AMTRAK CASCADES AND COAST 

STARLIGHT ROUTES: IMPLEMENTATION OF 

NEW METRICS AND STANDARDS IS KEY TO 

IMPROVING ON-TIME PERFORMANCE

Federal Railroad Administration

Report Number: CR-2010-117

Date Issued: September 23, 2010 
U.S. Department of

Memorandum

Transportation

Office of the Secretary

of Transportation

Office of Inspector General

Subject: ACTION: Report on the Causes of Delays for the 

Coast Starlight and Amtrak Cascades Routes

Federal Railroad Administration

Report Number: CR-2010-117

Date: September 23, 2010

From: Mitchell Behm

Assistant Inspector General for Rail, Maritime, & 

Economic Analysis

Reply to 

Attn. of: JA-50

To: Federal Railroad Administrator

Over the past 2 years, Congress has enacted legislation and committed billions of 

dollars to upgrade and expand the nation’s intercity passenger rail service. Early 

this year, the U.S. Department of Transportation awarded $8 billion in stimulus 

funds from the American Recovery and Reinvestment Act of 2009 (ARRA)1

In 2008, we reported that poor OTP on Amtrak's intercity passenger routes 

impacted its bottom line.

to 31

states to develop high-speed and intercity passenger train service. For this 

initiative to be successful, passenger trains need to reach their destinations on 

time. Poor on-time performance (OTP) discourages ridership, thereby resulting in

lower revenues and higher operating costs. 

2

 Subsequent to our findings, Congress passed the 

Passenger Rail Investment and Improvement Act of 2008 (PRIIA)3

, which 

requires us to report on service delays and needed improvements on Amtrak's 

Pacific Coast train routes—Coast Starlight and Amtrak Cascades.

4 Accordingly, 

this report (1) describes the routes’ OTP between 2004 and 20095

 1 Public Law 111-5

, (2) identifies

the factors underlying the routes' OTP, and (3) evaluates the impact of Federal 

Railroad Administration's (FRA) new metrics and standards on OTP.

2 OIG Report Number CR-2008-047 “The Effects of Amtrak’s Poor On-Time Performance,” March 28, 2008. OIG 

reports can be found on our website: www.oig.dot.gov. 3 Public Law 110-432 4 Section 225 of Division B of PRIIA. 5 All references to years are in fiscal years unless otherwise noted.
2

To conduct our work, we interviewed FRA, Surface Transportation Board (STB), 

and Amtrak officials and reviewed relevant laws, policies, and Amtrak 

documentation. We also traveled on the Coast Starlight and Amtrak Cascades 

routes and met with state, commuter train, and freight officials in Portland, OR, 

Washington, DC, and Seattle, WA. To determine the causes of delays, we 

analyzed Amtrak delay data and spoke with conductors, host railroad and state 

officials to obtain their views about the causes of delays along the routes. We 

conducted this performance audit from October 2008 through July 2010 in 

accordance with generally accepted government auditing standards. See details on 

our scope and methodology in Exhibit A.

RESULTS IN BRIEF 

While the Coast Starlight and Amtrak Cascades lines experienced significant 

delays from 2004 through 2009, total minutes of delay on both lines dropped after

2006. At their peak in 2006, the Coast Starlight and Amtrak Cascades experienced 

more than 67 and 38 hours of delays, respectively, per 10,000 train miles. 

However, by 2009, delays on both routes had fallen significantly. With these 

drops in delay time came improvements in OTP for both lines. After hitting a low 

of 4 percent in 2006, Coast Starlight's OTP improved to 82 percent by 2009. 

Amtrak Cascades' OTP also hit its low, below 50 percent, in 2006, but by 2009, it 

had risen to 71 percent. This level, however, was below Amtrak's established OTP 

goals for corridor trains at that time.

Most delays on the Coast Starlight and Amtrak Cascades routes were attributable

to the routes' host railroads, BNSF Railway and Union Pacific Railroad, with 

significant portions of total minutes of delay attributed to freight train interference 

(FTI) and slow orders.

6

 6 FTI can result from a number of circumstances, such as when passenger trains meet or overtake freight trains, 

resulting in the passenger train having to slow down or stop. Slow orders are reductions in train speeds imposed for 

safety reasons if the quality of a section of track is not sufficient to meet its maximum allowable speed for daily 

operations. In addition, slow orders can decrease the maximum allowable speed on segments involving or near 

maintenance areas or capital projects.

Other delays were attributable to Amtrak for problems 

such as train equipment failures and late connections as well as to third parties for 

events such as trespassing or poor weather conditions. Several factors contributed 

to the decrease in delays—and ultimately the lines’ improved OTP. First, the host 

railroads and Amtrak improved operations by enhancing training for host railroad

dispatchers and reducing the numbers of slow orders. Capital improvements and 

investments by the States of Washington and Oregon, among others also 

contributed to better OTP. Finally, reduced freight traffic caused by the depressed 

economy contributed to the routes' improved performance since fewer freight 

trains on the tracks reduced FTI.
3

FRA has taken action to develop new OTP metrics and standards, as required by 

PRIIA. However, delays in issuing these new performance measures have stalled 

other actions that could further improve OTP over the long term. For example, 

STB officials told us they planned to wait until the final metrics and standards 

were issued to begin investigating poor OTP. Effective implementation of the 

new metrics and standards will depend on the quality of Amtrak delay data, which 

is used to support them. Some state and host railroad officials questioned the 

quality of Amtrak delay data, even though only a small percentage of delay entries 

are ultimately challenged by host railroads. Ensuring quality data on delays is 

important given its uses by the various stakeholders involved in intercity 

passenger rail. FRA along with the states needs to ensure that the benefits of 

recent Federal intercity passenger rail legislation are fully realized and 

improvements in OTP for the Coast Starlight and Amtrak Cascades are 

sustainable. 

