June 1, 2021

The Honorable Pete Buttigieg 

U.S. Secretary of Transportation 

1200 New Jersey Ave, SE 

Washington, DC 20590 

Dear Secretary Buttigieg, 

The Metrics and Minimum Standards for Intercity Passenger Rail Service final rule published by the 

Federal Railroad Administration (“FRA”) on November 16, 2020 (the “Final Rule”), introduces a 

certified schedule metric that requires the FRA to report the number of certified Amtrak schedules, 

uncertified schedules, and disputed schedules, by train, route, and host railroad. 

The Final Rule defines a “certified schedule” as a published Amtrak train schedule that Amtrak and the 

host railroad jointly certify is aligned with the customer on-time performance (“OTP”) metric and 

standard set forth in the Final Rule. 

Pursuant to the requirements of the Final Rule, Amtrak and Southern California Regional Rail Authority 

(SCRRA) are transmitting this letter regarding the following schedules that remain uncertified as of May 

17, 2021, as agreement has not been reached on whether the schedule is aligned to customer OTP:

1. Coast Starlight Trains 11 and 14 

2. Pacific Surfliner Trains 561, 562, 564, 565, 566, 569, 572, 573, 578, 579, 580, 583, 584, 590, 

591, 593, 595, 759, 763, 767, 768, 774, 777, 782, 785, 792, 796, 1564, 1565, 1566, 1569, 1572, 

1573, 1584, 1590, 1591, 1761 and 1767 

3. Southwest Chief Trains 3 and 4 

4. Sunset Limited Trains 1 and 2. 

Exhibit A details Amtrak’s position regarding the components of the train schedules which are disagreed 

upon, signed by me. 

A supplemental exhibit providing SCRRA’s position regarding the components of the train schedules 

which are disagreed upon was requested by Amtrak but has thus far not been received for incorporation 

into the monthly joint letter prescribed by the Final Rule. 

AMTRAK

1 Massachusetts Avenue, NW, Washington, DC 20001

Email william.flynn@amtrak.com Tel 202-906-3963 

William J. Flynn

Chief Executive Officer
The Honorable Pete Buttigieg

June 1, 2021

Page 2

Amtrak and SCRRA continue to communicate regularly and hope to come to an agreement on the 

certification of all schedules by no later than September 30, 2021. Please let us know if you have any 

questions regarding the information provided in this transmittal. 

Sincerely,

William J. Flynn

Chief Executive Officer

Attachment 

cc: The Honorable Martin J. Oberman, Chairman, Surface Transportation Board 

The Honorable Peter A. DeFazio, Chair, Committee on Transportation and Infrastructure, U.S. 

House of Representatives

 The Honorable Sam Graves, Ranking Member, Committee on Transportation and Infrastructure, 

U.S. House of Representatives 

 The Honorable Maria Cantwell, Chair, Committee on Commerce, Science, and Transportation, 

U.S. Senate 

 The Honorable Roger Wicker, Ranking Member, Committee on Commerce, Science, and 

Transportation, U.S. Senate 

 The Honorable Rosa L. DeLauro, Chair, Committee on Appropriations, U.S. House of 

Representatives

 The Honorable Kay Granger, Ranking Member, Committee on Appropriations, U.S. House of 

Representatives

 The Honorable Patrick Leahy, Chair, Committee on Appropriations, U.S. Senate 

 The Honorable Richard Shelby, Ranking Member, Committee on Appropriations, U.S. Senate 

 The Honorable Pete Aguilar, U.S. House of Representatives 

 The Honorable Brian Babin, U.S. House of Representatives 

 The Honorable Nanette Diaz Barragán, U.S. House of Representatives 

 The Honorable Karen Bass, U.S. House of Representatives 

The Honorable Michael Bennet, U.S. Senate 

 The Honorable Cliff Bentz, U.S. House of Representatives 

 The Honorable Ami Bera, U.S. House of Representatives 

 The Honorable Andy Biggs, U.S. House of Representatives 

 The Honorable Earl Blumenauer, U.S. House of Representatives 

The Honorable Roy Blunt, U.S. Senate 

 The Honorable Suzanne Bonamici, U.S. House of Representatives 

 The Honorable Julia Brownley, U.S. House of Representatives 

 The Honorable Ken Buck, U.S. House of Representatives
The Honorable Pete Buttigieg

