Federal Railroad Administration

Report to Congress

Railroads’ Progress Toward Implementation of 

Positive Train Control Systems

July 1, 2018 
1

I. Introduction 

Pursuant to Title 49 United States Code (U.S.C.) § 20157(d), the United States Department of 

Transportation (DOT) and the Federal Railroad Administration (FRA) are providing this report

to the U.S. House of Representatives Committee on Transportation and Infrastructure and the 

U.S. Senate Committee on Commerce, Science, and Transportation on each railroad’s progress 

toward implementing a positive train control (PTC) system. The purpose of this report is to 

advise Congress, the public, railroads, and other industry stakeholders about:

(1) The statutory deadlines and requirements for full PTC system implementation, including 

the statutory criteria that railroads subject to the congressional mandate must meet by 

December 31, 2018;

(2) A summary of the recent actions FRA has taken to support railroads’ implementation of 

PTC systems and ensure compliance with the statutory requirements; 

(3) Each railroad’s progress toward implementing a PTC system, including information 

regarding the twelve railroads most at risk, as of March 31, 2018, of not meeting either 

the December 31, 2018, deadline, or the statutory criteria necessary to qualify for an 

alternative schedule under 49 U.S.C. § 20157(a)(3); and 

(4) A summary of railroads’ self-reported challenges and risks to fully implementing PTC 

systems in accordance with the statutory mandate. 

DOT and FRA are encouraged that railroads have made significant progress toward 

implementing highly complex PTC systems, which will further enhance the safety of rail 

transportation throughout the country. As of March 31, 2018, FRA-certified PTC systems were 

being operated in revenue service on over 33,000 route miles of the approximately 60,000 route 

miles subject to the mandate, which exhibits progress by the railroad industry in implementing 

this safety-enhancing technology. 

The key statistics and infographics in this report are based on self-reported data railroads have 

provided to FRA in their Quarterly PTC Progress Reports (Form FRA F 6180.165) for Quarter 1 

of 2018 and railroads’ 2017 Annual PTC Progress Reports (Form FRA F 6180.166).1 Unless 

otherwise noted, the data in this report is current as of March 31, 2018. The primary data 

presented illustrates the overall status of industry-wide PTC system implementation, each 

railroad’s progress with respect to meeting the statutory criteria required to qualify for an 

alternative schedule, if necessary, by December 31, 2018, common challenges that railroads 

continue to experience, and each railroad’s status toward full PTC system implementation.

Railroads are primarily implementing the following PTC systems in the United States: (1) the 

Interoperable Electronic Train Management System (I-ETMS), which is the predominant system 

being implemented by Class I railroads; (2) the Advanced Civil Speed Enforcement System II 

(ACSES II), which is being implemented by most railroads operating on the Northeast Corridor; 

(3) Enhanced Automatic Train Control (E-ATC), which is being implemented by six intercity 

passenger or commuter railroads; and (4) the Incremental Train Control System (ITCS), which is 

being implemented by Amtrak in parts of Michigan. 

 

1 See Office of Management and Budget (OMB) Control No. 2130-0553.
2

II. Summary of the Statutory Deadlines and Requirements for 

PTC System Implementation 

A. Background 

As the Rail Safety Improvement Act of 2008 first mandated, each Class I railroad and each entity 

providing regularly scheduled intercity or commuter rail passenger transportation must 

implement an FRA-certified PTC system on: (1) its main line over which 5 million or more gross 

tons of annual traffic and poison- or toxic-by-inhalation hazardous materials are transported; (2) 

its main line over which intercity or commuter rail passenger transportation is regularly 

provided; and (3) any other tracks the Secretary of Transportation prescribes by regulation or 

order.

2

 

Under 49 U.S.C. § 20157 and FRA’s implementing regulations, a PTC system must be designed 

to prevent train-to-train collisions, over-speed derailments, incursions into established work 

zones, and movements of trains through switches left in the wrong position, in accordance with 

the technical specifications under 49 CFR part 236, subpart I.3

B. The December 31, 2018, Deadline and the Requirements for Compliance

On October 29, 2015, the Positive Train Control Enforcement and Implementation Act of 2015 

(PTCEI Act) extended the original statutory deadline for full implementation of PTC systems 

from December 31, 2015, to December 31, 2018.4 

FRA interprets “complete”5or “full”6implementation of a PTC system to mean that an FRAcertified and interoperable PTC system—including all hardware, software, and other 

components—has been fully installed, sufficiently tested, and is in operation on all route miles 

required to have operations governed by a PTC system under 49 U.S.C. § 20157.7 Full 

implementation requires that all controlling locomotives shall be equipped with a fully operative 

and functioning onboard PTC apparatus, including the controlling locomotives of each railroad 

subject to the statutory mandate and each tenant railroad operating on a PTC-equipped track 

 

2 Rail Safety Improvement Act of 2008, Pub. L. No. 110-432, § 104(a), 122 Stat. 4848 (Oct. 16, 2008), as amended 

by the Positive Train Control Enforcement and Implementation Act of 2015, Pub. L. No. 114-73, 129 Stat. 568, 

576–82 (Oct. 29, 2015) and the Fixing America’s Surface Transportation Act, Pub. L. No. 114-94, § 11315(d), 129 

Stat. 1312, 1675 (Dec. 4, 2015) (codified as amended at 49 U.S.C. § 20157). See Title 49 Code of Federal 

Regulations (CFR) part 236, subpart I (Positive Train Control Systems). 

3 See, e.g., 49 U.S.C. § 20157(g)(1), (i)(5); 49 CFR § 236.1005.

4 49 U.S.C. § 20157(a). Please note that the PTCEI Act also required FRA to extend each deadline under 49 CFR 

§ 236.1006(b)(4)(iii)(B) by three years, related to equipping certain Class II and Class III railroads’ locomotives that 

operate in PTC territory. See 49 U.S.C. § 20157(k); 81 Fed. Reg. 10126 (Feb. 29, 2016).

5 See, e.g., 49 U.S.C. § 20157(c)(1); 49 CFR § 236.1005(b)(7). 

6 See, e.g., 49 U.S.C. § 20157(a)(3)(B)(v); 49 CFR § 236.1005(b)(7); 79 Fed. Reg. 49693, 49706 (Aug. 22, 2014).

7 See, e.g., 49 U.S.C. § 20157(a)(1)–(3), (e)–(h), (i)(3); 49 CFR part 236, subpart I. The PTCEI Act, however, 

recognizes that certain PTC system failures (e.g., initialization failures, cut outs, and malfunctions) will occur during 

the period specified in the statute, but a railroad must both operate at an equivalent or greater level of safety than the 

level of safety achieved immediately prior to the use or implementation of the PTC system and comply with certain 

safety measures during any PTC system failures. See 49 U.S.C. § 20157(j).
3

segment, except for a railroad’s controlling locomotives that qualify for an exception under 49 

CFR § 236.1006. The statutory mandate and FRA’s implementing regulations require a PTC 

system to be interoperable, meaning the locomotives of any host railroad and tenant railroad 

operating on the same main line will communicate with and respond to the PTC system, 

including uninterrupted movements over property boundaries.8

The PTCEI Act authorizes the Secretary of Transportation, and FRA by delegation, to approve a 

railroad’s “alternative schedule and sequence” with a full implementation deadline beyond 

December 31, 2018, to complete certain non-hardware, operational aspects of PTC system

implementation.

9 A railroad’s alternative schedule, if any, must contain a deadline that is as 

soon as practicable, but no later than December 31, 2020.10 To request FRA’s approval of a 

railroad’s alternative schedule to complete testing, certification, interoperability, and full 

implementation beyond December 31, 2018, a railroad must submit a written notification to FRA

when it has met the statutory criteria necessary to qualify for an alternative schedule and is 

prepared for FRA’s review and approval.11

To obtain FRA’s approval of an alternative schedule, a railroad’s written notification must 

demonstrate, to FRA’s satisfaction, that the railroad has met each of the statutorily-required 

criteria. The statutory criteria include: the installation of all PTC system hardware consistent 

with the railroad’s PTC Implementation Plan; the acquisition of all spectrum consistent with the 

railroad’s PTC Implementation Plan; and sufficient progress on employee training and advanced 

testing and/or implementation.

