September 14, 2018

As the December 31 deadline to fully implement positive train control (PTC) or else qualify for an alternative schedule approaches, railroads and regulators are already turning towards challenges that will remain after 2018.

These outstanding issues, particularly the interoperability of different railroads’ PTC systems, were a central focus of a House Subcommittee on Railroads, Pipelines, and Hazardous Materials hearing this week.

According to Susan A. Fleming, Director of the Physical Infrastructure Team at the Government Accountability Office (GAO), 32 of the 40 railroads with PTC requirements report that they, or the owner of the infrastructure they run on, will request an alternative schedule (AS). An AS will grant those railroads an extension until as late as Dec. 31, 2020 to come into full compliance.

Moreover, half of those railroads will apply to use “substitute criteria” to request an AS. Under the Surface Transportation Extension Act of 2015, railroads can apply for up to 24 months of additional time if they meet certain implementation milestones, including having installed all of their hardware, acquired all necessary spectrum, and entered revenue service demonstration (RSD). The substitute criteria allows railroads that have initiated field testing of their PTC systems to successfully apply for an AS without having entered RSD.

This means there will “still be substantial work after 2018, particularly regarding revenue service demonstration,” according to Director Fleming. She said that for railroads already in RSD, it took them two years on average to move from field testing to revenue service—meaning all of the railroads applying for an AS may need the full two-year extension or more before their PTC systems are fully implemented.

Interoperability is the biggest challenge

There was consensus among the witnesses—which included representatives from federal agencies, Class I railroads, Amtrak, and commuter railroads—that the biggest challenge post-2018 would be ensuring 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 enables trains using one PTC system to communicate with trains and infrastructure using a different PTC system, and to move seamlessly across tracks owned by different railroads.

For example, while Amtrak owns some of its own track (the Northeast Corridor being a prominent example), 72 percent of its train miles are on other hosts’ infrastructure. Scott Naparstek, Executive Vice President and Chief Operating Officer of Amtrak, testified that Amtrak is currently interoperable with five hosts and anticipates “several more” before the Dec. 31 deadline.

On the other hand, Amtrak plays host to a dozen other railroads, both commuter and freight, that use its infrastructure along the Northeast Corridor. Naparstek spelled out in his written testimony that 10 of these tenants are using Amtrak’s ACSES PTC system, while two (MARC and Norfolk Southern) are using freight’s I-ETMS system. Those different server systems need to be linked, and testing needs to happen to make sure they communicate without problems.

Naparestek said Amtrak will apply for an AS “given the difficulty of completing testing with so many freight and commuter partners.”

The interoperability component is also the main reason Class I railroads, most of which are otherwise done implementing PTC, are requesting extensions. Edward Hamberger, President and Chief Executive Officer of the Association of American Railroads, told the subcommittee that interoperability is “the biggest remaining challenge of PTC implementation.”

The sticking point here is that railroads lagging behind in PTC implementation are now preventing other railroads that have already done their work from being declared fully implemented. In other words, because many of the tenants running trains on Class I-owned infrastructure are filing for an AS, Class I railroads cannot prove their systems are fully operational including interoperability. The same is true for Amtrak: Mr. Naparestek said that while MARC and Norfolk Southern will be “I-ETMS ready,” it is not clear yet if everything for PTC operation will be in place by the deadline. And New Jersey Transit, which is also a tenant of Amtrak, “has significant work facing it before it will be PTC operational.”

It is not just the hosts being held up by other railroads. Stacey Mortensen, Executive Director of Altamont Corridor Express (ACE), said that one of the issues that will prevent ACE from meeting the deadline is that Caltrain, which hosts ACE trains for four miles in the San Jose area, will file for an AS. “We cannot complete work on that stretch without their cooperation,” she said.

(ACE’s sources of delay are numerous: in addition to the impending interoperability issue, Ms. Mortensen said that ACE’s status as one of the smallest railroads with PTC requirements put it at the end of the line to receive hardware and a site workforce from an extremely small pool of vendors. She also brought up the recall of radio antennas that were failing for other railroads, though they have not yet failed for ACE.)

This frustration—that some laggard railroads are putting others at risk of missing the deadline—came to a head towards the tail end of the two-hour hearing. But the frustration was directed not at those railroads, but at the Federail Railroad Administration (FRA). Mr. Hamberger told the subcommittee that several Class I railroads and Amtrak are ready to be declared fully implemented, but FRA denied their requests because they each have tenant railroads that are not fully implemented.

“FRA stipulates that nobody is fully implemented until everybody is fully implemented,” he said.

Asked by Rep. Randy Weber (R-TX) if host railroads “are to be held liable for their tenants,” FRA Administrator Ronald Batory responded that indeed “we said you can’t [be declared fully implemented] because you have tenants out there that aren’t going to be PTC equipped [by Dec. 31, 2018].”

“Get your tenants to file for an alternative schedule, then we can recognize you as being fully implemented,” Batory said he told those host railroads.

That was not a satisfying response to the host railroads. First, there is an issue of jurisdiction: one railroad cannot force another to apply for an AS. Second, “you can’t test interoperability with a tenant that isn’t ready to test with,” said Mr. Naparstek of Amtrak. “I can’t prove Amtrak’s system’s 100 percent interoperability… therefore, I need to work with my tenants.”

Watch the full hearing and read the witnesses’ written testimony here.