June 1, 2021

Page 3

 The Honorable Cheri Bustos, U.S. House of Representatives 

 The Honorable Ken Calvert, U.S. House of Representatives 

 The Honorable Salud Carbajal, U.S. House of Representatives 

The Honorable Tony Cárdenas, U.S. House of Representatives 

 The Honorable Troy Carter, U.S. House of Representatives 

 The Honorable Bill Cassidy, U.S. Senate 

 The Honorable Sean Casten, U.S. House of Representatives 

 The Honorable Joaquin Castro, U.S. House of Representatives

 The Honorable Judy Chu, U.S. House of Representatives 

 The Honorable Emanuel Cleaver, U.S. House of Representatives 

 The Honorable John Cornyn, U.S. Senate 

 The Honorable Lou Correa, U.S. House of Representatives 

 The Honorable Dan Crenshaw, U.S. House of Representatives 

 The Honorable Ted Cruz, U.S. Senate 

 The Honorable Henry Cuellar, U.S. House of Representatives 

 The Honorable Sharice Davids, U.S. House of Representatives 

 The Honorable Danny Davis, U.S. House of Representatives

 The Honorable Suzan DelBene, U.S. House of Representatives 

 The Honorable Mark DeSaulnier, U.S. House of Representatives 

 The Honorable Lloyd Doggett, U.S. House of Representatives 

 The Honorable Tammy Duckworth, U.S. Senate 

 The Honorable Dick Durbin, U.S. Senate 

 The Honorable Joni Ernst, U.S. Senate 

 The Honorable Veronica Escobar, U.S. House of Representatives 

 The Honorable Anna Eshoo, U.S. House of Representatives 

The Honorable Ron Estes, U.S. House of Representatives 

 The Honorable Dianne Feinstein, U.S. Senate 

 The Honorable Teresa Leger Fernandez, U.S. House of Representatives

The Honorable Lizzie Fletcher, U.S. House of Representatives

 The Honorable Bill Foster, U.S. House of Representatives 

 The Honorable Ruben Gallego, U.S. House of Representatives 

 The Honorable John Garamendi, U.S. House of Representatives 

 The Honorable Jesús García, U.S. House of Representatives 

 The Honorable Mike Garcia, U.S. House of Representatives 

 The Honorable Sylvia Garcia, U.S. House of Representatives

 The Honorable Jimmy Gomez, U.S. House of Representatives 

 The Honorable Tony Gonzales, U.S. House of Representatives 

 The Honorable Paul Gosar, U.S. House of Representatives 

 The Honorable Chuck Grassley, U.S. Senate 

 The Honorable Garret Graves, U.S. House of Representatives

 The Honorable Al Green, U.S. House of Representatives 
The Honorable Pete Buttigieg