12

 In its written notification, a railroad must also certify that the 

railroad will be in full compliance with all requirements of the statutory mandate on or before the 

deadline provided in its alternative schedule and demonstrate that it has included its proposed 

alternative schedule in its PTC Implementation Plan.

13

 Table 1 below describes each of these 

criteria in more detail.

Criteria Specific Progress Railroads Must Make to Qualify for an 

Alternative Schedule Under 49 U.S.C. § 20157(a)(3)

Hardware Installed, by December 31, 2018, all PTC system hardware that will be 

installed for PTC system implementation, consistent with the railroad’s 

governing PTC Implementation Plan.

Spectrum Acquired, by December 31, 2018, all spectrum necessary for 

implementation of the railroad’s PTC system, consistent with the 

railroad’s governing PTC Implementation Plan.

Employee Training Completed the employee training required under 49 CFR part 236,

subpart I for all applicable personnel in any territory, or segment 

thereof, where the PTC system is currently being operated in revenue 

service demonstration (RSD) or revenue service.

Advanced Testing 

and/or 

For Class I railroads and Amtrak, the railroad has implemented a PTC 

system or initiated RSD on the majority of territories (e.g., subdivisions 

 

8 See 49 U.S.C. § 20157(a)(2)(A)(i)(I), (a)(2)(D), (i)(3); 49 CFR §§ 236.1003, 236.1011(a)(3).

9 49 U.S.C. § 20157(a)(3)(A)–(D); 49 CFR § 1.89. 

10 49 U.S.C. § 20157(a)(3)(B)–(D).

11 49 U.S.C. § 20157(a)(3)(A)–(B).

12 49 U.S.C. § 20157(a)(3)(B)(i)–(iii), (vi)–(vii).

13 49 U.S.C. § 20157(a)(3)(B)(iv)–(v).
4

Implementation or districts) or route miles the railroad owns or controls that are required 

to have operations governed by a PTC system.

For railroads other than Class I railroads or Amtrak, the railroad has 

initiated RSD on at least one territory that is required to have operations 

governed by a PTC system, or met any other criteria established by 

FRA.

Schedule and 

Sequence

Included in the PTC Implementation Plan an alternative schedule and 

sequence for implementing a PTC system as soon as practicable, but no 

later than December 31, 2020.

Certification Certified to FRA in writing that the railroad will be in full compliance 

with the requirements of 49 U.S.C. § 20157 on or before the deadline in 

the proposed alternative schedule and sequence. 

Table 1 - Statutory Criteria for FRA Approval of Alternative Schedule and Sequence.

The PTCEI Act requires FRA to approve a railroad’s alternative schedule if a railroad submits a 

written request to FRA that demonstrates the railroad has met the statutory criteria for an 

alternative schedule under 49 U.S.C. § 20157(a)(3)(B).14 

Based on FRA’s review of the Annual PTC Progress Reports and Quarterly PTC Progress 

Reports railroads have submitted to date, it is likely that most railroads subject to the statutory 

mandate will need to request and obtain FRA’s approval of an alternative schedule with a 

deadline beyond December 31, 2018, in order to continue testing, obtaining PTC System 

Certification, achieving interoperability, and fully implementing PTC systems. 

Some railroads, most notably BNSF Railway (BNSF), the Southern California Regional Rail 

Authority (Metrolink), the Southeastern Pennsylvania Transportation Authority (SEPTA), and 

Union Pacific Railroad (UP), will likely have an FRA-certified PTC system in operation on their 

own locomotives on all route miles required under 49 U.S.C. § 20157, on or before December 

31, 2018. However, it is unlikely that all controlling locomotives of tenant railroads operating on 

these PTC-equipped railroad properties will be capable of operating with the host railroad’s PTC 

system by that date.

Accordingly, this report provides high-level information—current as of March 31, 2018—about 

each railroad’s progress toward meeting the statutory criteria required to qualify for an 

alternative schedule, based on the data railroads most recently reported in their Quarterly PTC 

Progress Reports (Form FRA F 6180.165) for Quarter 1 of 2018. 

III. FRA’s Recent Oversight Actions 

A. Overall Approach 

 

14 See 49 U.S.C. § 20157(a)(3)(A)–(D); 49 CFR § 1.89.
5

FRA continues to actively monitor Class I railroads’ and intercity passenger and commuter 

railroads’ incremental implementation of PTC systems and to provide guidance and outreach to 

railroads and other critical stakeholders, including state and local governments, associations 

representing railroads, and PTC system suppliers and vendors. On December 27, 2017, one year 

ahead of the deadline for PTC system implementation, Secretary Elaine L. Chao issued a letter to 

all Class I railroads, intercity passenger railroads, and commuter railroads, stressing the urgency 

and importance of safely implementing PTC systems in the upcoming year and meeting the 

statutory deadline. Given railroads’ progress as of this spring, and the limited time remaining to 

implement PTC systems by December 31, 2018, FRA considers railroads’ completion of the 

statutory requirements for an alternative schedule the most critical compliance matter between 

now and December 31, 2018.

Since December 2017, FRA leadership has continued to meet with the executive leadership and 

technical teams of each railroad subject to the statutory mandate to help ensure PTC systems are 

being implemented as efficiently as possible, discuss any challenges the railroads continue to 

experience, and review the railroads’ plans for compliance with the statutory mandate. FRA also 

continues to meet in person with key industry suppliers as well as associations representing 

railroads, and has helped create and support multiple industry forums dedicated to improving 

collaboration among all PTC stakeholders, including technical user groups for each of the three 

primary PTC systems being implemented. FRA will host three symposia throughout the summer 

of 2018 to proactively provide information and guidance on critical issues pertinent to the 

statutory 2018 requirements and successful implementation of PTC systems.15

B. FRA’s Oversight Actions from 2017 to Present

To ensure railroads and key stakeholders understand the statutory requirements to qualify for an 

alternative schedule beyond December 31, 2018, if necessary, and provide early warning to 

railroads that might be at risk of not meeting the necessary statutory criteria to qualify, FRA 

proactively began an outreach initiative last year that includes the following elements:

• Letters in May 2017 to the 17 railroads16 that, as of December 31, 2016, FRA considered 

at risk of neither meeting the December 31, 2018, deadline nor meeting the statutory 

 

15 The first symposium was held on June 15, 2018, to systematically communicate information to all railroads 

subject to the statutory mandate regarding compliance with the December 31, 2018, deadline and, if necessary, the 

process to qualify for and obtain FRA’s approval of an alternative schedule. FRA will hold a second symposium on 

July 16, 2018, to discuss best practices for PTC system field testing and interoperability testing. The third 

symposium, on August 20, 2018, will cover lessons learned and best practices for PTC Safety Plans, which are 

necessary for host railroads to obtain PTC System Certification from FRA and to achieve full PTC system 

implementation under the statutory mandate. 

16 The 17 recipients of letters about lack of hardware installation progress as of December 31, 2016, were: Altamont 

Corridor Express; Belt Railway Company of Chicago; Canadian National Railway; Capital Metropolitan 

Transportation Authority; Central Florida Rail Corridor; Denton County Transportation Authority; Long Island Rail 

Road; Maryland Area Regional Commuter; Massachusetts Bay Transportation Authority; Metro-North Commuter 

Railroad; Nashville Regional Transportation Authority (RTA) / Nashville and Eastern Railroad (NERR); New 

Jersey Transit; New Mexico Rail Runner Express; Northern Indiana Commuter Transportation District; South 

Florida Regional Transportation Authority; Trinity Railway Express; and Terminal Railroad Association of St. 

