F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

PTC Collaboration Session 

First of Six in 2019 and 2020

To promote information-sharing, 

best practices, and collaboration 

between FRA and industry

February 6, 2019
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Topics For Discussion

• Current PTC Status

• FRA PTC Organization & Current Initiatives

• PTC Safety Plan – FRA Approach to Certification (2019-2020)

• Material Modifications to PTC Systems

• PTC Regulation During and Post Full Implementation
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Current PTC Status

as of Q4 2018 
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Current Status – High-level Points 

• Railroad Industry Met or Exceeded the Statutory 2018 Requirements

o 4 railroads self-reported that they fully implemented an FRA-certified and interoperable

PTC system on all of their required route miles

– Metrolink (Southern California)

– North County Transit District (Southern California)

– PATH (New York / New Jersey)

– Portland & Western Railroad (Portland Metropolitan Area)

o 36 railroads demonstrated they met the six robust criteria necessary to qualify for an

alternative schedule and sequence, and FRA received all necessary written notifications by

December 21, 2018, in advance of the deadline

• Several Railroads Requested Final Deadlines Before December 31, 2020

• As of December 31, 2018, PTC systems were in operation on almost 46,000

of the nearly 58,000 route miles that are subject to the statutory mandate

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F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

All railroads met the 

December 31, 2018 

statutory requirements 

for an alternative 

schedule. 

Four railroads 

achieved full 

implementation.

SUBSTITUTE 

CRITERIA

STATUTORY 

REQUIREMENTS

ALTERNATIVE 

SCHEDULES

15 railroads out of 32 

eligible railroads 

requested testingrelated substitute 

criteria (instead of 

RSD). Two of these 

railroads still initiated 

RSD by 12/31/2018.

100% 47%

FRA has formally 

approved 25 alternative 

schedule and sequence 

requests, to date. All 

remaining decisions will 

be issued before 

statutory 90-day 

deadline.

75%

Current Status – Alternative Schedule and Substitute Criteria

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F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Route Miles Where Host Railroads’ 

Operations are Governed by PTC1

30%

83%

7%

0% 20% 40% 60% 80% 100%

Miles in Operation Miles in Advanced Testing

Freight

Passenger

1Based on Railroads’ Self-reported Progress and PTC Implementation Plans as of 

December 31, 2018

Current Status – Host Railroad Mileage and Interoperability

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F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

45,933

288

11,627

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

1

Series1 Series2 Series3

1,204 ; 

30%

288 ; 

7%

2,495 ; 

63%

Intercity Passenger and 

Commuter

1 2 3

14, 

13%

95; 

87%

Short Line/Other

44,715; 

83%

9,037; 

17%

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Required PTC Route Miles in Operation – A Closer Look
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

79%PTC Training 

Completed 98%

Closer Look at Status of PTC Training

92,613

14,099

1,071

316

1,463

85%

87%

89%

91%

93%

95%

97%

99%

101%

1 2 3

Series1 Series2

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F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Progress by Sector Toward Full PTC System1

Implementation

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1Based on Railroads’ Self-reported Progress and PTC Implementation Plans as of December 31, 2018
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

PTC Organization & Current Initiatives
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

FRA PTC Organization

Staff Director

PTC and S&TC

Deputy Staff 

Director - PTC

Deputy Staff 

Director – S&TC

PTC Project 

Manager

PTC Sr Test 

Monitors

(2)

PTC Specialists 

(8)

Analyst (1)

Engineers

(3)

S&TC 

Specialists (3)

Staff Director

Passenger Rail

Railroad Experts 

(4)

PTC Data Team 

(3)

Safety Experts 

(3)

PTCSP 

Contractor (1)

Key:

FRA Staff

Contractor

PTC Attorneys

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F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

• Revenue Service Demonstration: Provide continued technical assistance to 

railroads that are in the initial stages of field testing and have not yet initiated RSD

• Interoperability: Confirm the PTC Implementation Status of All Tenant Railroads