June 1, 2021

Page 4 

 The Honorable Raul Grijalva, U.S. House of Representatives 

The Honorable Josh Hawley, U.S. Senate 

The Honorable Martin Heinrich, U.S. Senate 

 The Honorable Yvette Herrell, U.S. House of Representatives 

The Honorable Jaime Herrera Beutler, U.S. House of Representatives

The Honorable John Hickenlooper, U.S. Senate 

 The Honorable Clay Higgins, U.S. House of Representatives

 The Honorable Darrell Issa, U.S. House of Representatives 

 The Honorable Sarah Jacobs, U.S. House of Representatives 

The Honorable Pramila Jayapal, U.S. House of Representatives

 The Honorable Robin Kelly, U.S. House of Representatives 

 The Honorable Mark Kelly, U.S. Senate 

 The Honorable John Kennedy, U.S. Senate 

 The Honorable Ro Khanna, U.S. House of Representatives 

 The Honorable Derek Kilmer, U.S. House of Representatives 

 The Honorable Young Kim, U.S. House of Representatives

 The Honorable Adam Kinzinger, U.S. House of Representatives 

 The Honorable Ann Kirkpatrick, U.S. House of Representatives 

 The Honorable Darin LaHood, U.S. House of Representatives 

 The Honorable Doug LaMalfa, U.S. House of Representatives

 The Honorable Jake LaTurner, U.S. House of Representatives

The Honorable Barbara Lee, U.S. House of Representatives

 The Honorable Sheila Jackson Lee, U.S. House of Representatives 

 The Honorable Mike Levin, U.S. House of Representatives 

 The Honorable Ted Lieu, U.S. House of Representatives 

 The Honorable Zoe Lofgren, U.S. House of Representatives 

The Honorable Ben Ray Luján, U.S. Senate 

The Honorable Tracey Mann, U.S. House of Representatives 

The Honorable Roger Marshall, U.S. Senate 

The Honorable Doris Matsui, U.S. House of Representatives 

The Honorable Michael McCaul, U.S. House of Representatives

 The Honorable Jeff Merkley, U.S. Senate 

 The Honorable Mariannette Miller-Meeks, U.S. House of Representatives

The Honorable Jerry Moran, U.S. Senate 

 The Honorable Patty Murray, U.S. Senate 

 The Honorable Grace Napolitano, U.S. House of Representatives 

 The Honorable Troy Nehls, U.S. House of Representatives 

The Honorable Marie Newman, U.S. House of Representatives

 The Honorable Jay Obernolte, U.S. House of Representatives 

 The Honorable Tom O'Halleran, U.S. House of Representatives 

 The Honorable Alex Padilla, U.S. Senate 
The Honorable Pete Buttigieg

June 1, 2021

Page 5 

 The Honorable Jimmy Panetta, U.S. House of Representatives 

 The Honorable Nancy Pelosi, U.S. House of Representatives

The Honorable Scott Peters, U.S. House of Representatives

The Honorable Katie Porter, U.S. House of Representatives

 The Honorable Mike Quigley, U.S. House of Representatives 

 The Honorable Chip Roy, U.S. House of Representatives 

 The Honorable Lucille Roybal-Allard, U.S. House of Representatives 

 The Honorable Raul Ruiz, U.S. House of Representatives 

 The Honorable Bobby Rush, U.S. House of Representatives 

 The Honorable Linda T. Sánchez, U.S. House of Representatives

The Honorable Steve Scalise, U.S. House of Representatives

 The Honorable Janice Schakowsky, U.S. House of Representatives 

 The Honorable Adam Schiff, U.S. House of Representatives 

 The Honorable Kurt Schrader, U.S. House of Representatives

 The Honorable Brad Sherman, U.S. House of Representatives 

 The Honorable Kyrsten Sinema, U.S. Senate 

 The Honorable Adam Smith, U.S. House of Representatives 

 The Honorable Greg Stanton, U.S. House of Representatives 

The Honorable Michelle Steel, U.S. House of Representatives

 The Honorable Marilyn Strickland, U.S. House of Representatives 

 The Honorable Mark Takano, U.S. House of Representatives 

 The Honorable Mike Thompson, U.S. House of Representatives 

 The Honorable Norma Torres, U.S. House of Representatives 

The Honorable Juan Vargas, U.S. House of Representatives

 The Honorable Michael Waltz, U.S. House of Representatives 

 The Honorable Maxine Waters, U.S. House of Representatives 

 The Honorable Randy Weber, U.S. House of Representatives

 The Honorable Ron Wyden, U.S. Senate 
Exhibit A

Amtrak’s position regarding the disagreed upon components of the train schedules.

The Final Rule defines a “certified schedule” as a published train schedule that Amtrak and the host railroad 

jointly certify is aligned with the customer on-time performance (“OTP”) metric and standard set forth in 

the Final Rule. In order to determine whether a train schedule is aligned with the customer OTP metric, 

Amtrak developed an analytical framework to review each schedule and its alignment with the customer 

OTP metric. Fundamentally, the analytical framework confirms whether the schedule works to minimize 

passenger delay while giving riders the greatest opportunity to arrive at their destinations on-time. Several 

criteria, listed below, were rigorously analyzed to determine whether the schedule was appropriately aligned 

to the customer OTP metric.

1. Prior Customer OTP Schedule Modifications. If Amtrak and the host railroad previously 

agreed to modify the schedule to align with customer OTP, and no significant changes in 

passenger deboarding patterns were evident since that agreement, that schedule was determined 

to be aligned with the customer OTP metric. 

2. Strong Historical Performance. While certification directly relates to the schedule, not actual 

performance, if a train has regularly exceeded the minimum standard 80% customer OTP, that 

schedule was deemed to be aligned with the customer OTP metric. 

3. Recovery Time-Ridership Correlation. Amtrak performed a regression analysis for each 

schedule to calculate the correlation between the placement of recovery time in the schedule and 

the number of detraining riders at each station. If the regression result was strong (0.5 or more), 

the train schedule was determined to be aligned with the customer OTP metric. 

4. Recovery Time Distributed to Passenger Benefit. Amtrak developed a measurement of the 

schedule’s recovery time distribution to determine whether that time is effectively placed to help 

passengers. If the recovery time is placed in advance of detraining passengers to help them arrive 

on-time, then, based on a consistent calculation for all trains, the schedule was determined to be 

aligned with the customer OTP metric.

Table 1 lists each uncertified train schedule by service and notes which criteria were met for each schedule

that led to Amtrak’s determination that the schedule is aligned with customer OTP. Amtrak looks forward 

to continuing to work with Southern California Regional Rail Authority to certify the following schedules.

