September 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 set forth at 49 C.F.R. 

Part 273 and published by the Federal Railroad Administration (“FRA”) on November 16, 2020 (the 

“Final Rule”), introduces a certified schedule metric that requires Amtrak to report to the FRA 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. The customer OTP metric is the percentage of all customers who 

arrive at their detraining point no later than fifteen (15) minutes after their published scheduled arrival 

time, reported by train and by route, and the customer OTP standard is eighty (80) percent for any two

consecutive calendar quarters. See 49 C.F.R. 273.5(a)(1) & (2). 

As required by the Final Rule, Amtrak and Metro-North Commuter Railroad Company (MNRR) are 

transmitting this joint letter reporting the following schedules that remain uncertified as of August 31, 

2021, as agreement has not been reached on whether the schedules are aligned with the customer OTP 

metric and standard:

1. Acela Trains 2150, 2151, 2154, 2155, 2159, 2160, 2163, 2164, 2165, 2167, 2168, 2171, 2175, 

2190, 2253, 2254, 2255, 2256, 2258, 2259, 2260, 2261, 2275 and 2290 

2. Adirondack Trains 68 and 69 

3. Ethan Allen Express Trains 290, 291, 292, 293, 295 and 296 

4. Maple Leaf Trains 63 and 64

5. New York – Albany Trains 230, 232, 233, 234, 235, 236, 237, 238, 241, 242, 243, 244, 245, 250, 

252, 253, 254, 255, 256, 259, 260 and 261 

6. New York – Niagara Falls Trains 280, 281, 283, 284 and 288 

7. Northeast Regional Trains 132, 137, 140, 141, 146, 148, 149, 150, 163, 167, 168, 177, 178, and 

179 

8. Richmond/Newport News/Norfolk Trains 65, 66, 67, 82, 86, 95, 96, 174 and 194 

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

September 1, 2021

Page 2

9. Roanoke Trains 171 and 176 

10. Vermonter Trains 54, 55, 56 and 57. 

We are pleased to report that 20 additional schedules were certified since the August 1, 2021, letter was 

transmitted. 

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

and MNRR have not yet agreed, signed by me. 

Exhibit B details MNRR’s position regarding the components of the train schedules upon which Amtrak 

and MNRR have not yet agreed, signed by MNRR Senior Vice President Justin R. Vonashek. 

Amtrak and MNRR continue to meet regularly and hope to come to an agreement on the certification of 

all schedules. Please let us know if you have any questions regarding the information provided in this 

transmittal.

Sincerely,

William J. Flynn

Chief Executive Officer

Attachments

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 Don Beyer, U.S. House of Representatives 
The Honorable Pete Buttigieg