We are making recommendations to the FRA administrator regarding adequate 

oversight for both the implementation of new metrics and standards and the 

actions needed to address concerns over the limitations of conductor delay reports.
4

BACKGROUND 

Together, the Coast Starlight and Amtrak Cascades

passenger rail corridors run more than 1,800 miles 

between Vancouver, British Columbia and Los 

Angeles, CA. Amtrak Cascades operates two daily 

roundtrip services between Vancouver and Seattle, and 

four daily roundtrip services between Seattle and 

Portland, and two daily roundtrip services between 

Portland and Eugene, which take approximately 

4, 3.5, and 2.5 hours, respectively. These short-distance 

corridor services are funded by Amtrak and 

Washington's and Oregon's departments of 

transportation. The Coast Starlight makes one daily 

round-trip between Los Angeles and Seattle. Each oneway journey is scheduled to take 34.5 hours. The Coast 

Starlight is one of Amtrak's 15 long-distance intercity 

passenger trains and is funded entirely by Amtrak.

Like most Amtrak passenger trains, Coast Starlight and 

Amtrak Cascades trains operate on tracks owned by 

private freight railroad companies. Dispatchers from 

the host railroads direct the movement of all freight and 

passenger trains. For routes to operate, Amtrak, the 

host railroads, and state departments of transportation 

enter into various agreements that specify their 

obligations to one another.

• Amtrak enters into operating agreements with host 

railroads to use their rights-of-way.7

incentive payments and penalties to the host railroad depending on the host's 

performance, and (3) the host railroad’s obligation to maintain its tracks at a 

certain level of utility. Amtrak has operating agreements with Union Pacific 

The agreements 

typically specify (1) Amtrak's per-train mile 

incremental maintenance costs to cover track wear 

and tear due to passenger trains, (2) Amtrak's 

 7 When it was created by the Rail Passenger Service Act of 1970, Amtrak was granted priority access to all tracks 

owned by private freight railroad companies. These include seven U.S. Class 1 railroad companies: BNSF Railway, 

Norfolk Southern Railway, CSX Transportation, Union Pacific Railroad, Kansas City Southern Railway, Grand 

Trunk Corporation, and Soo Line. The main exception is Amtrak's Northeast Corridor (NEC) train service, which 

operates between Washington, DC, and Boston, MA, where Amtrak passenger trains run on tracks, except for short 

stretches, that are owned by Amtrak.
5

and BNSF for Coast Starlight,8

• Amtrak maintains operating agreements with state departments of 

transportation to operate trains on state-subsidized corridor routes. These

agreements typically specify the number of trips, schedules and OTP goals,

and the types of services Amtrak will provide, such as ticketing and reservation 

systems. The agreements also stipulate the amount of compensation the state 

will pay Amtrak for these services and other actions the state will take to make 

the service feasible, such as providing passenger station facilities. For the 

Amtrak Cascades routes, Amtrak has agreements with Oregon and 

Washington.

and with Union Pacific and BNSF for Amtrak 

Cascades.

• States and host railroads enter into various agreements for capital improvement 

projects, such as increasing rail capacity and upgrading track and signals. 

These agreements have not historically included all specified service outcome

elements—number of trips, trip times, and reliability.

In March and September 2008, we reported on Amtrak’s poor non-NEC OTP. In 

the March report, we estimated that Amtrak could have reduced its 2006 operating 

losses by $136.6 million by bringing overall OTP up to 85 percent from 30 percent 

for long distance and 67 percent for corridor routes.

9

 In the September report,10

we identified several root causes of delays that contributed to poor OTP for 

Amtrak trains, including host railroad's dispatching and track maintenance

practices, and insufficient rail capacity11

Several PRIIA objectives aim to improve the service and reliability of intercity 

passenger rail. First, PRIIA requires FRA and Amtrak to establish new OTP and 

delay measures and urges Amtrak and the host railroads to incorporate these new 

measures into their operating agreements to the extent practicable. Second, PRIIA 

gives the STB authority to initiate an investigation—on its own or in response to a 

complaint from Amtrak, a host railroad, or other train operator—if an intercity 

passenger train service fails to achieve minimum performance measures for two 

consecutive quarters. STB can award damages if it determines that the cause of 

to handle the growing needs of intercity 

passenger, freight, and commuter trains. We made recommendations, including

that FRA seek legislative changes that would provide Amtrak with a platform to 

address its concerns regarding host railroad practices that affect OTP.

 8 For a short distance, the Coast Starlight runs on tracks owned by the Southern California Regional Rail Authority. 9 OIG Report Number CR-2008-047. 10 OIG Report Number CR-2008-076, "Root Causes of Amtrak Train Delays," September 8, 2008. OIG reports are 

available on our website: www.oig.dot.gov. 11 Available rail capacity is impacted by a number of factors including train control and dispatching systems, the 

number of main line tracks and crossings, the number and length of sidings, the presence of longer freight trains, and 

the differences in speeds of passenger and freight trains.
6

poor performance was the host railroad's failure to provide preference to Amtrak 

over freight trains. Finally, PRIIA requires Amtrak to evaluate the financial and 

operating performance of each of its 15 long-distance routes, many of which have 

turned in poor OTP records in recent years. It also requires Amtrak to develop 

performance improvement plans for these long-distance routes and tasks FRA with 

overseeing the development and implementation of those plans. 

WHILE DELAYS CONTINUE, ON-TIME PERFORMANCE HAS 

IMPROVED

While the Coast Starlight and Amtrak Cascades routes experienced significant 

delays from 2004 through 2009, the total minutes of delay per 10,000 train miles 

have dropped since 2006, their peak year, resulting in improved OTP for both 

routes (see figure 1). Delays on both routes peaked in 2006 at a total of 4,053 and 

2,310 minutes for the year, equating to more than 67 and 38 hours of delay per 

10,000 train miles, respectively. However, by 2009, delays on both routes 

dropped to 1,776 and 1,674 minutes, respectively, for the year. 

Figure 1: Coast Starlight and Amtrak Cascades Total 

Minutes of Delay, Fiscal Years 2004 through 2009

1,000

1,500

2,000

2,500

3,000

3,500

4,000

4,500

2004 2005 2006 2007 2008 2009

Coast Starlight Cascades

Minutes of Delay

(per 10,000 train miles)

Source: OIG analysis of Amtrak data

With decreases in minutes of delay, annual OTP for Coast Starlight and Amtrak 

Cascades improved (see figure 2). Coast Starlight's annual OTP dipped to a low of 

4 percent in 2006—the lowest on record that year in the Amtrak system—but by 

2009 had risen to 82 percent, surpassing previously established Amtrak goals for 
7

long-distance trains. During the same 6-year period, Amtrak Cascades showed a 

small drop and then a steady, moderate overall improvement in annual OTP. The 

route's OTP fell to below 50 percent in 2006, but began to rise the following year, 

reaching its highest level, 71 percent, in 2009. This level, however, remains below 

Amtrak's previously established OTP goals for corridor trains.