Sincerely,

William J. Flynn

Chief Executive Officer

Amtrak
Table 1: Amtrak Schedule Alignment Analysis Results by Train

Service Train

Train OriginDestination 

1. Prior Customer 

OTP Schedule 

Modifications

2. Strong Historical 

Performance 

3. Recovery TimeRidership 

Correlation

4. Recovery Time 

Distributed to 

Passenger Benefit 

Assessment based on 

Criteria

Coast 

Starlight

11 Seattle-Los Angeles √ √ Aligned to Customer OTP

Coast 

Starlight

14 Seattle-Los Angeles √ Aligned to Customer OTP

Pacific 

Surfliner

561 San Diego-Los 

Angeles

√ √ √ √ Aligned to Customer OTP

Pacific 

Surfliner

562 Los Angeles-San 

Diego

√ √ √ Aligned to Customer OTP

Pacific 

Surfliner

564 Los Angeles-San 

Diego

√ √ √ Aligned to Customer OTP

Pacific 

Surfliner

565 San Diego-Los 

Angeles

√ √ √ Aligned to Customer OTP

Pacific 

Surfliner

566 Los Angeles-San 

Diego

√ √ √ Aligned to Customer OTP

Pacific 

Surfliner

569 San Diego-Los 

Angeles

√ √ Aligned to Customer OTP

Pacific 

Surfliner

572 Los Angeles-San 

Diego

√ √ √ Aligned to Customer OTP

Pacific 

Surfliner

573 San Diego-Los 

Angeles

√ √ √ Aligned to Customer OTP

Pacific 

Surfliner

578 Los Angeles-San 

Diego

√ √ √ √ Aligned to Customer OTP

Pacific 

Surfliner

579 San Diego-Los 

Angeles

√ √ √ √ Aligned to Customer OTP

Pacific 

Surfliner

580 Los Angeles-San 

Diego

√ √ √ Aligned to Customer OTP

Pacific 

Surfliner

583 San Diego-Los 

Angeles

√ √ √ √ Aligned to Customer OTP

Pacific 

Surfliner

584 Los Angeles-San 

Diego

√ √ √ Aligned to Customer OTP

Pacific 

Surfliner

590 Los Angeles-San 

Diego

√ √ √ Aligned to Customer OTP

Pacific 

Surfliner

591 San Diego-Los 

Angeles

√ √ Aligned to Customer OTP
Pacific 

Surfliner

593 San Diego-Los 

Angeles

√√√√ Aligned to Customer OTP

Pacific 

Surfliner

595 San Diego-Los 

Angeles

√√√√ Aligned to Customer OTP

Pacific 

Surfliner

759 Los Angeles-Goleta√√√√ Aligned to Customer OTP

Pacific 

Surfliner

763 San Diego-Goleta√√√ Aligned to Customer OTP

Pacific 

Surfliner

767 San Diego-Los 

Angeles

√√√√ Aligned to Customer OTP

Pacific 

Surfliner

768 Goleta-San Diego√√√√ Aligned to Customer OTP

Pacific 

Surfliner

774 San Luis Obispo-

San Diego

√√√ Aligned to Customer OTP

Pacific 

Surfliner

777 Goleta-San Diego√√ Aligned to Customer OTP

Pacific 

Surfliner

782 Goleta-San Diego√√√√ Aligned to Customer OTP

Pacific 

Surfliner

785 San Diego-Goleta√√√√ Aligned to Customer OTP

Pacific 

Surfliner

792 Goleta-San Diego√√√ Aligned to Customer OTP

Pacific 

Surfliner

796 Goleta-San Diego√√√ Aligned to Customer OTP

Pacific 

Surfliner

1564 Los Angeles-San 

Diego

√√√√ Aligned to Customer OTP

Pacific 

Surfliner

1565 San Diego-Los 

Angeles

√√√√ Aligned to Customer OTP

Pacific 

Surfliner

1566 Los Angeles-San 

Diego

√√√ Aligned to Customer OTP

Pacific 

Surfliner

1569 San Diego-Los 

Angeles

√√ Aligned to Customer OTP

Pacific 

Surfliner

1572 Los Angeles-San 

Diego

√√ Aligned to Customer OTP

Pacific 

Surfliner

1573 San Diego-Los 

Angeles

√√√√ Aligned to Customer OTP

Pacific 

Surfliner

1584 Los Angeles-San 

Diego

√√√ Aligned to Customer OTP

Pacific 

Surfliner

1590 Los Angeles-San 

Diego

√√√ Aligned to Customer OTP
Pacific 

Surfliner

1591 San Diego-Los 

Angeles

√√√ Aligned to Customer OTP

Pacific 

Surfliner

1761 San Diego-Goleta√ Aligned to Customer OTP

Pacific 

Surfliner

1767 San Diego-Los 

Angeles

√√√√ Aligned to Customer OTP

Southwest 

Chief

3 Chicago-Los 

Angeles

√√√ Aligned to Customer OTP

Southwest 

Chief

4 Chicago-Los 

Angeles

√√ Aligned to Customer OTP

Sunset 

Limited

1 New Orleans-Los 

Angeles

√√ Aligned to Customer OTP

Sunset 

Limited

2 New Orleans-Los 

Angeles

√√ Aligned to Customer OTP