September 1, 2021

Page 3 

 The Honorable Richard Blumenthal, U.S. Senate 

 The Honorable Cory Booker, U.S. Senate 

 The Honorable Jamaal Bowman, U.S. House of Representatives

 The Honorable Brendan Boyle, U.S. House of Representatives 

 The Honorable Anthony Brown, U.S. House of Representatives 

 The Honorable Ben Cardin, U.S. Senate 

 The Honorable Tom Carper, U.S. Senate 

 The Honorable Bob Casey, U.S. Senate

 The Honorable David Cicilline, U.S. House of Representatives 

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

 The Honorable Ben Cline, U.S. House of Representatives 

 The Honorable Gerry Connolly, U.S. House of Representatives 

 The Honorable Chris Coons, U.S. Senate 

 The Honorable Joe Courtney, U.S. House of Representatives 

 The Honorable Madeleine Dean, U.S. House of Representatives 

 The Honorable Antonio Delgado, U.S. House of Representatives 

 The Honorable Adriano Espaillat, U.S. House of Representatives

 The Honorable Dwight Evans, U.S. House of Representatives 

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

 The Honorable Kirsten Gillibrand, U.S. Senate 

 The Honorable Bob Good, U.S. House of Representatives 

 The Honorable Morgan Griffith, U.S. House of Representatives 

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

 The Honorable Maggie Hassan, U.S. Senate 

 The Honorable Jahana Hayes, U.S. House of Representatives 

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

 The Honorable Jim Himes, U.S. House of Representatives 

 The Honorable Steny Hoyer, U.S. House of Representatives 

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

The Honorable Hakeem Jeffries, U.S. House of Representatives

The Honorable Mondaire Jones, U.S. House of Representatives 

 The Honorable Tim Kaine, U.S. Senate 

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

 The Honorable Ann McLane Kuster, U.S. House of Representatives 

 The Honorable Jim Langevin, U.S. House of Representatives

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

 The Honorable Elaine Luria, U.S. House of Representatives 

 The Honorable Stephen Lynch, U.S. House of Representatives 

 The Honorable Nicole Malliotakis, U.S. House of Representatives

 The Honorable Carolyn Maloney, U.S. House of Representatives 

 The Honorable Sean Patrick Maloney, U.S. House of Representatives 

 The Honorable Ed Markey, U.S. Senate 
The Honorable Pete Buttigieg

September 1, 2021

Page 4 

 The Honorable Donald McEachin, U.S. House of Representatives 

 The Honorable James McGovern, U.S. House of Representatives 

 The Honorable Gregory W. Meeks, U.S. House of Representatives 

 The Honorable Bob Menendez, U.S. Senate 

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

The Honorable Kweisi Mfume, U.S. House of Representatives

 The Honorable Joseph Morelle, U.S. House of Representatives 

 The Honorable Chris Murphy, U.S. Senate 

 The Honorable Jerrold Nadler, U.S. House of Representatives 

 The Honorable Richard Neal, U.S. House of Representatives 

 The Honorable Donald Norcross, U.S. House of Representatives 

 The Honorable Eleanor Holmes Norton, U.S. House of Representatives 

 The Honorable Alexandria Ocasio-Cortez, U.S. House of Representatives 

The Honorable Frank Pallone, Jr., U.S. House of Representatives 

 The Honorable Donald M. Payne, Jr., U.S. House of Representatives 

 The Honorable Ayanna Pressley, U.S. House of Representatives 

 The Honorable Jamie Raskin, U.S. House of Representatives 

 The Honorable Jack Reed, U.S. Senate 

 The Honorable Kathleen Rice, U.S. House of Representatives 

 The Honorable Lisa Blunt Rochester, U.S. House of Representatives 

 The Honorable C. A. Dutch Ruppersberger, U.S. House of Representatives 

 The Honorable Bernie Sanders, U.S. Senate

 The Honorable John P. Sarbanes, U.S. House of Representatives 

 The Honorable Mary Gay Scanlon, U.S. House of Representatives 

 The Honorable Chuck Schumer, U.S. Senate 

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

 The Honorable Jeanne Shaheen, U.S. Senate 

 The Honorable Albio Sires, U.S. House of Representatives 

 The Honorable Christopher H. Smith, U.S. House of Representatives 

 The Honorable Abigail Spanberger, U.S. House of Representatives 

 The Honorable Elise Stefanik, U.S. House of Representatives 

 The Honorable Thomas Suozzi, U.S. House of Representatives 

 The Honorable Claudia Tenney, U.S. House of Representatives 

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

 The Honorable Pat Toomey, U.S. Senate 

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

 The Honorable Chris Van Hollen, U.S. Senate 

 The Honorable Nydia Velazquez, U.S. House of Representatives 

 The Honorable Mark Warner, U.S. Senate 

 The Honorable Elizabeth Warren, U.S. Senate 

 The Honorable Bonnie Watson Coleman, U.S. House of Representatives 

 The Honorable Peter Welch, U.S. House of Representatives 
The Honorable Pete Buttigieg

September 1, 2021

Page 5 

 The Honorable Jennifer Wexton, U.S. House of Representatives 

The Honorable Sheldon Whitehouse, U.S. Senate 

 The Honorable Rob Wittman, U.S. House of Representatives 
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. 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 

metric1

. The criteria which Amtrak used as the basis to certify schedules were included in our December 

18, 2020 schedule certification proposal to Metro-North Commuter Railroad (MNRR). Amtrak and Metro 

North have been meeting regularly to review the schedules. 