Figure 2: Coast Starlight and Amtrak Cascades OTP, 

Fiscal Years 2004 through 2009

0%

15%

30%

45%

60%

75%

90%

2004 2005 2006 2007 2008 2009

Coast Starlight Cascades

Endpoint OTP (%)

Source: OIG analysis of Amtrak data

The monthly OTP for both Coast Starlight and Amtrak Cascades varied by season. 

During winter months, severe weather conditions such as snow, freezing 

temperatures, heavy rains, and mudslides delay trains in the Pacific Northwest. 

During summer months, trains may be delayed because of heightened track 

maintenance and construction work. Host railroad officials pointed out that OTP 

could improve if Amtrak instituted flexible scheduling or developed seasonal 

schedules to accommodate slow orders, track work, and other operational 

conditions. Although Amtrak reviews its public schedules biannually, it generally 

issues travel advisories and makes temporary schedule adjustments for anticipated 

delays due to host railroad track work, rather than issue revised schedules for an 

entire season.

FREIGHT TRAIN INTERFERENCE AND SLOW ORDERS CAUSED 

MOST DELAYS, BUT RECENT ACTIONS HAVE IMPROVED OTP

Most delays on the Coast Starlight and Amtrak Cascades routes were attributable

to the lines’ host railroads, with significant portions of total minutes of delay
8

assigned to FTI and slow orders. However, delays have decreased— ultimately 

improving the routes’ OTP—due to several factors, including improved 

operations, capital investments, and reduced freight traffic.

Most Delays Are Attributable to Host Railroads' FTI and Slow Orders

Delays on the Coast Starlight and Amtrak Cascades routes were primarily 

attributable to the host railroads. Between 2004 and 2008, host-responsible delays 

averaged roughly 80 percent of all delays before declining to their lowest levels of

67 and 70 percent, respectively in 2009 (see figure 3).

Figure 3: Percent of Host Responsible Minutes of Delay, 

Fiscal Years 2004 through 2009

80%

78%

81% 82%

77%

67%

79% 78%

80%

77% 76% 70%

50%

55%

60%

65%

70%

75%

80%

85%

90%

2004 2005 2006 2007 2008 2009

Coast Starlight Cascades

Host Responsible Delays

Source: OIG analysis of Amtrak data

A large portion of the host-responsible minutes of delay from 2004 through 2009 

were attributable to FTI and slow orders. Between 2004 and 2007, delays due to 

FTI fluctuated between 20 and 40 percent of total minutes of delay. However, by 

2009, these delays had dropped to below 15 percent. While delays caused by slow 

orders dropped to approximately 20 percent of total minutes of delay in 2009—

after peaking in 2006 and 2007 at over 30 percent for the Coast Starlight—they 

became the leading cause of delays for both routes (see figures 4 and 5).
9

Figure 4: Percent of Host Responsible Minutes of Delay by 

Category, Coast Starlight

0%

5%

10%

15%

20%

25%

30%

35%

2004 2005 2006 2007 2008 2009

FTI Slow Orders PTI Signal Delays Routing Delays Other

Minutes of Delay (%)

Source: OIG analysis of Amtrak data

Figure 5: Percent of Host Responsible Minutes of Delay by

Category, Amtrak Cascades

0%

5%

10%

15%

20%

25%

30%

35%

40%

45%

2004 2005 2006 2007 2008 2009

FTI Slow Orders PTI Signal Delays Routing Delays Other

Minutes of Delay (%)

Source: OIG analysis of Amtrak data
10

The remaining minutes of delay were attributable to Amtrak for problems such as 

train equipment failures, passenger-related issues, and late connections, or were 

categorized as third party due to issues such as trespasser incidents, customs and 

immigration concerns, unused recovery time, and weather. (See Exhibit E for the 

percentages of delays in each category for the Coast Starlight and Amtrak 

Cascades routes.)

Operational Changes, Capital Investments, and Reduced Freight 

Traffic Have Contributed to Improved OTP

Over the past several years, the host railroads and Amtrak have improved their

operations by enhancing training for host railroad dispatchers and reducing the 

number of slow orders to improve OTP. Capital investments and maintenance 

work by states, commuter lines, and host railroads have also led to improved OTP 

on the Coast Starlight and Amtrak Cascades routes. Finally, the lagging economy 

has contributed to the improved OTP of Amtrak's passenger trains. With fewer 

freight cars moving on the rails, delays due to FTI, one of the major causes of poor 

OTP on both routes, have declined. 

Operational Changes by the Host Railroads and Amtrak Have Led to

Improved OTP

Improved dispatching practices have led to fewer FTI delays on the Coast Starlight 

and Amtrak Cascades routes. To improve passenger train dispatching, Union 

Pacific hired a new manager of dispatching operations and enhanced its dispatcher 

training program. New dispatchers are required to complete a 6-month training 

program that includes both class work and simulations of dispatch situations.

12

A reduction in the number of slow orders issued by Union Pacific also contributed 

to Coast Starlight's improved OTP. Amtrak officials told us that Union Pacific

had been issuing a large number of slow orders for track defects and maintenance 

work on tracks used by the Coast Starlight and Amtrak Cascades. From calendar 

year 2004 to 2006, the number of minutes of delay attributed to these slow orders

rose from 100 minutes to more than 170 minutes per trip, according to data 

 

BNSF officials also informed us that they provide dispatchers with extensive 

training, which includes classroom and on-the-job training, followed by 

workshops and skills training. Officials at both railroads said they provide newer 

dispatchers with on-the-job coaching and counseling by senior staff, supervision, 

and performance evaluations.

 12 Host railroad officials from both Union Pacific and BNSF Railway stated that recent retirements have required the 

companies to hire large numbers of new dispatchers.
11

provided by Union Pacific and Amtrak.13

Capital Investments and Maintenance Work by States, Commuter

Lines, and Host Railroads Increased Line Capacities and Reduced 

Delays

Arbitration between Amtrak and Union 

Pacific led to Union Pacific’s agreement in February 2009 to comply with most of 

the contractual limits on slow orders. During arbitration, Union Pacific began 

undertaking major track and tie improvement work along the Coast Starlight route, 

resulting in a significant reduction in slow orders. By late calendar year 2009, the 

number of minutes of delay attributable to slow orders on the Coast Starlight route 

had dropped to about 40 minutes per trip.