Louis. Please note, that on March 28, 2018, FRA conditionally approved NERR’s request for a regulatory main line 

track exception under 49 CFR § 236.1019(c)(2)(ii). The exception applies to the approximately 32 miles on which 
6

criteria required to qualify for an alternative schedule, specifically because self-reported 

data indicated that each railroad had installed less than 50% of its PTC system hardware 

as of December 31, 2016;

• Letters in June 2017 to governors and state departments of transportation (state DOTs)

17

regarding any commuter railroad in the state that had installed less than 50% of its PTC 

system hardware as of December 31, 2016;

• Initiation of enforcement actions in June and July 2017 against 14 railroads that either 

failed to complete the end-of-2016 hardware installation milestones that the railroad 

established in its PTC Implementation Plan or failed to submit a timely Annual PTC 

Progress Report to FRA by the statutory March 31, 2017, deadline, as described below in 

Section III(D);

• A December 27, 2017, letter from Secretary Elaine L. Chao to all Class I railroads, 

intercity passenger railroads, and commuter railroads, in response to the December 18, 

2017, Amtrak 501 accident, stressing the urgency and importance of safely implementing 

PTC systems during the upcoming year and meeting the statutory deadline; 

• Meetings during the first six weeks of 2018 with the executive leadership and technical 

teams from each of the 41 railroads subject to the statutory mandate to discuss the 

importance of timely PTC system implementation, ongoing challenges that railroads are 

experiencing, and each railroad’s precise plans for compliance with the statutory 

mandate;

• Letters on March 14, 2018, to each of the major PTC system suppliers and vendors, 

emphasizing the critical role they play in ensuring that railroads implement PTC systems 

in a timely manner and inviting each supplier and vendor to meet with FRA leadership in 

Washington, DC;

• Meetings from March 23 to May 8, 2018, with the ten major PTC system suppliers and 

vendors to discuss which railroads the supplier or vendor is providing PTC system 

products or components and/or any related services, and the suppliers’ and vendors’ plans 

to expedite delivery of PTC system products, components, and other services;

• Letters on April 24, 2018, to 15 railroads18 that FRA considered at risk of not meeting the 

statutory criteria to qualify for an alternative schedule, specifically because self-reported 

data from 15 railroads indicated that each railroad had installed less than 80% of its PTC 

system hardware as of December 31, 2017;

• At least monthly PTC system implementation meetings with Amtrak executive staff since 

February 2018;

• Continued industry engagement—for example, on May 1, 2018, FRA presented at the 

Surface Transportation Board’s Railroad-Shipper Transportation Advisory Council about 

 

RTA provides Music City Star commuter rail service. The track segment is signaled, using a centralized traffic 

control system, and NERR noted it maintains temporal separation by operating freight trains only when commuter 

service is not operating. 

17 For example, FRA sent letters to the state DOTs and state governors of California, Florida, Indiana, Maryland, 

Massachusetts, New Jersey, New Mexico, New York, Tennessee, and Texas.

18 The 15 recipients of at-risk letters based on hardware installation progress as of December 31, 2017, were: 

Altamont Corridor Express; Belt Railway Company of Chicago; Capital Metropolitan Transportation Authority; 

Central Florida Rail Corridor; Consolidated Rail Corporation; Florida East Coast Railway; Maryland Area Regional 

Commuter; Massachusetts Bay Transportation Authority; Metro-North Commuter Railroad; New Jersey Transit; 

New Mexico Rail Runner Express; Northern Indiana Commuter Transportation District; Peninsula Corridor Joint 

Powers Board (Caltrain); South Florida Regional Transportation Authority; and Trinity Railway Express. 
7

the status of the industry’s implementation of PTC systems. On May 2 and May 10, 

2018, respectively, FRA career staff met with the American Public Transportation 

Association (APTA) and its member railroads and the Association of American Railroads

(AAR) and its member railroads to discuss and answer industry questions. On May 21, 

2018, FRA supported a PTC seminar with over 250 attendees sponsored by the Railway 

Systems Suppliers, Inc.;

• Continued participation in industry stakeholder meetings, including AAR’s ACSES II 

Working Group, APTA’s I-ETMS Working Group for commuter railroads, the railroadled E-ATC Working Group, and other meetings designed to bring together railroads, 

vendors, and suppliers with common PTC systems to discuss ongoing technical issues 

and lessons learned;

• Letters on June 1, 2018, to twelve railroads19 that FRA remains concerned are at risk of 

not meeting the statutory criteria to qualify for an alternative schedule, specifically 

because self-reported data from twelve railroads indicated that each railroad had installed 

less than 85% of its PTC system hardware as of March 31, 2018;

• From May 30 to June 1, 2018, FRA met with each of the twelve at-risk railroads to 

review the steps each railroad is taking to ensure it complies with the statutory mandate, 

to discuss its implementation progress during recent months, and to offer these railroads 

as much technical assistance as possible during this important time;

• Letters on June 1, 2018, to the governors and state DOTs of California, Florida, Indiana, 

Maryland, Massachusetts, New Jersey, New Mexico, and Texas, regarding any commuter 

railroad in the state that had installed less than 85% of its PTC system hardware as of 

March 31, 2018. FRA emphasized the importance of the state government ensuring these 

railroads have proper technical support and sufficient oversight of PTC system 

implementation;

• Ongoing quarterly meetings with at-risk railroads and regular engagement throughout the 

year; and

• FRA’s first-ever PTC symposium on June 15, 2018, to systematically communicate 

information to all railroads subject to the statutory mandate regarding compliance with 

the December 31, 2018, deadline and, if necessary, the process to qualify for and obtain 

FRA’s approval of an alternative schedule.

In addition, FRA continues to provide frequent technical assistance directly to railroads

throughout all phases of PTC system development, installation, field testing, revenue service 

demonstration, and implementation by providing lessons learned guidance and other technical 

advice to help railroads resolve issues during each phase. Moreover, in support of PTC Research 

and Development, FRA has provided technical support for railroads’ development of their PTC 

systems, including I-ETMS, ACSES II, E-ATC, and the Interoperable Incremental Train Control 

System (I-ITCS). For example, FRA has supported the continued operation of the PTC test bed 

at the Transportation Technology Center, Inc. in Pueblo, Colorado. In cooperation with 

 

19 The twelve recipients of at-risk letters based on hardware installation progress as of March 31, 2018, were: 

Altamont Corridor Express; Belt Railway Company of Chicago; Capital Metropolitan Transportation Authority; 

Central Florida Rail Corridor; Maryland Area Regional Commuter; Massachusetts Bay Transportation Authority; 

New Jersey Transit; New Mexico Rail Runner Express; Northern Indiana Commuter Transportation District; 

Peninsula Corridor Joint Powers Board (Caltrain); South Florida Regional Transportation Authority; and Trinity 

Railway Express. 
8

individual railroads, as well as APTA, AAR, and the American Short Line and Regional 

Railroad Association (ASLRRA) committees, FRA is also supporting approximately ten PTCrelated research projects.

C. Grant Funding and Financial Assistance

The safety enhancements of PTC systems come with significant costs, both in terms of initial 

implementation costs and increased operations and maintenance costs. Industry estimates initial 

implementation costs will exceed $14 billion, and multiple railroads have estimated that ongoing 

operations and maintenance costs will be approximately 15 to 20 percent of annual capital 

costs.20 Since 2009, FRA has awarded approximately $735 million in grant funding to support 

railroads’ implementation of PTC systems. FRA also supported the Federal Transit 

Administration (FTA) with its evaluation and selection of approximately $197 million in grant 

fund awards to 17 commuter and intercity passenger railroads and state and local governments 

for installation of PTC systems, which were announced on May 31, 2017. The sources of the 

approximately $932 million in FRA and FTA grant funding are: 

• $475 million from FRA’s High-Speed Intercity Passenger Rail Grant Program; 

• $197 million in Fixing America’s Surface Transportation Act (FAST Act) funding;

• $120 million in annual capital grant funding to Amtrak (as of March 2018); 

• $86 million from FRA’s Railroad Safety Technology Grant Program; 

• $52 million in American Recovery and Reinvestment Act grant funding to Amtrak; and

• $2 million in Research and Development grants.