MNRR continues to advise that they will not certify schedules for trains that are not currently running and 

as such, they have not engaged in further discussions of these trains. 

Amtrak and Metro North have made progress and recently certified the following additional 20 schedules: 

1. Acela Trains 2169, 2173, 2249, 2250, 2251, 2252, and 2257 

2. Northeast Regional Trains 135, 136, 139, 143, 161, 162, 166, 169, 170, 172, 175 and 190 

3. Richmond/Newport News/Norfolk Trains 157 

Table 1 appended below 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 will continue to work closely with MNRR on the remaining uncertified schedules. 

Sincerely,

William J. Flynn

Chief Executive Officer

Amtrak

1 The four analytic criteria applied to each schedule were: (i) 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, (ii) if a train has regularly exceeded the minimum standard 80% customer OTP, 

(iii) If a regression, measuring the relationship between the placement of recovery time in the schedule and the 

number of detraining riders at each station resulted in a strong (0.5 or more) correlation, or (iv) if the recovery 

time is placed in advance of detraining passengers to help them arrive on-time. If a train schedule met any of 

these four criteria, the schedule was determined to be aligned with the customer OTP metric. 95% of the trains 

met more than one criterion.
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

Acela 2150 Washington-Boston √ √ √ Aligned to Customer OTP

Acela 2151 Boston-Washington √ √ √ √ Aligned to Customer OTP

Acela 2154 Washington-Boston √ √ √ Aligned to Customer OTP

Acela 2155 Boston-Washington √ √ √ √ Aligned to Customer OTP

Acela 2159 Boston-Washington √ √ √ √ Aligned to Customer OTP

Acela 2160 Washington-Boston √ √ Aligned to Customer OTP

Acela 2163 Boston-Washington √ √ √ Aligned to Customer OTP

Acela 2164 Washington-Boston √ √ √ Aligned to Customer OTP

Acela 2165 Boston-Washington √ √ √ Aligned to Customer OTP

Acela 2167 Boston-Washington √ √ √ Aligned to Customer OTP

Acela 2168 Washington-Boston √ √ Aligned to Customer OTP

Acela 2171 Boston-Washington √ √ √ √ Aligned to Customer OTP

Acela 2175 Boston-Washington √ √ √ Aligned to Customer OTP

Acela 2190 New York-Boston √ √ √ Aligned to Customer OTP

Acela 2253 Boston-Washington √ √ √ √ Aligned to Customer OTP

Acela 2254 Washington-Boston √ √ Aligned to Customer OTP

Acela 2255 Boston-Washington √ √ √ √ Aligned to Customer OTP

Acela 2256 Washington-Boston √ √ √ Aligned to Customer OTP

Acela 2258 Washington-Boston √ Aligned to Customer OTP

Acela 2259 Boston-Washington √ √ √ √ Aligned to Customer OTP

Acela 2260 Washington-Boston √ √ √ Aligned to Customer OTP

Acela 2261 Boston-Washington √ √ √ Aligned to Customer OTP

Acela 2275 Boston-Washington √ √ √ √ Aligned to Customer OTP

Acela 2290 New York-Boston √ √ √ Aligned to Customer OTP

Adirondack 68 New York-Montreal √ √ √ Aligned to Customer OTP

Adirondack 69 New York-Montreal √ √ √ Aligned to Customer OTP

Ethan Allen 

Express

290 New York-Rutland √ √ √ √ Aligned to Customer OTP

Ethan Allen 

Express

291 New York-Rutland √ √ Aligned to Customer OTP

Ethan Allen 

Express

292 New York-Rutland √ √ √ Aligned to Customer OTP

Ethan Allen 

Express

293 New York-Rutland √ √ √ Aligned to Customer OTP
Ethan Allen 

Express

295 New York-Rutland√ Aligned to Customer OTP

Ethan Allen 

Express

296 New York-Rutland√√√√ Aligned to Customer OTP

Maple Leaf 63 New York-Toronto√√ Aligned to Customer OTP

Maple Leaf 64 New York-Toronto√√√ Aligned to Customer OTP

New York -

Albany

230 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

232 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