Substantial capital investments have increased capacity and train round trips, and 

improved OTP, on both the Coast Starlight and Amtrak Cascades routes. 

However, given the long-term nature of capital improvement programs, many 

capital projects are ongoing. Between 2004 and 2009, the State of Washington 

invested nearly $61 million in capital projects along both the Coast Starlight and 

Amtrak Cascades routes. Washington made investments intended to mitigate the 

impact of additional passenger trains, increase line capacity, reduce delays, and 

improve OTP. For example, between 2005 and 2007, the state spent almost $4 

million on the construction of a new set of crossovers to allow faster passenger 

trains, including those on the Amtrak Cascades route, to move around slower 

freight trains. As outlined in the project description, the benefits include improved 

safety by allowing trains to safely pass one another at greater speeds and improved 

on-time performance with faster, more frequent service.

During the same period, the State of Oregon invested almost $38 million in capital 

projects to improve infrastructure along the tracks used by the Coast Starlight and 

Amtrak Cascades routes. State officials informed us that these investments have 

focused on the construction of additional tracks, and track and signal 

improvements. These track and signal improvements lessened the impact of 

adding a second Amtrak Cascades roundtrip and increased line capacity, train 

speeds, and rail network fluidity for both passenger and freight trains, all of which 

ultimately improved OTP on both routes.

Sound Transit commuter rail also invested over $500 million during this time 

period between Seattle, Everett, and Tacoma, Washington—in BNSF's line which

it shares with both Coast Starlight and Amtrak Cascades. The investments

addressed capacity constraints by upgrading or expanding signaling systems and

by adding tracks and crossovers, which allow trains to move from one track to 

another. These investments, while made to improve Sound Transit services, have

 13 According to Amtrak officials, these delays exceeded the allowable number of minutes of delay due to slow orders

contained in Amtrak's operating agreement with Union Pacific.
12

positively impacted the OTP of the two Amtrak routes. BNSF and Union Pacific

also undertook capital and maintenance projects that have improved the quality of 

service along the Coast Starlight and Amtrak Cascades routes. For example, Union 

Pacific completed significant tie replacements, cleaned or replaced ballast, and 

added a new siding to maintain existing tracks and expand capacity.14

All of the actions that Amtrak, host railroads, and states have taken to improve 

performance along the Coast Starlight and Amtrak Cascades routes are consistent 

with Amtrak's operational performance improvement plans.

BNSF, 

solely or in conjunction with Sound Transit or the State of Washington, installed 

segments of double track and added sidings and crossovers to allow Amtrak trains 

to pass freight trains more easily. According to freight officials, these 

improvements have led to higher quality tracks and additional capacity, making it 

easier for Amtrak trains to remain on schedule. Most recently, the Federal 

government has increased its role in intercity passenger rail by making capital 

funds available to the states, from which the Coast Starlight and Amtrak Cascades 

routes will benefit (see Exhibit C for additional information on recent Federal 

grant programs for rail). 

15 Amtrak's operational 

performance improvement plan process addresses OTP and delay problems 

through three stages: (1) operational improvements, such as dispatching practices 

and signaling systems; (2) maintenance issues, such as repairs and upgrades to 

host railroad track and other infrastructure or to Amtrak trains and equipment; and 

(3) capital improvements to increase rail capacity. Amtrak officials said that, in

these plans, capital improvements are undertaken only if operational and 

maintenance improvements do not fully address the existing OTP and delay issues. 

They noted that capital spending is always a last resort and that many delay 

problems for both Amtrak and the host railroads can be solved through operational 

and maintenance actions. Although such a plan has not been implemented for 

either the Coast Starlight or the Amtrak Cascades routes, the process is similar to 

the actions that Amtrak, host railroads, the states of Washington and Oregon, and 

Sound Transit have taken to improve passenger service on the 2 routes.

 14 Ties are the portion of the track structure placed under the rails to hold them steady in place and distribute the weight 

of the rails and rolling stock. A siding is a track located next to a main rail line that allows a train to move out of the 

way of an oncoming train. Sidings are also used to store trains or to add or remove cars from a train. Ballast is a 

selected material placed in a track to hold its position, distribute weight, dissipate force, and provide drainage. 15 Previously, Amtrak called these performance improvement plans, but renamed them operational performance 

improvement plans to distinguish them from the PRIIA-mandated performance improvement plans for all longdistance passenger routes. The PRIIA-mandated plans are to consider service quality, financial issues, as well as 

OTP. Amtrak’s operational improvement plans focus on OTP and delay issues.
13

Lower Freight Traffic Increased Capacity on Both Routes

The recent decline in freight traffic on the Pacific Coast, caused by the lagging 

economy, contributed to the improved performance of these routes. According to 

STB data,16

Figure 6: Trends in Freight Traffic (by Calendar Year)

the amount of freight traffic in California, in terms of the number of 

freight carloads, began to fall in calendar year 2007 and continued to drop in 2008 

(see figure 6). During this 2-year period, freight traffic in the state declined by 

about 10 percent from a peak of nearly 7.6 million carloads in 2006. Data are not 

yet available for 2009. The decline started earlier in Oregon and Washington. The 

amount of freight traffic began to drop in calendar year 2006, a year earlier than in 

California, and continued to fall through 2008. During this 3-year period, freight 

traffic in Oregon and Washington declined by 15 and 13 percent, respectively, 

from their peaks in 2005.

0

1,000,000

2,000,000

3,000,000

4,000,000

5,000,000

6,000,000

7,000,000

8,000,000

2003 2004 2005 2006 2007 2008

California Oregon Washington

Number of Carloads

Source: OIG analysis of STB data

FRA officials informed us that while the lagging economy has led to reduced 

freight traffic, freeing up capacity on rail lines and improving passenger train 

OTP, there is not a one-to-one relationship between higher OTP and lower freight 

traffic. For example, between 2007 and 2009, the Coast Starlight's OTP rose by 

60 percent and the Amtrak Cascades' OTP increased by some 20 percent, while 

freight traffic declined by only 10 to 15 percent in the three Pacific Coast states. 