• Meeting with Class I, Amtrak, and commuter host railroads to validate and confirm tenant 

PTC requirements

• Meeting with all tenant railroads to review their PTC program of work, schedule, and 

technical implementation status (host railroads’ PTC Implementation Plans reference 

approximately 115 unique tenant railroads in total)

• Document the status of each tenant railroad

• Provide any requested technical support

• PTC Safety Plans: Streamline the Review and Approval Process

• PTC Reporting: Errors and Malfunctions Forms 

• PTC Compliance Manual: Inspection Approach

Current Initiatives

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F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

PTC Specialist Perspective
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

PTC Safety Plans
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

PTC Safety Plans (Host Railroads Only)

Current Status (1)

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F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

PTC Safety Plans

Current Status (2)

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F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

PTC Safety Plans

Current Status (3)

Note: One (1) PTCSP submission date still to be confirmed

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F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

• Compliance with Regulatory Requirements for PTC Safety Plans

• § 236.1015 (d) (1 – 21) and (e) (1 – 4)

• Descriptions may summarize and refer to other railroad documentation

• Key Focus Areas of FRA’s PTCSP Review

• Any Variances to Applicable PTC Development Plan and Type Approval

• Hazard Log

• Risk Assessment, including Residual Human Error Risk to Incursion into Work Zones

• Configuration and Revision Control

• Post-implementation Testing

• Rerouting Plan

• Safety Analysis as Required by System Type (Non-vital Overlay, Vital Overlay, Standalone, 

or Mixed)

• Vendor Documentation 

• Baseline Documentation

• Configuration Management

• Document Railroad-specific Variations

PTC Safety Plans

FRA’s Approach to Certification of PTC Systems from 2019 to 2020

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F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

• Interoperable Electronic Train Management System (I-ETMS)

• Advanced Civil Speed Enforcement System II (ACSES) / 

Advanced Speed Enforcement System II (ASES)

• Enhanced Automatic Train Control (E-ATC)

PTC Safety Plans

Working Group Updates

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F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Material Modifications

Management of PTCSPs 
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Changes requiring filing of a request for amendment (RFA) 

(§ 236.1021(h)):

• Discontinuance of a PTC system or other appliance or device

• Decrease of a PTC system’s limits

• Modification of a safety-critical element of a PTC system

• Modification of a PTC system that affects the safety-critical functionality 

of any other PTC system with which it interoperates

Material Modification

Regulatory Requirements

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F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

• Simplify the post-2020 process for PTC Safety Plan changes as a 

result of material modifications

• FRA welcomes feedback on any potential regulatory simplifications regarding 

material modifications to PTC Safety Plans (after initial statutorily-required PTC 

System Certification)

• How is a host railroad planning to do to ensure alignment between the 

PTC system and its PTC Safety Plan

• How are railroads internally planning to update the PTC Safety Plan? What 

processes are already in place for the 12 host railroads with conditional PTC 

System Certification?

• How to address PTC system product changes that impact multiple 

PTCSPs

• Potentially 23 I-ETMS PTCSP RFAs?

• Potentially 6 E-ATC PTCSP RFAs?

Material Modification

Discussion Topics

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F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

FRA’s Oversight and Regulation of PTC Systems

During and After Full Implementation 
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Oversight Focus During the Implementation of PTC Systems 

(Throughout 2019 and 2020)

• Compliance with Governing PTC Implementation Plans (PTCIP)

 Railroads must implement a PTC system in accordance with the applicable PTCIP

(i.e., the one that governs implementation on the applicable main line)

 Railroads must comply with the specific schedule and risk-based track segment

sequence, including the railroad’s schedule for:

 Field Testing and Revenue Service Demonstration

 Achieving Interoperability with Each Tenant Railroad, as Specified

 Submission of a PTC Safety Plan (Host Railroads Only)

 Activation of a PTC System on All Route Miles (or Remaining Route Miles)

• Purpose and Reminders:

 By statute, FRA must conduct compliance reviews at least once per year to

determine whether railroads are adhering to their PTCIPs.