233 New York-Albany√√√ Aligned to Customer OTP

New York -

Albany

234 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

235 New York-Albany√√√ Aligned to Customer OTP

New York -

Albany

236 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

237 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

238 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

241 New York-Albany√√√ Aligned to Customer OTP

New York -

Albany

242 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

243 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

244 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

245 New York-Albany√√√ Aligned to Customer OTP

New York -

Albany

250 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

252 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

253 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

254 New York-Albany√√√√ Aligned to Customer OTP
New York 

-

Albany

255 New York-Albany√√√ Aligned to Customer OTP

New York -

Albany

256 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

259 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

260 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

261 New York-Albany√√√√ Aligned to Customer OTP

New York -

Niagara 

Falls

280 New York-Niagara 

Falls

√√√√ Aligned to Customer OTP

New York -

Niagara 

Falls

281 New York-Niagara 

Falls

√ Aligned to Customer OTP

New York -

Niagara 

Falls

283 New York-Niagara 

Falls

√ Aligned to Customer OTP

New York -

Niagara 

Falls

284 New York-Niagara 

Falls

√√√√ Aligned to Customer OTP

New York -

Niagara 

Falls

288 New York-Niagara 

Falls

√√√√ Aligned to Customer OTP

Northeast 

Regional

132 Washington-Boston√√ Aligned to Customer OTP

Northeast 

Regional

137 Boston-Washington√√√√ Aligned to Customer OTP

Northeast 

Regional

140 Washington-

Springfield

√√ Aligned to Customer OTP

Northeast 

Regional

141 Springfield-

Washington

√√√√ Aligned to Customer OTP

Northeast 

Regional

146 Washington-

Springfield

√√ Aligned to Customer OTP

Northeast 

Regional

148 Washington-

Springfield

√√ Aligned to Customer OTP

Northeast 

Regional

149 Boston-Washington√√√√ Aligned to Customer OTP
Northeast 

Regional

150 Washington-Boston√√√ Aligned to Customer OTP

Northeast 

Regional

163 Boston-Washington√√√√ Aligned to Customer OTP

Northeast 

Regional

167 Boston-Washington√√√√ Aligned to Customer OTP

Northeast 

Regional

168 Washington-Boston√√ Aligned to Customer OTP

Northeast 

Regional

177 Boston-Washington√√ Aligned to Customer OTP

Northeast 

Regional

178 Washington-Boston√√ Aligned to Customer OTP

Northeast 

Regional

179 Boston-New York√√√ Aligned to Customer OTP

Richmond / 

Newport 

News / 

Norfolk

65 Boston-Newport 

News

√√√ Aligned to Customer OTP

Richmond / 

Newport 

News / 

Norfolk

66 Newport News-

Boston

√√√ Aligned to Customer OTP

Richmond / 

Newport 

News / 

Norfolk

67 Boston-Newport 

News

√√√ Aligned to Customer OTP

Richmond / 

Newport 

News / 

Norfolk

82 Richmond-Boston√√√ Aligned to Customer OTP

Richmond / 

Newport 

News / 

Norfolk

86 Richmond-Boston√√√√ Aligned to Customer OTP

Richmond / 

Newport 

News / 

Norfolk

95 Boston-Norfolk√√√ Aligned to Customer OTP

Richmond / 

Newport 

96 Newport News-

Boston

√√√ Aligned to Customer OTP
News / 

Norfolk

Richmond / 

Newport 

News / 

Norfolk

174 Newport News-

Boston

√√√ Aligned to Customer OTP

Richmond / 

Newport 

News / 

Norfolk

194 Newport News-

Boston

√√√ Aligned to Customer OTP

Roanoke 171 Boston-Roanoke√√√√ Aligned to Customer OTP

Roanoke 176 Roanoke-Boston√√ Aligned to Customer OTP

Vermonter 54 Washington DC-St. 