 16 These data come from the STB’s Carload Waybill Sample database, which contains a sample of waybills filed by 

most large U.S. railroad companies. Waybills are documents that contain the details of the shipment, route, and 

charges. This review used the total number of loaded rail cars that originated in, terminated in, or passed through 

California, Oregon, or Washington.
14

Officials agreed that other factors may be affecting OTP, such as more stringent 

Federal guidance (e.g., FRA's proposed metrics and standards for intercity 

passenger rail), which may have prompted host railroads to focus on passenger 

train OTP. These officials acknowledged that while OTP has improved, it will 

reemerge as an issue, especially when the economy revives.

DELAYS IN ISSUING NEW METRICS AND STANDARDS HAS 

STALLED ACTIONS TO FURTHER IMPROVE OTP

FRA and Amtrak have taken action to develop new OTP metrics and standards, as 

required by PRIIA. However, the final metrics and standards have only recently

been issued, delaying several PRIIA requirements and related actions that could 

improve OTP. Furthermore, the measures' effectiveness could be compromised by 

the limitations of the data used to support them. Some state and host railroad 

officials questioned the reliability of Amtrak delay data. Ensuring quality data on 

delays is not only critical to effectively implementing new performance measures 

but it is also important given its numerous uses by Amtrak, FRA, the states, and 

host railroads.

Implementation of New Metrics and Standards Affecting OTP Has

Been Delayed

As required by PRIIA, FRA and Amtrak jointly developed metrics and minimum 

standards for measuring the OTP of intercity passenger train operations 

(see table 1). FRA also set minimum standards for the number of host-responsible 

and Amtrak-responsible minutes of delay.17

Table 1: OTP Metrics and Standards for Non-Northeast Corridor Routes

Metric Purpose Minimum standard

Endpoint OTP Records the percentage of trains that arrive at their 

final destinations on time.a At least 80 percent 

Effective speed Helps prevent long-term "schedule creep" by 

dividing a train's mileage by scheduled time plus 

average lateness at final destination.

All-stations OTP Identifies the percentage of trains that arrive at each 

station along a route on time.b

At least 80 percent c

a Based on the former Interstate Commerce Commission's tolerances, which consider trains 10 to 30 

minutes past scheduled arrival to be on time, depending on the length of the trip. A Coast Starlight train, 

for example, can arrive 30 minutes late at its final destination and still be considered on time. b Based on 49 U.S.C. Section 24101(c)(4), a train is considered to be on time at each station along a route 

if it arrives within 15 minutes of its scheduled arrival time. c Effective 2012.

 17 Amtrak-responsible delays are set at no more than 325 minutes per 10,000 Train Miles. Host-responsible delays are 

set at no more than 900 minutes per 10,000 Train Miles. 
15

While FRA issued its proposed metrics and standards for public comment in 

March 2009, the final metrics and standards were not issued until May 2010. As a 

result, several PRIIA requirements and related actions have been stalled.

First, the development of new performance improvement plans between Amtrak 

and host railroads was slowed because, according to Amtrak officials, the host 

railroads want to ensure that the plans' goals are aligned with the final metrics and 

standards. Second, progress in incorporating the new, more rigorous measures into 

Amtrak-host railroad operating agreements as they expired or were renegotiated 

stalled. According to FRA staff, the new metrics and standards will provide more 

stringent and transparent performance measures than those used to calculate 

performance incentives in the current agreements, which provide greater 

tolerances. For example, in calculating OTP, FRA's endpoint OTP metric allows a 

basic tolerance of 10 minutes for a short trip, which means a train can be up to 10 

minutes late and still be considered on time. For the same trip, a host railroad's 

tolerance used to calculate a performance incentive may be significantly more. 

One state official suggested that more binding and realistic agreements between 

Amtrak and host railroads would be more effective.

Finally, delays in issuing the new metrics and standards have also had an impact 

on STB investigations into OTP. According to STB officials, they planned to wait

until the final metrics and standards were issued to begin investigating poor OTP 

or other service quality deficiencies of intercity passenger train services to 

determine the extent to which delays could reasonably be addressed by the host 

railroad, Amtrak, or other operators. STB will have the authority to review the 

accuracy of passenger train performance data, which it can obtain from all parties, 

and the extent to which scheduling and congestion contribute to delays. In some 

cases, investigations may result in awards to Amtrak if STB determines that a 

service's delays or inability to achieve minimum standards are attributable to a 

host railroad’s failure to provide preference to Amtrak trains over freight trains. 

State officials said that the threat of STB action may have led to recent 

improvements in Amtrak’s OTP. One state official said STB's new role has made 

host railroad's pay attention to passenger train OTP. 

State and Host Railroad Officials Question the Reliability of Amtrak's 

OTP Data

The effectiveness of FRA's new metrics and standards will depend on the 

reliability of Amtrak's OTP data, most of which are derived from conductor delay 

reports. Some state and host railroad officials have expressed concerns about the 

reliability of the information—particularly attribution of the causes of delays. 

Several officials said that conductors are limited by what they see when recording 

the cause of a delay and often do not know the root cause of a delay. Officials 

also pointed out that conductors’ other responsibilities—including tasks such as 
16

counting and recording passenger tickets—may distract them from accurately 

identifying causes of delays. In addition, comment letters related to FRA's 

proposed metrics and standards related concerns about FRA's reliance on 

conductor delay data. One freight railroad trade association commented that 

conductor delay reports are of little value in assessing the true extent and cause of 

delays and that FRA should require use of supplemental data, such as freight train 

data, to determine root causes of delays. Amtrak officials told us that assigning 

root causes of delays is subjective. However, analysis of root causes can be a 

useful supplemental method for understanding why the direct cause of a delay 

occurred. They stated that in order to avoid subjectivity, Amtrak assigns delay 

codes based on the direct causes of delay to the Amtrak train.

Amtrak's process for preparing conductor delay reports is well documented. 

Conductors manually fill in standard delay report forms, which include station 

arrival and departure times and the type and minutes of each delay using 47 predefined codes. (See Exhibit D for a list of the codes.) Each conductor assigns a 

code based on his or her observations of the direct cause of the delay event,

including information from the train engineer or host railroad dispatcher. At the 

end of a trip, conductors fax their reports to an Amtrak operations center,18 where 

data entry clerks key the conductor-recorded information into Amtrak's On-Time 

Performance and Delay Reporting System. Each delay code has a direct 

responsible party, either the host railroad or Amtrak, or the third party category. 