Additionally, in May 2015, FRA issued a $967.1-million Railroad Rehabilitation and 

Improvement Financing (RRIF) loan to the Metropolitan Transportation Authority for Long 

Island Rail Road’s and Metro-North Railroad’s implementation of PTC systems. On December 

8, 2017, DOT’s Build America Bureau closed a $162 million Transportation and Infrastructure 

Finance and Innovation Act (TIFIA) loan and a $220 million RRIF loan to be issued to the 

Massachusetts Bay Transportation Authority for PTC system implementation.21

Furthermore, the FAST Act authorized three new competitive rail development grant 

programs—i.e., two capital grant programs and one operating grant program: Consolidated Rail 

Infrastructure and Safety Improvements (CRISI), Federal-State Partnership for the State of Good 

Repair, and Restoration and Enhancement. For Fiscal Years 2017 and 2018, Congress 

appropriated an additional $961 million in funding with an emphasis on assisting with PTC 

system implementation. 

 

20 In a March 2017 report, AAR estimated that it will cost freight railroads “. . . hundreds of millions of additional 

dollars . . . each year after [PTC system implementation] to maintain” PTC systems. See AAR, Positive Train 

Control, at 2 (March 2017). APTA also stated in a February 21, 2017, press release that PTC system 

implementation is “expected to cost the commuter rail industry . . . $100 million annually in additional maintenance 

costs.” See APTA, Commuter Rail Industry Continues to Make Progress on Positive Train Control, (Feb. 21, 2017) 

http://www.apta.com/mediacenter/pressreleases/2017/Pages/PTC-Quarterly-Report.aspx.

21 Approximately $31 billion is currently available for lending under the RRIF program. Lending authority under 

the TIFIA program is approximately $22 billion; however, this figure is subject to available subsidy budget authority 

and the levels of risk associated with future loans.
9

• $661 million for CRISI for capital projects, regional and corridor planning, 

environmental analyses, research, workforce development, and training to improve the 

safety, efficiency, and reliability of passenger and freight rail systems, of which $250 

million is set aside for PTC system implementation;

• $275 million for Federal-State Partnership for State of Good Repair for capital projects 

on public- or Amtrak-owned infrastructure, equipment, and facilities to replace existing 

assets in-kind or with assets that increase capacity or service, maintain service while 

existing assets are brought into a state of good repair, or bring existing assets into a state 

of good repair; and

• $25 million for Restoration and Enhancement Grants for operating assistance for up to 

three years per route to initiate, restore, or enhance intercity passenger rail transportation. 

In the Consolidated Appropriations Act of 2018, Congress made commuter railroads eligible 

applicants for the $250 million set-aside in the CRISI program for PTC system implementation.22 

On May 18, 2018, FRA published a Notice of Funding Opportunity for the $250 million in Fiscal 

Year 2018 CRISI grant funding in the Federal Register, providing an expedited 45-day deadline 

for grant applications.23 To assist applicants with preparing grant applications, FRA participated 

in an APTA webinar on May 21 and an ASLRRA webinar on May 30, 2018, and hosted two 

webinars on June 4, 2018. FRA is working expeditiously to make available the remaining CRISI 

grant funding that Congress appropriated for Fiscal Year 2018 on March 23, 2018.

D. Compliance Reviews

The PTCEI Act requires FRA to conduct compliance reviews at least annually to ensure each 

railroad is implementing a PTC system in accordance with its Revised PTC Implementation Plan 

(PTCIP), including any FRA-approved amendments.24 FRA is authorized to assess civil 

penalties against any railroad that fails to complete the end-of-year implementation milestones 

the railroad established in its PTCIP, including the railroad’s end-of-2016 and end-of-2017 

milestones for PTC system hardware installation, spectrum acquisition (if necessary for the 

railroad’s PTC system), and employee training.25 FRA has effectively complied with this 

oversight mandate and has taken multiple steps to ensure railroads implement PTC systems in 

accordance with the interim deadlines in their Revised PTCIPs. 

For example, during calendar year 2017, FRA determined that 17 railroads each failed to 

complete one or more PTC system hardware installation milestones the railroad established for 

calendar year 2016 in its Revised PTCIP. In March 2017, FRA sent a letter to each of these 17 

non-complaint railroads,26 reminding each railroad that the PTCEI Act requires the railroad to 

 

22 See Pub. L. No. 115-141 (Mar. 23, 2018).

23 83 Fed. Reg. 23328 (May 18, 2018). 

24 49 U.S.C. § 20157(c)(2). 

25 49 U.S.C. § 20157(a)(2)(D), (e)(2). 

26 The following 17 railroads each failed to complete one or more end-of-2016 PTC system hardware installation 

milestones from its Revised PTCIP: Amtrak; Belt Railway Company of Chicago; BNSF Railway; Canadian 

National Railway; Canadian Pacific Railway; Capital Metropolitan Transportation Authority; CSX Transportation, 

Inc.; Kansas City Southern Railway; Maryland Area Regional Commuter; Nashville Regional Transportation 

Authority / Nashville and Eastern Railroad; New Jersey Transit; Norfolk Southern Railway; Northeast Illinois 
10

implement a PTC system in accordance with its Revised PTCIP and failure to do so is a 

punishable violation.27 

In June and July 2017, FRA initiated enforcement action against seven railroads that both (1) 

failed to complete one or more end-of-2016 PTC system hardware installation milestones from 

its Revised PTCIP, and (2) were at or below 33% done with full PTC system implementation as 

of December 31, 2016. FRA determined it was necessary to take enforcement action to propel 

these railroads to implement a PTC system in accordance with their own schedules.28 In 

addition, FRA believes that the assessment of a civil penalty against those railroads was 

necessary to urge them to expedite installation of PTC system hardware, which is integral to full 

implementation of a PTC system. FRA considers railroads’ failure to complete end-of-year 

hardware installation milestones particularly problematic because a railroad must install all PTC 

system hardware by December 31, 2018, to qualify for an alternative schedule under the PTCEI 

Act, among the other statutory criteria.

29

 Significant hardware installation is also necessary for a 

railroad to be able to initiate the required field testing of its PTC system, including revenue 

service demonstration.30 

In terms of other PTC enforcement action to date, in June and July 2017, FRA issued Notices of 

Probable Violation against seven other railroads that failed to submit a timely Annual PTC 

Progress Report (Form FRA F 6180.166, OMB Control No. 2130-0553) to FRA by the statutory 

March 31, 2017, deadline.31 All 14 railroads paid the civil penalties that FRA assessed for these 

violations of the statutory mandate and FRA’s implementing regulations. 

By mid-July 2018, FRA will issue Notices of Probable Violation, including a proposed civil 

penalty assessment, to 13 railroads that each failed to complete its end-of-2017 PTC system 

hardware installation milestones and/or spectrum acquisition milestones from its Revised PTCIP, 

including any FRA-approved amendments in effect on December 31, 2017.32 Consistent with 

FRA’s commitment to ensuring railroads comply with the statutory mandate, including interim 

requirements, FRA will propose the maximum civil penalty for this type of violation—i.e., a 

one-time civil penalty of $27,904—against any railroad that failed to complete its end-of-2017 

hardware installation milestones and/or spectrum acquisition milestones.33 

 

Regional Commuter Railroad (Metra); Northern Indiana Commuter Transportation District; Southern California 

Regional Rail Authority (Metrolink); Terminal Railroad Association of St. Louis; and Union Pacific Railroad.

27 49 U.S.C. § 20157(a)(2)(D), (e)(2).

28 FRA issued a Notice of Probable Violation and a civil penalty to the following seven railroads for the failure to 

complete one or more of its end-of-2016 PTC hardware installation milestones from its Revised PTCIP: Belt 

Railway Company of Chicago; Capital Metropolitan Transportation Authority; Maryland Area Regional Commuter; 

Nashville and Eastern Railroad; New Jersey Transit; Northern Indiana Commuter Transportation District; and 

Terminal Railroad Association of St. Louis.

29 49 U.S.C. § 20157(a)(3)(B)(i).

30 See 49 U.S.C. § 20157(a)(3)(B)(vi)–(vii); 49 CFR § 236.1035.

31 See 49 U.S.C. § 20157(c)(1), (e)(1); 49 CFR § 236.1009(a)(5). FRA issued a Notice of Probable Violation and a 

civil penalty to the following seven railroads for the failure to submit its Annual PTC Progress Report to FRA by the 

deadline: Amtrak; New Mexico Rail Runner Express; Northstar Commuter Rail; Regional Transportation District 

Commuter Rail (Denver RTDC); Sonoma-Marin Area Rail Transit; Sounder Commuter Rail; and Southeastern 

Pennsylvania Transportation Authority. 