Albans

√√√ Aligned to Customer OTP

Vermonter 55 Washington DC-St. 

Albans

√√√√ Aligned to Customer OTP

Vermonter 56 Washington DC-St. 

Albans

√√√ Aligned to Customer OTP

Vermonter 57 Washington DC-St. 

Albans

√√√√ Aligned to Customer OTP
Page 1 of 2

Exhibit B

Metro-North Commuter Railroad Company’s (“Metro-North”) position on the disagreedupon components of Amtrak’s train schedules.

Metro-North, a New York State public benefit corporation and subsidiary of the Metropolitan 

Transportation Authority (“MTA”), operates the second-busiest commuter railroad in the country. 

Pre-COVID, Metro-North operated 713 weekday revenue trains carrying an average of 289,000 

weekday riders. Pursuant to certain Trackage Rights Agreements between Metro-North and 

Amtrak, Amtrak operates over Metro-North’s New Haven and Hudson Lines (Metro-North’s 

“territory”). Amtrak enters Metro-North’s New Haven Line territory in New Haven, CT and leaves 

the New Haven Line in New Rochelle, NY, continuing on to Penn Station in midtown Manhattan. 

Amtrak enters Metro-North’s Hudson Line territory in Poughkeepsie, NY and exits near Riverdale 

in the Bronx, NY, again continuing on to Penn Station. 

The Metrics and Minimum Standards for Intercity Passenger Rail Service, 49 C.F.R. Part 273, 

published by the Federal Railroad Administration (“FRA”) on November 16, 2020 (the “Final 

Rule”) defines a “certified schedule” as a published train schedule for Amtrak trains 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. To ensure Amtrak’s train schedules meet the 

Customer OTP metric and standard, Amtrak’s schedules must provide trains with sufficient

running time while in Metro-North’s territory. Amtrak’s trains traverse long distances; MetroNorth has no control over events outside of its territory and must account for such unknowns in its 

review and certification of Amtrak’s schedules. As such, the “host running time” metric, also 

established by the Final Rule, which compares a train’s actual running time with the scheduled 

running time between the first and final reporting points for a host railroad, is important and must 

be accurately calculated prior to certification to demonstrate the schedule adjustments necessary 

for Amtrak trains to have enough time to traverse Metro-North’s territory and successfully meet 

the Customer OTP metric and standard. 

Almost all of the schedules Amtrak has asked Metro-North to certify were set prior to the COVID19 pandemic, and several of these pre-COVID trains have not been operating through the 

pandemic. Additionally, many schedules Amtrak has requested Metro-North to certify have not 

been provided by Amtrak to Metro-North for review. It remains Metro-North’s position that 

certifying schedules (1) for Amtrak trains that have not been operating for over a year and/or (2) 

have not been reviewed or adjusted to account for pre- and post-COVID-19 realities and ridership 

changes is premature. Therefore, Metro-North will not certify train schedules that are not 

currently running and have no projected effective date. A schedule can only be certified when 

the parties are fully aware of the conditions the train will be operating in, which may change. 

Similarly, any future adjustments Amtrak seeks to make to previously certified schedules may 

invalidate Metro-North’s certifications and require re-review and re-certification. 

Metro-North is continuing to use the framework outlined below to analyze Amtrak’s schedules to 

determine whether the Amtrak schedules meet the Customer OTP metric and standard and can be 

certified. Amtrak and Metro-North agreed to certify twenty (20) train schedules effective with an 

Amtrak schedule change on August 30, 2021. 
Page 2 of 2

1. Does the Amtrak train currently operate? Due to COVID-19, in Spring 2020 Amtrak 

reduced the number of trains operating on Metro-North’s territory. Amtrak has returned a few 

trains to service, but many pre-COVID trains remain suspended. Metro-North is unaware of 

Amtrak’s plans to resume suspended services.

2. Does Metro-North have a schedule for this Amtrak train? Train schedules provided to 

Metro-North of currently operating trains since May 2020 and proposed for July 2021 service 

restoration have been reviewed for certification. Train schedules not provided to Metro-North or 

that have been suspended since May 2020 were not analyzed for certification as Metro-North has 

no schedule to reference.

