interoperability is a key remaining  hurdle for full implementation by the end of 2018, and railroads expect  this challenge to persist in the future. 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. To help manage the forthcoming influx of documentation, FRA officials  have offered to review draft documentation, such as substitute criteria  requests and test requests, and have advised railroads to take FRA’s  review times into account prior to submitting required documentation. Although FRA has taken steps to provide key extension information to  railroads and help ensure railroads’ compliance with PTC deadlines,  uncertainty remains, particularly in regard to FRA’s enforcement strategy  if railroads are noncompliant with the statute, 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 railroad industry are poised for full PTC implementation by  December 31, 2020.
Why GAO Did This Study

Forty railroads including Amtrak, commuter, and freight 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. PTC must be interoperable, meaning trains can operate seamlessly on the same PTC-equipped track, including “tenants” that operate on track owned by another “host” railroad. 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 railroads' PTC implementation progress. This statement discusses (1) railroads' implementation progress and FRA's steps to assist them and (2) how 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, many railroads remained in the early stages of positive train control (PTC) implementation—including equipment installation and early field testing. About half of the 40 railroads implementing PTC reported that they are still installing equipment, though many are nearing completion. However, with the exception of the largest freight railroads—known as Class I—and Amtrak, most railroads reported less progress in later implementation stages, especially revenue service demonstration (RSD), an advanced form of field testing that is required to fully implement PTC. Of the 28 commuter railroads required to implement PTC, 19 reported initiating field testing, but only 8 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 6 statutory criteria. For the sixth criterion, commuter and smaller freight 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 for railroads eligible to use substitute criteria, initiating field testing instead of RSD was one approach that could potentially receive FRA's approval. FRA's actions are consistent with GAO's March 2018 recommendation that the agency communicate to the railroads the requirements and process for an extension.
Most railroads anticipate needing an extension, leaving substantial work for both railroads and FRA to complete before the end of 2020. Thirty-two of 40 railroads reported to GAO that they, or the railroad which owns the track on which they operate, will apply for an extension. Sixteen commuter and smaller freight railroads reported planning to apply for an extension using substitute criteria, and of these, 12 intend to apply for substitute criteria based on early testing such as field testing. Though substitute criteria are authorized in law, this approach defers time-intensive RSD testing into 2019 and beyond. In addition, railroads expressed concerns with the time and effort involved with interoperability testing—a key remaining hurdle for railroads such as Class I railroads that are further along with implementation. Further, 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 has taken recent steps to help manage the forthcoming influx of documentation, such as reallocating resources. Nonetheless, given that as of early September 2018, only 1 railroad—a Class I 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. In addition, challenges related to PTC implementation and FRA's resources raise questions as to the extent FRA and the railroad industry are poised for full PTC implementation by December 31, 2020.

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, and GAO will continue to monitor FRA's progress.