 FRA may assess $28,474 per violation under 49 U.S.C. § 20157(e)(1)─(4).

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F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Oversight Focus During the Implementation of PTC Systems 

(Once the PTC System Is Certified by FRA) – Slide 1 of 6

 Compliance with Governing PTC Safety Plan and PTC System Certification

 A host railroad and any other railroads that operate on the host railroad’s main lines

subject to the statutory mandate must also comply with:

 All applicable provisions of the host railroad’s PTC Safety Plan, and

 The conditions FRA placed on its PTC System Certification for the specific PTC system at

issue

Exception: Unless the operations are subject to an exception under 49 CFR § 236.1006(b), as 

set forth in the host railroad’s PTC Implementation Plan (e.g., exceptions for certain freight yard 

movements and very limited Class II or III movements)

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F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Oversight Focus During the Implementation of PTC Systems 

(Once the PTC System Is Certified by FRA) – Slide 2 of 6

 Compliance with Statutory Early Adopter Provisions and Reporting Requirements

– Background –

As a reminder, the PTC Enforcement and Implementation Act of 2015 imposes a temporary 

prohibition on FRA’s authority to enforce certain PTC regulations. 

• When? October 29, 2015 → One year after the last Class I railroad obtains PTC System

Certification and finishes implementing a PTC system on all of its required lines.

• What is the scope of the prohibition? Railroads may not be subject to the operational

restrictions (e.g., speed restrictions) in 49 CFR §§ 236.567 or 236.1029 that would apply

where a controlling locomotive experiences a PTC system failure; a PTC-operated consist

is not provided by another railroad in interchange; or a PTC system otherwise fails to

initialize, cuts out, or malfunctions.

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F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Oversight Focus During the Implementation of PTC Systems 

(Once the PTC System Is Certified by FRA) – Slide 3 of 6

 Compliance with Statutory Early Adopter Provisions and Reporting Requirements

• Is this prohibition unlimited? No, the prohibition preventing FRA from enforcing the

operational restrictions applies only if the railroad operates at an equivalent or greater level of

safety than the level achieved immediately prior to PTC system implementation.

• So, what operational restrictions do apply and what does FRA enforce during this

period? The safety measures (including operating rules) that the railroad states, in its PTC

Safety Plan, it will put in place during a system failure. 49 U.S.C. § 20157(j)(3); 49 CFR § 236.1009(d)(3).

• What safety assurances does Congress require? If an FRA-certified PTC system fails to

initialize, cuts out, or malfunctions, the affected railroad shall make reasonable efforts to

determine the cause of the failure and adjust, repair, or replace any faulty component causing

the system failure in a timely manner.

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F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Oversight Focus During the Implementation of PTC Systems 

(Once the PTC System Is Certified) – Slide 4 of 6

 Compliance with Statutory Early Adopter Provisions and Reporting Requirements

– Reporting Requirements –

• When do the statutory reporting requirements apply? During the period set forth in the

statute (October 29, 2015 → ~December 31, 2021)

• What triggers the requirement? When an FRA-certified PTC system fails to initialize, cuts

out, or malfunctions, the railroad shall submit a notification to the appropriate FRA

regional office within 7 days (or under alternative location and deadline requirements set by

FRA).

 Notification must include a description of safety measures the railroad has in place.

• What is the current requirement? The above reporting requirement is in effect for all 12

host railroads that have obtained conditional PTC System Certification and any tenant

railroad that has commenced PTC-governed operations on such main lines.

 Although not currently required, FRA encourages railroads w/ certified PTC systems to submit a courtesy

copy of such notifications to FRA’s Secure Information Repository, so FRA can begin centralized analysis.