At the same time, copies of conductor delay reports are also sent to host railroads. 

If a host railroad does not agree with an item in a report, it can raise the issue with 

Amtrak staff or directly with the train conductor or field supervisor in order to 

resolve it.19

A small percentage of delay entries are questioned by host railroads. Amtrak 

officials noted that, of the estimated 2,000 delay entries recorded each day for the 

entire network, host railroads question about 10 to 20 entries (about 1⁄2 to 1 

percent). Amtrak officials also cited an audit conducted by a host railroad that 

examined a sample of 55 train runs during a single month in 2008. Of a total 7,066 

minutes of delay reported by Amtrak conductors, the host railroad raised questions 

on about 8 percent of the total, including over-reported delays and the use of 

wrong delay codes. Of the amount questioned, only a portion were found to 

 The host railroads have up to 6 days to propose changes to delay

reports. In addition to reviewing conductor reports, Amtrak staff also follow-up 

with conductors and field supervisors as necessary. Conductors may be asked to 

clarify or correct entries in their reports. After 6 days, the delay data are "locked" 

in the OTP system and cannot be changed.

 18 Coast Starlight and Amtrak Cascades reports go to the operations center in Oakland, California. 19 Most host railroads have passenger desks manned by host railroad staff fully funded by Amtrak who review the 

conductor delay reports. Passenger desk staff also monitor the status of Amtrak trains and notify Amtrak of major 

impending issues, and advocate for Amtrak delay avoidance within the host dispatching center. 
17

require adjustment upon review. Amtrak officials noted that many of these

adjustments reallocated minutes from one host-responsible delay code to another 

(e.g., from FTI to slow orders). Officials pointed out that conductor delay data are 

the only data that are consistently collected across the Amtrak system.

The reliability of Amtrak conductor delay reports takes on greater significance 

when considering its many other uses. In addition to supporting PRIIA-required 

metrics and standards, conductor-recorded delay data are used extensively by 

Amtrak, FRA, the host railroads, and state departments of transportation for a 

variety of official purposes: 

• Amtrak uses conductor delay data for both internal and external purposes. It 

uses the information in daily reports, which show the performance of all 

Amtrak trains for the prior day, and in information "dashboards", which go to 

Amtrak’s Board of Directors and management officials. Amtrak also uses 

delay data: to calculate its monthly performance incentive payments to host 

railroads; to develop operational improvement plans that address OTP and 

delay problems; and for monthly statistical reports that are posted on its public 

and internal websites. 

• FRA uses Amtrak conductor delay data as the basis for its quarterly reports to 

Congress. These reports track the performance progress of all Amtrak 

passenger train routes, including OTP. 

• The state departments of transportation (for state-supported routes) and host 

railroads use Amtrak conductor delay data to develop periodic reports on train 

delays and to help pinpoint locations of recurring delays. Host railroads and the 

states told us that they routinely "scrub" the Amtrak data. For example, host 

railroads may replay dispatchers' tapes to learn why delays occurred, and states 

may verify Amtrak data with information collected by their own field staff. 

CONCLUSIONS

The groundwork for improved OTP for the Coast Starlight and Amtrak Cascades

routes has been laid. This is evident by the operational improvements instituted by 

Amtrak and host railroads to enhance host railroad dispatching practices and 

reduce slow orders. In addition, the substantial capital investments and 

maintenance work by the states of Washington and Oregon, host railroads, and

Sound Transit to increase capacity and improve the quality of the freight rail 

infrastructure have had a positive impact on the routes' OTP. Also, given the 

Federal government's recent investment of $590 million in stimulus from ARRA 

in Washington state, linking enforceable service outcomes to grant awards is key 

to ensuring that the public investments result in the anticipated public benefits, 
18

such as improved OTP. However, FRA's delay in finalizing new metrics and 

standards for OTP of intercity passenger trains makes it difficult to determine if

the momentum that has been achieved up to now—throughout the Amtrak

system—is sustainable, particularly when the economy improves, freight traffic 

increases, and the rails become congested again. While it remains to be seen what 

effect STB will have in its new investigative role, FRA will be challenged in

ensuring that Amtrak develop and implement effective performance improvement 

plans, negotiate OTP requirements into operating agreements, and address 

concerns about the accuracy of conductor delay data.

RECOMMENDATIONS

To ensure that the benefits of recent Federal intercity passenger rail legislation are 

fully realized and that improvements in OTP for the Coast Starlight and Amtrak 

Cascades routes are sustainable, we recommend that the Federal Railroad 

Administrator:

1. Ensure that the new metrics and standards are incorporated into Amtrak

performance improvement plans for its 15 long-distance routes and ensure 

their implementation.

2. Provide the appropriate technical assistance to Amtrak and host railroads as 

they negotiate new operating agreements that incorporate the new metrics 

and standards. 

3. Take actions to improve data quality or address concerns regarding the 

limitations of conductor-recorded delay data.

AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 

RESPONSE 

We provided a draft of our report to FRA on July 30, 2010 and received their

response on September 3, 2010, which can be found in its entirety in the appendix 

of this report. FRA fully concurs with our recommendations and agreed to inform 

us within 6 months from the issuance of our final report of any activity related to 

our recommendations by Amtrak or the host railroads. However, with regard to 

recommendation 1, while FRA agrees with the intent of the recommendation they

raised concerns about their authority to compel the inclusion of the new metrics 

and standards into performance improvement plans. Since performance 

improvement plans for the 5 worst performing long-distance routes are currently 

underway, FRA should be able to provide a target action date for this 

recommendation. 
19

Additionally, we appreciate FRA's efforts to improve intercity passenger rail 

service. The agency is working to ensure that all capital investments of Federal 

funds in these services will include enforceable contractual agreements between 

stakeholders to make and sustain operational improvements. FRA has expressed 

its understanding that these agreements should cover not only service design and 

operational issues such as scheduled trip times and service frequencies, but also

service reliability.