32 49 U.S.C. § 20157(a)(2)(D), (e)(2).

33 See 82 Fed. Reg. 16127 (Apr. 3, 2017).
11

Finally, FRA is diligently reminding railroads that a railroad’s FRA-approved PTCIP on file on 

December 31, 2018, or at the time a railroad requests FRA’s approval of an alternative schedule, 

defines what milestones must be achieved for compliance, particularly with respect to the total 

quantities of PTC system hardware that must be installed for implementation of a PTC system.34

IV. Status of Railroads’ Implementation of PTC Systems

The infographics in this report and the appendix provide only an overview of railroads’ selfreported progress, based on their Quarterly PTC Progress Reports (Form FRA F 6180.165) for 

Quarter 1 of 2018 and 2017 Annual PTC Progress Reports (Form FRA F 6180.166). To view 

railroads’ full PTC progress reports, including further detail and narrative explanations of the 

reported progress, please download railroads’ reports from FRA’s website at: 

https://www.fra.dot.gov/Page/P0628.

A. FRA’s Conditional Certification of Railroads’ PTC Systems

Under the statutory mandate, a railroad must obtain PTC System Certification from FRA before 

it operates a PTC system, or a component thereof, in revenue service on the general rail system.35 

To date, based on FRA’s highly detailed, technical review of each railroad’s PTC Safety Plan 

(PTCSP), FRA has conditionally certified the following seven railroads’ I-ETMS systems as 

non-vital overlay PTC systems: BNSF, Canadian Pacific Railway, CSX Transportation, Inc.

(CSX), Kansas City Southern Railway, Norfolk Southern Railway (NS), Metrolink, and UP.

36

 In 

addition, FRA has conditionally certified Amtrak’s Advanced Civil Speed Enforcement System 

II (ACSES II) and SEPTA’s ACSES II as vital overlay PTC systems.37 Three other railroads, 

Portland and Western Railroad, North County Transit District, and Canadian National Railway, 

have submitted PTCSPs to FRA, which are currently under FRA review. 

On August 20, 2018, FRA will host a symposium to convene railroads to discuss lessons learned 

and best practices for railroads’ PTCSPs. Although submission of a PTCSP by December 31, 

2018, is not required by law to qualify for an alternative schedule, FRA’s approval of a host 

railroad’s PTCSP is necessary for a host railroad to obtain PTC System Certification from FRA 

and to achieve full PTC system implementation under the statutory mandate.

 

34 See 49 U.S.C. § 20157(a)(3)(B)(i)–(vii), (a)(3)(C)–(D). 

35 See 49 U.S.C. § 20157(h)(1). However, FRA may authorize a railroad to commence operation of a PTC system in 

revenue service, before the railroad obtains PTC System Certification, to the extent necessary to enable the safe 

implementation and operation of a PTC system in phases. See 49 U.S.C. § 20157(h)(2).

36 See 49 U.S.C. § 20157(h)(1). See also 49 CFR §§ 1.89, 236.1015.

37 Both non-vital and vital overlay systems must be designed to reliably prevent train-to-train collisions, over-speed 

derailments, incursions into established work zone limits, and movements through a main line switch in the 

improper position. A non-vital overlay system must obtain at least an 80-percent reduction of the risk associated 

with PTC-preventable accidents and maintain a level of safety for each subsequent system modification that is equal 

to or greater than the level of safety for the previous PTC system. See 49 CFR § 236.1015(e)(1). A vital overlay 

system must meet a higher threshold, as its PTCSP must include sufficient documentation to demonstrate that the 

PTC system, as built, fulfills the safety assurance principles set forth in Appendix C to 49 CFR part 236. See 49 

CFR § 236.1015(e)(2). Pursuant to Appendix C, a vital overlay PTC system must, for example, adhere to an 

intrinsic fail-safe design concept and must automatically assume a safe operating mode in the event of failure.
12

B. Railroads’ Progress Toward Full PTC System Implementation

At the onset of this Administration, PTC systems were in operation on approximately 18% of the 

freight railroads’ route miles required to be governed by a PTC system, which over the last year 

increased significantly to 60% as of March 31, 2018. Intercity passenger and commuter railroads

also made progress in this respect, albeit at a much slower rate—specifically, PTC systems were 

in operation on approximately 24% of the required route miles as of March 31, 2017, which

increased only to 25% as of March 31, 2018.

Figure 1 – Status of Overall Industry PTC System Implementation as of March 31, 2018.

As indicated in the statistics provided in Figure 1, the railroad industry continues to make 

significant progress toward full implementation of PTC systems, but considerable work remains 

to be done by intercity passenger and commuter railroads. Please see Appendix A to this report 

for specific railroad-by-railroad progress toward meeting several requirements for full 

implementation of PTC systems, including data regarding PTC-operable locomotives and track 

segments, employee training, spectrum acquisition and availability, PTC System Certification, 

route miles where PTC systems are in operation, and interoperability between host railroads and 

tenant railroads. 

In addition to granting nine host railroads conditional PTC System Certification and thereby 

authorizing each railroad to operate its PTC system in revenue service, FRA has conditionally 

approved requests from an additional 23 railroads to field test uncertified PTC systems on the 
13

general rail system, under 49 CFR § 236.1035 as of June 30, 2018. Specifically, in addition to 

the nine railroads that have obtained conditional PTC System Certification, FRA has approved

requests from seven additional railroads to initiate revenue service demonstration (i.e., advanced 

field testing)38 and 16 more railroads to initiate initial field testing39 as of June 30, 2018. 

C. Railroads’ Progress Toward Meeting 2018 Statutory Requirements

As indicated in Figure 2, railroads subject to the statutory mandate have made significant 

progress in installing onboard, wayside, and back office hardware necessary for PTC systems. 

As of March 31, 2018, railroads self-report that approximately 93% of PTC system hardware has 

been installed. From Quarter 1 of 2017 to Quarter 1 of 2018, railroads increased the total 

amount of installed PTC system hardware from 77% to 93%. 

 

38 Canadian National Railway; North County Transit District; Port Authority Trans-Hudson; Portland and Western 

Railroad; Regional Transportation District Commuter Rail (Denver RTDC); Sonoma-Marin Area Rail Transit; and 

Sounder Commuter Rail. 

39 Alaska Railroad; Belt Railway Company of Chicago; Central Florida Rail Corridor; Consolidated Rail 

Corporation; Denton Country Transportation Authority; Florida East Coast Railway; Long Island Rail Road; 

Massachusetts Bay Transportation Authority; Metro-North Commuter Railroad; New Jersey Transit; Northeast 

Illinois Regional Corporation (Metra); Northern Indiana Commuter Transportation District; South Florida Regional 

Transportation Authority; Terminal Railroad Association of St. Louis; Trinity Railway Express; and Utah Transit 

Authority FrontRunner Commuter Rail. 

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Q1 2016 Q1 2017 Q1 2018 Q1 2016 Q1 2017 Q1 2018 Q1 2016 Q1 2017 Q1 2018

Onboard Hardware Wayside Hardware Back Office Hardware

Percentage of Hardware Installed

Percentage of PTC System Hardware Installation

By Hardware Type

Freight Passenger

Percentage of All 

Hardware Installed 

by 3/31/2016: 60%

Percentage of All 

Hardware Installed 

by 3/31/2017: 77%

Percentage of All 

Hardware Installed 

by 3/31/2018: 93%

Figure 2 – Industry Progress Toward Installing PTC System Hardware from Quarter 1 of 2016 to Quarter 1 of 2018.
14

Notably, intercity passenger and commuter railroads increased PTC system hardware installation 

by 20% from Quarter 1 of 2017 to Quarter 1 of 2018, with freight railroads increasing hardware 

installation by 16% during that same period. Hardware installation is an initial, yet critical, 

phase of implementing a PTC system. As of March 31, 2018, 14 railroads report they have 

completed installation of all hardware necessary for PTC system implementation and another 13 

railroads report they have installed over 80% of the required hardware.