3. What actions has Metro-North taken? Metro-North has either analyzed schedules that 

Amtrak has provided to determine whether they can be certified, or Metro-North is awaiting a 

schedule proposal from Amtrak to review for certification.

4. What is the definition of Metro-North’s calculated running time for Amtrak trains on 

Metro-North territory? This is Metro-North’s calculated schedule of pure running time, station 

stops, acceleration, braking, diverting movements and recovery time for Amtrak trains on MetroNorth territory in order for the schedule to be reliable and certifiable.

5. What is the definition of Amtrak’s current running time? This is the current Amtrak 

schedule for the Amtrak train on Metro-North’s territory.

6. What is the definition of running-time deficiency? This is the delta between Metro-North’s

calculated running times and the current Amtrak schedule.

The attached Table 1 lists each Amtrak train that Metro-North has not certified to date based on 

the framework and analysis identified above. The columns for Table 1 conform to the above steps.

Metro-North remains committed to working with Amtrak to certify its schedules and ensure its 

customers have the best possible ridership experience and looks forward to continuing to work 

with Amtrak to resolve these differences.

Very truly yours,

Justin R. Vonashek

Senior Vice President – Operations 

Metro-North Commuter Railroad Company
Train

(1) Train is Currently 

Operating as of May 

2021

(2) Schedule Provided to 

Metro-North between 

May 2020 and May 2021

(3) Metro-North Action 

Taken

(4) MNR-Calculated 

Running Time (Minutes)

(5) Current Amtrak 

Running Time (Minutes)

(6) Running Time 

Deficiency

2150 Yes Yes Review for Certification 73 70 3

2151 No No Waiting for Schedule

2154 Yes Yes Review for Certification 75 68 7

2155 Yes Yes Review for Certification 73 68 5

2159 Yes Yes Review for Certification 73 69 4

2160 No No Waiting for Schedule

2163 Yes Yes Review for Certification 73 70 3

2164 No No Waiting for Schedule

2165 No No Waiting for Schedule

2167 No Yes Waiting for Schedule

2168 No Yes Waiting for Schedule

2171 No No Waiting for Schedule

2175 No No Waiting for Schedule

2190 No No Waiting for Schedule

2253 Yes Yes Review for Certification 75 72 3

2254 Yes Yes Review for Certification 73 70 3

2255 Yes Yes Review for Certification 73 70 3

2256 Yes Yes Review for Certification 73 67 6

2258 No No Waiting for Schedule

2259 Yes Yes Review for Certification 75 71 4

2260 No No Waiting for Schedule

2261 No Yes Waiting for Schedule

2275 No No Waiting for Schedule

2290 No No Waiting for Schedule

68 No No Waiting for Schedule

69 No No Waiting for Schedule

290 Yes Yes Review for Certification 75 70 5

291 Yes Yes Review for Certification 75 70 5

292 Yes Yes Review for Certification 75 70 5
Train

(1) Train is Currently 

Operating as of May 

2021

(2) Schedule Provided to 

Metro-North between 

May 2020 and May 2021

(3) Metro-North Action 

Taken

(4) MNR-Calculated 

Running Time (Minutes)

(5) Current Amtrak 

Running Time (Minutes)