ACTIONS REQUIRED 

We consider FRA's planned actions and follow-up within 6 months for 

recommendations 2 and 3 reasonable and resolved, subject to follow-up provisions 

in accordance with DOT Order 8000.1C. We request that within 30 days of this 

report FRA provide in writing a target completion date for recommendation 1. We 

appreciate the courtesies and cooperation of FRA representatives during this audit. 

If you have any questions concerning this report, please call me at (202) 366-9970

or Toayoa Aldridge, the Program Director, at (202) 366-2081.

cc: Audit Liaison, OST, M-1

 Audit Liaison, FRA, RAD-43
20

Exhibit A. Scope and Methodology

EXHIBIT A. SCOPE AND METHODOLOGY 

This audit examined the causes of delays and the on-time performance (OTP) for 

two Amtrak passenger train routes, the Coast Starlight and the Amtrak Cascades, 

during a 6-year period (fiscal years 2004 through 2009). The audit was prepared in 

response to a mandate in Public Law 110-432, §225, the Passenger Rail 

Investment and Improvement Act (PRIIA) of 2008. 

To determine the causes of delays along the Coast Starlight and Amtrak Cascades 

routes, we obtained and analyzed Amtrak's minutes of delay data from Amtrak's 

On-Time Performance and Delay Reporting System (OTP System) for the 6-year 

period. We examined the data to check for accuracy and completeness and found 

no obvious errors. We compared a sample of data provided with the total minutes 

of delay we calculated from reports available on Amtrak's website and determined 

that it was sufficiently reliable for the purposes of this audit. We used prior audit 

work to identify factors that cause most train delays on Amtrak trains systemwide. 

During site visits to the West Coast, we rode on most segments of the Coast 

Starlight and Amtrak Cascades routes to interview Amtrak personnel and make 

observations. During these rides, we spoke with Amtrak engineers, train 

conductors, and other personnel to obtain their views on the types of delays they 

encountered and their causes, track condition and infrastructure, dispatching 

practices, and other topics. While on the West Coast, we also conducted 

interviews with other key stakeholders about their perspectives on the locations

and causes of train delays, their level of involvement and investment in the two 

passenger train routes, and their relationships with other stakeholders. These 

stakeholders included officials from Amtrak's Pacific Division, Union Pacific 

Railroad, Washington State Department of Transportation, and Sound Transit. We 

also conducted telephone interviews with officials from BNSF Railway, the 

California State Department of Transportation, and the Oregon State Department 

of Transportation, to obtain their views. 

To evaluate trends in OTP for the Coast Starlight and Amtrak Cascades routes 

over the 6-year period and identify the factors that contributed to the trends, we 

obtained and assessed OTP data from Amtrak's OTP System and determined that it 

was sufficiently reliable for the purposes of our audit. To look at recent trends in 

freight traffic, we obtained Sample Waybill data from the Surface Transportation 

Board (STB) for the number of carloads that originated, terminated, or passed 

through the states of California, Oregon, and Washington during 6 years (calendar 

years 2003 through 2008) and used the information as illustrative. In interviews 

with officials from the California, Oregon, and Washington's departments of 

transportation, Sound Transit, Union Pacific, BNSF, and Amtrak, we obtained 

information on recent operational changes (e.g., dispatching practices, reduction in 
21

Exhibit A. Scope and Methodology

slow orders due to maintenance work, etc.) and capital investments that may have 

affected OTP. Finally, we met with officials from Amtrak's Washington 

headquarters, the Federal Railroad Administration, and the STB to obtain their 

views on recent passenger train performance and discuss their new responsibilities 

under PRIIA and DOT's high-speed and intercity rail grant programs.

We conducted this performance audit from October 2008 through July 2010. We 

conducted this audit in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our findings and 

conclusions based on our audit objectives. We believe that the evidence obtained 

provides reasonable basis for our findings and conclusions based on our audit 

objectives. 
22

Exhibit B. Organizations Visited or Contacted

EXHIBIT B. ORGANIZATIONS VISITED OR CONTACTED

Federal Agencies:

Federal Railroad Administration, U.S. Department of Transportation, 

Washington, DC

Surface Transportation Board, Washington, DC

Amtrak:

Amtrak Headquarters, Washington, DC

Amtrak Pacific Division, Seattle, Washington

Host Railroads:

BNSF Railway, Washington, DC

Union Pacific Railroad, Portland, Oregon

State and Local Rail Agencies:

Washington State Department of Transportation, Seattle

Oregon State Department of Transportation, Portland

California State Department of Transportation, Sacramento 

Sound Transit, Seattle
23

Exhibit C. Recent Federal Grant Programs

EXHIBIT C. RECENT FEDERAL GRANT PROGRAMS

To establish long-term partnerships between states and the Federal government to 

support intercity passenger rail, in 2008 Congress enacted the Capital Assistance 

to States—Intercity Passenger Rail Service Program. The program was established 

in part to achieve tangible improvements in intercity passenger rail services by 

improving capacity and reliability, possibly resulting in improvements to OTP. 

Between 2008 and 2009, $120 million in grants were made available to states

through the program. PRIIA established the High-Speed Intercity Passenger Rail 

Program (HSIPR), which built on the existing capital assistance grant program, 

and strengthened the roles of Amtrak, FRA, states, and other stakeholders, 

requiring them to improve intercity passenger rail service and operations.1

 ARRA 

moved the HSIPR Program forward by awarding $8 billion to 31 states to develop 

high-speed and intercity passenger train service. The Coast Starlight and Amtrak 

Cascades routes will benefit from this Federal funding (see table 2 below). 

Table 2: Federal Grant Awards to Washington, Oregon, and California 

2008-2010

State Capital Assistance to 

States Program

Project Description HSIPR 

Program

Project Description

Washington $6 million Projects include 

preliminary 

engineering, 

environmental review, 

and right-of-way 

acquisition for a 1.2 

mile segment of the 

Point Defiance Bypass 

project. Components of 

the project include new 

track and signal systems 

on a realigned right-ofway and a gradeseparated railroad 

crossing. 

$590 

million

Projects include building bypass 

tracks and multiple upgrades to 

existing track and signal systems. 

Several safety-related projects will 

also be funded, including grade 

separations, positive train control, 

and seismic retrofits to Seattle’s 

King Street Station. 

Oregon No relevant funds 

awarded.

Not applicable. $8 million Work includes upgrading 

Portland’s Union Station and 

engineering and environmental 

work for track and signaling 

projects.