In addition, as of March 31, 2018, all but two railroads report having acquired sufficient 

spectrum for their PTC system needs, which represents substantial progress. From Quarter 1 of 

2017 to Quarter 1 of 2018, railroads acquired 23% of the spectrum necessary for PTC system 

implementation, with 93% of the necessary spectrum acquired as of March 31, 2018.

Figure 3 provides a detailed analysis of each railroad’s self-reported progress as of March 31, 

2018, with respect to the various statutory criteria a railroad must meet to qualify for an 

alternative schedule, as explained in Section II(B) above.40

 

40 49 U.S.C. § 20157(a)(3)(B)(i)–(vii).
15

1

Data is current as of March 31, 2018. All data is based on self-reported data via railroads’ Quarterly PTC Progress Reports from Q1 of 2018 (Form FRA F 6180.165, OMB Control No. 2130-0553).

2

Onboard hardware may include multiple components per locomotive.

Figure 3 – Railroads’ Progress Toward Meeting Statutory Criteria for an Alternative Schedule as of March 31, 2018.
16

D. Railroads at Risk of Failing to Meet One or More Statutory Criteria Required for an 

Alternative Schedule by December 31, 2018

FRA considers any railroad that had installed less than 85% of its PTC system hardware as of 

March 31, 2018, to be at risk, as hardware installation is only an initial phase of implementing a 

PTC system and only one of the statutory criteria required to qualify for an alternative schedule. 

FRA provides below a synopsis of the twelve railroads, in alphabetical order, that FRA currently 

considers at risk based on the objective metric regarding hardware installation progress as of 

March 31, 2018. Please note that, in certain cases, FRA identifies below tenant railroads that 

operate on the same main lines as the twelve at-risk railroads for additional context; however, 

please reference the “Interoperability” column in Appendix A for the number of required tenant 

railroads that are equipping locomotives with PTC technology and for more comprehensive 

information, please reference each railroad’s PTCIP in its PTC docket at 

https://www.fra.dot.gov/Page/P0628. 

Altamont Corridor Express (ACE)

ACE operates eight weekday commuter trains over approximately 85 miles of track owned by 

UP and the Peninsula Corridor Joint Powers Board (Caltrain) from Stockton to San Jose, 

California. ACE does not own any track and is a tenant-only railroad. FRA considers ACE at 

risk as it had installed only 25% of the hardware required for its PTC system as of March 31, 

2018, based on self-reported data. ACE’s current plan is to complete installation of all onboard 

PTC system equipment on ACE’s six locomotives and seven cab cars during October 2018 and 

to begin field testing on UP in the summer of 2018 and on Caltrain in approximately October 

2018. Given its small fleet and number of revenue service operations, ACE is confident it can 

complete PTC system hardware installation during the fourth quarter of 2018; however, initiating 

the required level of testing on its host railroads, along with Caltrain’s ability to meet the 

statutory criteria required for an alternative schedule, will remain ACE’s primary risks. 

Belt Railway of Company of Chicago (BRC)

BRC is a Class III switching and terminal railroad with 28 route miles of main line that enable

the transfer of freight among all Class I railroads, regional railroads, and short line railroads in 

the Chicago Switching District. FRA considers BRC at risk as it had installed 80% of the 

hardware required for its PTC system as of March 31, 2018, based on self-reported data. While 

BRC will implement a PTC system on all 28 miles, it recently requested to amend its PTC

Implementation Plan to limit its required PTC system implementation to the two miles of track 

where BRC hosts regularly scheduled intercity and commuter rail passenger transportation—

specifically, two daily Amtrak trains and 30 daily Northeast Illinois Regional Corporation 

(Metra) commuter trains on weekdays and six daily trains on Saturdays. BRC has informed FRA 

that, to date, BRC has finished installing all PTC system hardware on the two miles of track 

where Amtrak and Metra operate. BRC cites its supplier’s ability to develop BRC’s back office 

and a PTC-capable dispatch system as the most significant ongoing challenges for BRC’s 

implementation of a PTC system. BRC has confirmed it will request FRA’s approval to 

establish substitute criteria instead of the applicable statutory criterion that requires initiating

revenue service demonstration “on at least 1 territory that is required to have operations 
17

governed by a [PTC] system,” for purposes of qualifying for an alternative schedule.41 Based on 

BRC’s revised PTC Implementation Plan, BRC has an achievable path to meeting the statutory 

criteria required to qualify for an alternative schedule, but it must closely manage its supplier to 

ensure it timely completes and delivers the back office and PTC-capable dispatch subsystems.

Caltrain

Caltrain operates approximately 92 daily commuter trains over its 52-route-mile corridor from 

downtown San Francisco to San Jose, California, and an additional six daily trains over 

approximately 25 route miles of track owned by UP from San Jose to Gilroy, California. FRA 

considers Caltrain at risk in part because it had installed 74% of the hardware required for its 

PTC system as of March 31, 2018, based on self-reported data. Notably, given termination of its 

primary contractor in February 2017, Caltrain is no longer implementing I-ITCS as its PTC 

system. In March 2018, Caltrain awarded a contract to Wabtec to implement I-ETMS. Although 

it is possible that many of the PTC system hardware components can be effectively reused, 

surveys are ongoing to determine the extent of compatibility between the existing physical 

equipment and I-ETMS. At a minimum, this transition will require significant onboard and back 

office hardware modifications, in addition to perhaps other modifications. The testing that must 

be performed to validate system functionality and Caltrain’s ongoing electrification construction 

efforts also present significant schedule risks for implementation of I-ETMS. Caltrain continues 

to work closely with FRA and has put forward an achievable path to meeting the statutory 

criteria required to qualify for an alternative schedule, but only if it closely manages the ongoing 

equipment surveys, its schedule, and any potential complications that arise due to its 

contemporaneous capital projects. 

Capital Metropolitan Transportation Authority (CMTY)

CMTY operates approximately 38 weekday commuter trains over its 32-mile Central 

Subdivision in the Austin, Texas, metropolitan area. FRA continues to consider CMTY at risk as 

it had installed none of the hardware required for its PTC system as of March 31, 2018, based on 

self-reported data. CMTY informed FRA that, by June 30, 2018, CMTY plans to complete 

hardware installation on two of its locomotives and on the 10-mile track segment on which it will 

conduct field testing and revenue service demonstration. CMTY anticipates it will complete the 

remainder of onboard PTC system hardware installation by November 2018 and wayside 

hardware installation by December 2018. On December 4, 2017, in response to CMTY’s written 

request, FRA established substitute criteria that would permit CMTY to initiate revenue service 

demonstration on the 10-mile segment described in its October 31, 2017, request letter instead of 

one entire territory, for purposes of meeting substitute criteria under 49 U.S.C. 

§ 20157(a)(3)(B)(vii)(II). Given CMTY’s plan to complete hardware installation on its 10-mile

pilot track segment by June 30, 2018, and CMTY’s estimate that it will commence initial field 

testing in October 2018, FRA has conveyed to CMTY that initiating revenue service 

demonstration this year might be infeasible, so it might be necessary for CMTY to request other 

substitute criteria for purposes of qualifying for an alternative schedule. CMTY has put forward 

an achievable path to meeting the statutory criteria required to qualify for an alternative 

schedule, but it must remain vigilant, adhere to an aggressive installation schedule, and

 

41 See 49 U.S.C. § 20157(a)(3)(B)(vii).
18

expeditiously manage and mitigate risks, including the final design and delivery of E-ATC 

software.