(6) Running Time 

Deficiency

293 No No Waiting for Schedule

295 No No Waiting for Schedule

296 No No Waiting for Schedule

63 Yes Yes Review for Certification 75 70 5

64 Yes Yes Review for Certification 75 71 4

230 No No Waiting for Schedule

232 Yes Yes Review for Certification 73 70 3

233 Yes Yes Review for Certification 75 70 5

234 Yes Yes Review for Certification 73 68 5

235 No No Waiting for Schedule

236 Yes Yes Review for Certification 75 70 5

237 Yes Yes Review for Certification 73 67 6

238 Yes Yes Review for Certification 75 70 5

241 Yes Yes Review for Certification 75 70 5

242 No No Waiting for Schedule

243 Yes Yes Review for Certification 75 70 5

244 Yes Yes Review for Certification 73 68 5

245 No No Waiting for Schedule

250 Yes Yes Review for Certification 75 70 5

252 No No Waiting for Schedule

253 Yes Yes Review for Certification 75 70 5

254 No No Waiting for Schedule

255 No No Waiting for Schedule

256 No No Waiting for Schedule

259 Yes Yes Review for Certification 75 70 5

260 Yes Yes Review for Certification 75 70 5

261 No No Waiting for Schedule

280 Yes Yes Review for Certification 73 68 5

281 Yes Yes Review for Certification 73 68 5

283 Yes Yes Review for Certification 75 70 5

284 Yes Yes Review for Certification 75 70 5

288 No No Waiting for Schedule

132 No No Waiting for Schedule

137 Yes Yes Review for Certification 79 71 8

140 Yes Yes Review for Certification 79 75 4
Train

(1) Train is Currently 

Operating as of May 

2021

(2) Schedule Provided to 

Metro-North between 

May 2020 and May 2021

(3) Metro-North Action 

Taken

(4) MNR-Calculated 

Running Time (Minutes)

(5) Current Amtrak 

Running Time (Minutes)

(6) Running Time 

Deficiency

141 Yes Yes Review for Certification 79 75 4

146 Yes Yes Review for Certification 77 73 4

148 Yes Yes Review for Certification 79 76 3

149 No Yes Waiting for Schedule

150 Yes Yes Review for Certification 79 74 5

163 No Yes Waiting for Schedule

167 Yes Yes Review for Certification 79 74 5

168 Yes Yes Review for Certification 79 76 3

177 Yes Yes Review for Certification 79 75 4

178 Yes Yes Review for Certification 79 76 3

179 No Yes Waiting for Schedule

65 Yes Yes Review for Certification 79 72 7

66 Yes Yes Review for Certification 79 76 3

67 Yes Yes Review for Certification 79 72 7

82 No Yes Waiting for Schedule

86 No No Waiting for Schedule

95 Yes Yes Review for Certification 75 70 5

96 Yes Yes Review for Certification 79 74 5

174 Yes Yes Review for Certification 79 76 3

194 Yes Yes Review for Certification 79 76 3

171 Yes Yes Review for Certification 77 74 3

176 Yes Yes Review for Certification 79 76 3

54 No Yes Waiting for Schedule

55 No Yes Waiting for Schedule

56 No Yes Waiting for Schedule

57 No Yes Waiting for Schedule
September 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 

August 31, 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

September 1, 2021

Page 2

SCRRA has advised that they will reply to Amtrak regarding certification once they have completed their 

review which is currently focused on schedule changes that will go into effect in October. Amtrak and 

SCRRA 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 Bennett, 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 Pete Buttigieg

September 1, 2021

Page 3 

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

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

 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 Mike Garcia, U.S. House of Representatives

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

The Honorable Jesús García, 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 Pete Buttigieg

September 1, 2021

Page 4 

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

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

 The Honorable Raúl 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 Mark Kelly, U.S. Senate 

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

 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 Pete Buttigieg

September 1, 2021

Page 5 

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

 The Honorable Alex Padilla, U.S. Senate 

 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 Lauren Underwood, U.S. House of Representatives 

 The Honorable Juan Vargas, 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, applying four criteria to determine whether the schedule was aligned to the customer OTP 

metric1

. 

Table 1 lists each uncertified train schedule by service and notes which dimensional 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

1 The four analytic criteria applied to each schedule were: (i) 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, (ii) if a train has regularly exceeded the minimum standard 80% customer OTP, 

(iii) If a regression, measuring the relationship between the placement of recovery time in the schedule and the 

number of detraining riders at each station resulted in a strong (0.5 or more) correlation, or (iv) if the recovery 

time is placed in advance of detraining passengers to help them arrive on-time. If a train schedule met any of 

these four criteria, the schedule was determined to be aligned with the customer OTP metric. 95% of the trains 

met more than one criterion. 
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