 1 This includes Amtrak’s long-distance routes, the Northeast Corridor, state-supported corridors, and new high-speed 

corridors.
24

Exhibit D. Amtrak Delay Codes and Categories*

EXHIBIT D. AMTRAK DELAY CODES AND CATEGORIES*

Category Code Delay 

Host

Signal Delays DCS Signal Delays 

Maintenance of Way Work DMW Maintenance of Way Work 

Slow Orders DSR Temporary Slow Orders

Freight Train Interference FTI Freight Train Interference 

Passenger Train Interference PTI Passenger Train Inference

Routing Delays RTE Routing Delays

Other CTI Commuter Train Interference

DBB B&B Work

DBS Debris Strike

DET Electric Traction Work Due to Defect

DTR Detour

ITE Initial Terminal Delay Due to Engineering

PBB Planned B&B Work

PET Planned Electric Traction Work

PSR Planned Slow Orders

SMW Scheduled Maintenance of Way Work

Amtrak

Equipment CAR Car Failure

CCR Cab Car Failure

ENG Engine Failure

ITM Initial Terminal Delay Due to Mechanical Failure

Late Connections CON Hold For a Late Connection

Passenger Related ADA Passenger Related-Disabled Passengers

HLD All Other Passenger Related Delay

Other CTC CETC System

INJ Injury

ITI Initial Terminal Delay Due to Late-Arriving Inbound Train

ITT Initial Terminal Delay Due to Transportation/Operations Related 

Causes

LMU Late Makeup

MAL Mail or Baggage Work

MCH Miscellaneous Mechanical Delay

MSC Miscellaneous Passenger Delay

OPS Miscellaneous Operation Delay

OTH Miscellaneous Amtrak-Responsible Delays

SMK Smoking Breaks

SVS Servicing Delays

SYS System Delays
25

Exhibit D. Amtrak Delay Codes and Categories*

Category Code Delay 

Third Party

Unused Recovery Time NOD No Delay

Passenger Related ADA Passenger Related-Disabled Passengers

Other BSP Bridge Strike

CUI Customs and Immigration

DBS Debris Strike, Damage, and Set Outs

ITE Initial Terminal Delay Due to Engineering

ITT Initial Terminal Delay Due to Transportation/Operations Related 

Causes

MBO Drawbridge Opening for Marine Traffic

POL Police Related

TRS Trespasser Incidents

WTR Weather

*As of April 2009
26

Exhibit E. Percentages of Delays for Coast Starlight and Amtrak 

Cascades Routes, by Fiscal Year and Responsibility*

EXHIBIT E. PERCENTAGES OF DELAYS FOR COAST 

STARLIGHT AND AMTRAK CASCADES ROUTES, BY FISCAL 

YEAR AND RESPONSIBILITY*

Coast Starlight

Responsibility Category 2004 2005 2006 2007 2008 2009

2004-

2009

Amtrak Equipment 1.98 4.29 2.94 3.16 4.68 4.68 3.35

Late Connections 1.14 0.49 1.02 0.55 0.80 0.39 0.74

Other 9.06 12.16 9.09 6.85 8.33 10.95 9.01

Passenger Related 3.88 3.23 2.48 3.18 4.34 5.17 3.38

Amtrak Total 16.06 20.35 15.52 13.74 18.44 21.20 16.47

Host Signal Delays 6.86 6.81 5.76 6.48 8.33 10.81 6.83

Maintenance of Way Work 3.09 3.18 3.39 5.52 4.50 3.87 3.71

Slow Orders 26.90 28.31 32.88 31.42 25.90 21.19 27.62

Freight Train Interference 27.89 22.53 24.97 23.18 17.48 8.10 21.22

Other 1.24 0.94 1.58 1.98 3.11 3.89 1.82

Passenger Train Interference 10.08 10.68 9.53 10.34 13.88 15.50 10.69

Routing Delays 4.60 4.89 3.73 4.40 4.22 3.14 4.05

Host Total 80.65 77.33 81.85 83.32 77.42 66.52 75.95

Third Party Other 3.23 2.27 2.55 2.92 3.53 4.86 2.92

Passenger Related 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Unused Recovery Time 0.06 0.05 0.08 0.02 0.61 7.42 0.87

Third Party Total 3.29 2.32 2.63 2.94 4.14 12.28 3.79

Amtrak Cascades

Responsibility

Category 2004 2005 2006 2007 2008 2009

2004-

2009

Amtrak Equipment 4.01 4.84 3.77 4.42 5.56 7.99 5.06

Other 3.81 4.11 6.17 5.09 4.52 5.86 4.98

Passenger Related 2.78 2.79 2.04 3.41 4.30 4.83 3.34

Late Connections 1.95 0.72 0.68 0.71 0.82 0.77 0.92

Amtrak Total 12.55 12.46 12.65 13.62 15.20 19.44 14.31

Host Signal Delays 9.69 8.25 7.87 7.99 8.42 9.73 8.62

Maintenance of Way Work 2.86 2.36 2.54 3.73 2.79 3.14 2.92

Slow Orders 14.08 20.21 12.72 19.00 22.88 18.15 17.75

Freight Train Interference 36.54 29.94 38.20 24.50 20.06 12.98 27.14

Other 0.31 0.51 1.12 1.03 1.17 1.37 0.94

Passenger Train Interference 7.09 7.66 8.84 11.49 9.82 10.93 9.38

Routing Delays 8.72 9.60 8.40 9.30 10.45 13.90 10.02

Host Total 79.29 78.55 79.69 77.03 75.59 70.20 76.76

Third Party Other 8.16 8.99 7.65 9.31 9.17 9.62 8.80

Unused Recovery Time 0.01 0.01 0.01 0.03 0.04 0.73 0.13

Third Party Total 8.16 9.00 7.66 9.34 9.21 10.35 8.93

*As of January 2010
27

Exhibit F. Major Contributors to This Report

EXHIBIT F. MAJOR CONTRIBUTORS TO THIS REPORT

Toayoa Aldridge Program Director

Name Title

Nancy Benco Senior Analyst

Lindsay Steward Analyst

Karen Sloan Communications Officer

Susan Neill Writer-Editor
28

Appendix. Agency Comments

APPENDIX. AGENCY COMMENTS 
29

Appendix. Agency Comments
30

Appendix. Agency Comments