Central Florida Rail Corridor (CFRC or SunRail)

SunRail commenced commuter rail service in May 2014, and it currently operates 36 weekday 

trains on approximately 31.5 route miles of track owned by the Florida Department of 

Transportation (FDOT). A PTC system is being implemented on FDOT’s entire 61.35-mile 

CFRC corridor, which also hosts six daily Amtrak trains, including the Auto Train, and freight 

trains operated by CSX and one short line railroad. FRA considers CFRC at risk because it had 

installed 53% of the hardware required for its PTC system as of March 31, 2018, based on selfreported data. CFRC informed FRA that it plans to complete hardware installation on its 

locomotives and cab cars in July 2018 and wayside hardware installation by October 2018, and 

will replace its computer-aided dispatch system in approximately September 2018. On January 

23, 2017, in response to CFRC’s written request, FRA established substitute criteria that would 

permit CFRC to initiate revenue service demonstration on the 15-mile track segment described in 

its October 31, 2016, request letter instead of one entire territory, for purposes of meeting 

substitute criteria under 49 U.S.C. § 20157(a)(3)(B)(vii)(II). Although CFRC has put forward an 

achievable path to meeting the statutory criteria required to qualify for an alternative schedule,

CFRC must remain vigilant, adhere to an aggressive installation schedule, and expeditiously 

manage and mitigate risks. Given CFRC’s estimate that it will commence field testing in 

October 2018, FRA has conveyed to CFRC that initiating revenue service demonstration this 

year might be infeasible, so it might be necessary for CFRC to request other substitute criteria 

for purposes of qualifying for an alternative schedule. 

Maryland Area Regional Commuter (MARC)

In addition to limited weekend service, MARC operates, on average, 93 weekday commuter 

trains serving Maryland, Washington DC, and West Virginia over 202 miles of track owned 

primarily by CSX and Amtrak. As MARC requested and obtained FRA’s approval of a main 

line track exception for the track it owns (MARC’s 3.2-mile Frederick Branch), MARC is 

implementing a PTC system on only its locomotives and cab cars and is obtaining a hosted back 

office server. FRA considers MARC at risk because it had installed 52% of the hardware 

required for its PTC system as of March 31, 2018, based on self-reported data. While onboard 

installations have been progressing since 2016, MARC did not reach an agreement to obtain 

onboard PTC radios until early 2018, negotiation of which MARC cites as the most difficult 

challenge to date. It is possible that MARC will be able to begin operating I-ETMS in revenue 

service on CSX’s track by December 31, 2018, as CSX, as the host railroad, has already obtained 

conditional PTC System Certification for I-ETMS from FRA, and MARC will coordinate field 

testing and interoperability testing with CSX during the summer and fall of 2018. At a 

minimum, however, MARC will need an alternative schedule for its implementation of I-ETMS 

and ACSES II on Amtrak’s Northeast Corridor. MARC has made significant progress over the 

last six months and has an achievable path to meeting the statutory criteria required to qualify for 

an alternative schedule.
19

Massachusetts Bay Transportation Authority (MBTA)

MBTA provides commuter rail service via 491 weekday trains on approximately 394 route miles 

of track, which also hosts the operations of Amtrak, CSX, NS, and three other railroads. FRA 

considers MBTA at risk because it had installed 71% of the hardware required for its PTC 

system as of March 31, 2018, based on self-reported data. MBTA informed FRA that it

currently plans to complete onboard hardware installation by August 31, 2018, and wayside 

hardware installation by late September 2018. MBTA has commenced field testing of its PTC 

system on 71 route miles, and it anticipates it will request FRA’s approval to initiate revenue 

service demonstration on its Stoughton Branch in September 2018. In addition, underscoring 

MBTA’s commitment to compliance with the mandate, MBTA has confirmed it will reduce 

commuter rail service during weekends to ensure it meets the statutory criteria required to 

qualify for an alternative schedule.

42

 MBTA has made significant progress over the last year and 

has an achievable path to meeting the statutory criteria required to qualify for an alternative 

schedule.

New Jersey Transit (NJT)

In total, NJT operates over 700 weekday trains and 382 weekend trains on approximately 1,001 

route miles of track, including operations over the Consolidated Rail Corporation and Amtrak’s 

Northeast Corridor. As set forth in its PTC Implementation Plan, NJT is implementing a PTC 

system on the 326 route miles of track it owns and controls. FRA considers NJT at risk because 

it had installed only 13% of the hardware required for its PTC system as of March 31, 2018, 

based on self-reported data. 

While NJT will equip 440 locomotives and cab cars with PTC system hardware, it recently 

requested to amend its PTC Implementation Plan to limit its required hardware installation to 

282 locomotives and cab cars, which is what NJT uses for regular service, including a 10% spare 

ratio. NJT is increasing the pace of onboard PTC system hardware installation by adding shifts 

to its two facilities, and it projected to equip 25 to 30 vehicles per month during the second 

quarter of 2018 and 30 to 40 vehicles per month afterwards, which NJT notes will position the 

railroad to equip more locomotives and cab cars than the 282 required by December 31, 2018. In 

addition, NJT informed FRA that it is moving forward aggressively with wayside hardware 

installation, even though it is awaiting final designs, so that NJT can meet the statutory 

requirements. To date, NJT has commenced field testing of its PTC system on approximately six 

miles of its Morristown Line. On June 26, 2018, in response to NJT’s May 8, 2018, request,

FRA established substitute criteria under 49 U.S.C. § 20157(a)(3)(B)(vii)(II) that would permit 

NJT to conduct field functionality testing on a 16.5-mile segment of track that is representative 

of NJT’s main lines that are subject to the statutory mandate, instead of the criterion that requires 

initiating revenue service demonstration on one territory. Although NJT has put forward an 

achievable path to meeting the statutory criteria required to qualify for an alternative schedule,

NJT and its contractors need to continue to monitor installation rates and other aspects of PTC 

system implementation vigilantly, and expeditiously manage and mitigate risks. NJT confirmed 

 

42 MBTA, Commuter Rail Positive Train Control, (May 31, 2018) https://www.mbta.com/projects/commuter-railpositive-train-control-ptc.
20

it will reduce commuter rail service, beginning June 4, 2018, until early 2019, to help facilitate 

compliance with the statutory mandate.

43

New Mexico Rail Runner Express (Rio Metro Regional Transit District or NMRX)

On its 120-mile network, NMRX operates 16 daily commuter trains from Santa Fe to 

Albuquerque, New Mexico, and Amtrak operates two daily Southwest Chief trains from Control 

Point (CP) Madrid to CP Lamy. FRA considers NMRX at risk because it had installed only 9% 

of the hardware required for its PTC system as of March 31, 2018, based on self-reported data. 

By July 2018, NMRX expects to have a fully executed contract in place with a PTC system 

supplier. NMRX is currently in the process of preparing a “limited operations main line track 

exception” under 49 CFR § 236.1019(c)(1)(iii), which requires the development of a risk 

mitigation plan and FRA review and approval. NMRX has indicated that it will request a main 

line track exception on a temporary basis only and intends to fully implement a PTC system by 

December 31, 2020. Before December 31, 2018, NMRX must complete the required risk 

assessment; implement any identified risk mitigations; obtain necessary concurrence from its 

tenant railroads, BNSF and Amtrak; submit its formal request to FRA; and obtain FRA approval. 

As of June 1, 2018, NMRX anticipates it will submit the formal exception request to FRA in the 

summer of 2018. Primarily, NMRX cites the high cost of implementing a PTC system and 

insufficient funding as its primary challenges. 

Northern Indiana Commuter Transportation District (NICD or South Shore Line)

NICD operates 43 weekday trains from South Bend, Indiana, to Chicago, Illinois, over NICD’s 

75 route miles and an additional 15 route miles owned by Metra. FRA considers NICD at risk 

because it had installed 53% of the hardware required for its PTC system as of March 31, 2018, 

based on self-reported data. Approximately 72 of NICD’s 82 rail cars are locomotives, and 

NICD is equipping each locomotive even if it will not serve as the controlling locomotive of a 

commuter train. Notably, NICD informed FRA that, to date, it has equipped sufficient 

locomotives with PTC system hardware to cover its regular daily service, including an additional 

50% surplus, and it plans to complete onboard hardware installation on the remaining 

locomotives by November 2018. To date, NICD has commenced PTC system field testing on 

approximately 72 route miles and plans to conduct field qualification testing in September or 

October 2018, prior to initiating FRA-approved revenue service demonstration. NICD has made 

significant progress over the last year and has an achievable path to meeting the statutory criteria 

required to qualify for an alternative schedule. NICD cited funding as a primary challenge to 

PTC system implementation, particularly pointing to high operations and maintenance costs each 

year going forward. 