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F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Oversight Focus During the Implementation of PTC Systems 

(Once the PTC System Is Certified) – Slide 5 of 6

 Compliance with Statutory Early Adopter Provisions and Reporting Requirements

– Reporting Requirements –

• FRA’s Initiative – The statute authorizes FRA to establish an alternative reporting deadline (instead of

within 7 days of a PTC system initialization failure, cut out, or malfunction) and an alternative reporting

location (instead of the applicable FRA regional office)

 FRA is currently considering alternative options and welcomes feedback. Ideas?

o Centralized reporting to Washington, DC on a monthly basis

o A new monthly form identifying # of failures to initialize, cut outs, and malfunctions

• Would additional breakdowns of each required high-level category be useful?

o Would industry be interested in an electronic, fill-in form (like 2015 monthly PTC questionnaires)?

 Once form is developed, FRA will publish a Federal Register notice and seek comment during a 60-day

period, before submitting form/Information Collection Request to the Office of Management and Budget.

• Reminders:

• FRA is authorized only to establish an alternative reporting deadline/frequency and location.

• FRA cannot change the scope of the reporting requirement (the statutory reporting requirement

encompasses all failures to initialize, cut outs, and malfunctions).

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F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Oversight Focus During the Implementation of PTC Systems – Slide 6 of 6

 Full Implementation of FRA-certified and Interoperable PTC Systems on All Required

Main Lines As Soon as Possible

All railroads should strive to fully implement FRA-certified and interoperable PTC systems “as soon 

as practicable,” and not later than December 31, 2020, as the statutory mandate requires.

FRA stands ready to provide technical assistance to the greatest extent possible.

 Reminders Regarding Interoperability

All operations of a host railroad and its tenant railroads must be governed by an FRA-certified and 

interoperable PTC system on all route miles subject to the statutory mandate, except as otherwise 

permitted under 49 CFR § 236.1006(b) (including permanent exceptions for short, limited movements by 

Class II and III railroads, and temporary exceptions where interoperability may be achieved by December 

31, 2023). 

“Interoperability” means that a host railroad’s and a tenant railroad’s trains operating on the same 

main line are able to communicate with and respond to the PTC system, including uninterrupted 

movements over property boundaries.

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F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Oversight Focus Both During & After the Full Implementation of PTC Systems 

Slide 1 of 2

 Reliability and Performance of PTC Systems

• FRA will monitor implementation and performance via railroads’ required reporting

o Statutory and Regulatory – Progress Reports Toward Full Implementation

o Quarterly PTC Progress Report Form (FRA F 6180.165, OMB Control No. 2130-0553)

o Annual PTC Progress Report Form (FRA F 6180.166, OMB Control No. 2130-0553)

o Statutory (Previous Slides) – The reporting requirements under the early adopter provisions

remain in effect until approximately December 31, 2021 (however, the actual end date is one year

after the last Class I railroad obtains PTC System Certification and finishes fully implementing an

interoperable PTC system on all of its required route miles).

o Regulatory (Only Applies After Full Implementation) – Beginning April 16 after a

railroad fully implements its PTC system, a railroad must submit an annual report regarding PTC

system failures that occurred during prior calendar year, with specific information re: locomotive,

wayside, communications, and back office system failures. See 49 CFR § 236.1029(h).

o Vendors’ and Suppliers’ Required Notifications to Railroads and FRA Under 49

CFR § 236.1023 (Errors and Malfunctions)

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F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Oversight Focus Both During & After the Full Implementation of PTC Systems 

Slide 2 of 2

 Compliance with All Technical Requirements Under 49 CFR Part 236, Subpart I

• FRA is authorized to conduct audits to determine whether a railroad is in compliance with 49 CFR part

236, subpart I.

o FRA “shall be afforded reasonable access to monitor, test, and inspect processes, procedures, facilities,

documents, records, design and testing materials, artifacts, training materials and programs, and any

other information used in the design, development, manufacture, test, implementation, and operation of

the system, as well as interview any personnel . . . .” 49 CFR § 236.1009(h).

 Ongoing Coordination with the Industry to Improve PTC System Performance,

Reliability, and Efficiency

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F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Questions and Suggestions for FRA