South Florida Regional Transportation Authority (Tri-Rail or SFRTA)

SFRTA operates 50 weekday Tri-Rail commuter trains serving the Broward, Miami-Dade, and 

Palm Beach counties over 72.6 route miles of track, and hosts four daily Amtrak trains in 

addition to CSX freight trains. FRA considers SFRTA at risk because it had installed only 25% 

of the hardware required for its PTC system as of March 31, 2018, based on self-reported data. 

 

43 NJT, Positive Train Control, http://www.njtransit.com/var/var_servlet.srv?hdnPageAction=PTCTo.
21

Notably, SFRTA became the host railroad on March 29, 2015, when it took effective operating 

control over the 72.6-mile territory, which is owned by FDOT and had been dispatched and 

maintained by CSX until that time. SFRTA informed FRA that it plans to complete wayside 

PTC system hardware installation in August 2018 and onboard hardware installation by 

December 2018. On May 30, 2018, in response to SFRTA’s written request, FRA established 

substitute criteria that would permit SFRTA to initiate field integration testing on its entire 72.6-

mile territory, subject to certain testing conditions and industry standards, for purposes of 

meeting substitute criteria under 49 U.S.C. § 20157(a)(3)(B)(vii)(II). Although SFRTA has put 

forward an achievable path to meeting the statutory criteria required to qualify for an alternative 

schedule, the highest risk lies with the timely delivery of SFRTA’s new computer-aided dispatch 

system in the fall of 2018, which is a pivotal prerequisite to integration testing of the PTC 

system. SFRTA must remain vigilant, expeditiously manage and mitigate risks, and adhere to an 

aggressive installation schedule.

Trinity Railway Express (TRE)

TRE operates 47 weekday trains and 19 trains on Saturday over approximately 34 route miles of 

track between Dallas and Fort Worth, Texas, and currently hosts operations by Amtrak, BNSF, 

UP, and two short line railroads. FRA continues to consider TRE at risk as it had installed none 

of the hardware required for its PTC system as of March 31, 2018, based on self-reported data. 

TRE informed FRA that as of May 30, 2018, it has equipped two of its 17 locomotives with PTC 

system hardware. TRE projects that it will finish installing all onboard, wayside, and back office 

PTC system hardware by October 2018, although it noted serious concerns regarding its 

supplier’s ability to deliver hardware kits and provide sufficient resources in accordance with the 

updated schedule, given the supplier’s past delays and long lead times. TRE has noted that one 

primary challenge to beginning PTC system implementation was multiple failed solicitations due 

to pricing disputes from 2014 to mid-2017. TRE has indicated it will likely request FRA’s 

approval to establish substitute criteria instead of the applicable statutory criterion that requires 

initiating revenue service demonstration “on at least 1 territory that is required to have operations 

governed by a [PTC] system.”44 TRE has put forward an aggressive path to meet the statutory 

criteria required to qualify for an alternative schedule, and TRE must closely manage its 

schedule, its supplier’s performance, and any potential complications or further delays that arise 

due to its ongoing capital projects. 

E. Observations

FRA continues to encourage railroads, particularly commuter railroads, to explore any and all 

options available to expedite the safe implementation of PTC systems. Options may include 

partnering with other railroads, sharing resources, reducing or halting capital construction on 

lines where PTC technology is being implemented, providing priority to test trains and 

PTC-related work zones, and even the suspension of service on certain lines or segments, as 

necessary, to facilitate hardware installation required for PTC systems. Although some of these 

options might not be not ideal or desirable in the short term, including for the traveling public, 

some railroads might have few other available options at this point to ensure they comply with 

the statutory mandate. 

 

44 See 49 U.S.C. § 20157(a)(3)(B)(vii).
22

V. Industry Challenges

During FRA’s meetings with the leadership of the 41 railroads subject to the statutory mandate

in January and February 2018 and continued meetings to date, railroads commonly conveyed the 

following ongoing challenges:

• There is a limited number of PTC system vendors and suppliers, all of which are 

significantly resource-constrained and serving all 41 railroads and their tenant railroads;

• As reliability and stability of PTC systems is still immature, railroads are experiencing 

significant technical issues with both PTC system hardware and PTC system software 

that often take considerable time to diagnose and resolve, impacting current operations;

• Host railroads noted that many tenant railroads that operate on main lines requiring PTC 

system implementation have made variable, and often unknown, progress equipping 

locomotives with operational PTC technology, while some tenant railroads report that 

their host railroads are not providing opportunity for testing; 

• Railroads have only recently begun testing PTC systems for interoperability; 

• Many commuter railroads stated that negotiating legal agreements with certain vendors 

and suppliers often took multiple years to complete, given various insurance, liability, 

and state law issues; and

• Railroads noted concern about FRA’s approval review and approval cycle, given the 

surge in submissions requiring FRA approval in 2018. 

In addition, as summarized in Figure 4 below, 78% of reporting railroads (32 of 41 annual 

reports received) specifically cited challenges they are experiencing with PTC system 

implementation in their Annual PTC Progress Reports for Calendar Year 2017.

45

 

 

45 Form FRA F 6180.166, OMB Control No. 2130-0553.
23

Figure 4 – Challenges Reported in Railroads’ 2017 Annual PTC Progress Reports.

Consistent with previous reports, the key challenges railroads continue to face relate to the 

limited capacity and resources of PTC system suppliers and vendors, PTC system maturity 

(including software and system development), and testing and achieving interoperability among 

host railroads and tenant railroads that operate on the same main lines. These reported 

challenges echo the discussions and conclusions drawn by FRA during its meetings with 

railroads’ executive leadership and technical teams and the supplier and vendor industry. These 

noted challenges are also interconnected, as they relate to the overall maturity of PTC systems as 

a whole, particularly given the wide-scale deployment required. Before each individual railroad 

can address interoperability testing with each of the other railroads that operates on the same 

main lines, a railroad must first achieve stable operation of its own PTC system. Railroads 

continue to address reliability and capacity issues born from the rapid deployment of PTC 

systems and the ongoing changes necessary to achieve proper performance of these softwaredriven and highly complex systems. To support railroads and help address their concerns 

regarding testing, FRA will hold a second symposium on July 16, 2018, to discuss best practices 

for PTC system field testing and interoperability testing.

VI. Conclusion

FRA understands that throughout 2018 and continuing in 2019 and 2020, there will be an 

increase in railroads’ requests for FRA approval of Requests for Amendments to PTC 

Implementation Plans, requests to conduct PTC system field testing and revenue service 

3

6

9

4

2

1

14

9

12

6

6

4

4

0 5 10 15 20 25

Suppliers

Software

Interoperability

PTC System is Still Under Development

Funding

FRA Review Times

Engineering and Logistics

PTC Implementation Challenges

Freight Passenger
24

demonstration, and thereafter more railroads will submit PTC Safety Plans to FRA for review 

and approval, in order to obtain PTC System Certification. To address these needs in a manner 

that supports accelerated timelines, FRA has increased its PTC workforce through hiring and 

training, expanded contracts with existing PTC support contractors, and initiated one additional 

contract to provide technical support to FRA regarding the review of PTC Safety Plans.

At this time, FRA believes that—with limited exceptions—the vast majority of railroads subject 

to the statutory mandate will meet, and in many cases, exceed, the statutory criteria required to 

qualify for and obtain an alternative schedule and remain in compliance with this critical 

mandate. Given the imminent December 31, 2018, statutory deadline, FRA continues to compel 

each railroad and all stakeholders to carefully consider and evaluate each railroad’s PTC system 

implementation progress to date. It is imperative that railroads understand and properly account 

for any remaining technical and schedule-related risks. 

FRA is strongly urging railroads to achieve full implementation of FRA-certified and 

interoperable PTC systems on all main lines subject to the statutory mandate in accordance with 

the congressional deadlines. FRA will continue to transparently track and report on the railroad 

industry’s progress toward full PTC system implementation and to provide technical assistance 

to railroads to the greatest extent possible to help ensure PTC systems are fully implemented as 

safely and efficiently as possible.