Rail Safety: Preliminary Observations on Federal Rail Safety Oversight and Positive Train Control Implementation
Published: 2013-06-19T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The rail network is one of Americas safest modes of transportation, although several recent rail accidents have reinforced the need for constant effort from the private and public sectors to ensure safety for rail passengers, the public, and railroad employees. FRA, the federal agency responsible for railroad safety, works with freight, commuter, and intercity passenger railroads and certain states to ensure the safety of the U.S. railroad network.
In 2007, FRA developed and implemented a risk-based approach to its safety inspections of the railroad network. In 2008, RSIA was enacted and, among other things, reauthorized FRAs rail safety program and included several new rail safety provisions, such as the implementation of PTC and creation of rail safety risk reduction plans.
This statement discusses GAOs preliminary observations about 1) how FRA oversees rail safety, 2) challenges to rail safety, and 3) PTC implementation by the U.S. rail industry. GAO examined FRAs overall rail safety framework and interviewed state rail safety officials and officials from FRA; selected Class I, II, and III railroads; and Amtrak on rail safety and PTC implementation.
GAO plans to issue reports on reviews of rail safety and PTC in the fall of 2013.
section_title: What GAO Found
paragraphs: The Federal Railroad Administration (FRA) primarily monitors railroads' compliance with federal safety regulations through routine inspections by individual inspectors at specific sites on railroads' systems. Thirty states also employ railroad safety inspectors, who participate in a partnership program with FRA to conduct supplemental safety oversight activities based on FRA rail safety regulations and enforce state railroad safety laws. FRA applies a quantitative, risk-based approach, the National Inspection Plan, to inform its rail safety oversight efforts using analyses of past accident and inspection data and other information to target inspections in each region. FRA also uses a planning and evaluation tool, the Staffing Allocation Model (SAM), to distribute its inspection resources across each FRA region. However, according to several FRA regional administrators that GAO spoke with, the staffing decisions based on SAM results do not necessarily align with their perspectives on the inspector needs for their regions.
Based on GAO's work to date, there are several potential challenges affecting FRA's rail safety oversight. First, the Rail Safety Improvement Act (RSIA) required FRA to issue regulations requiring certain railroads to submit risk reduction plans within 4 years. FRA has not yet issued a final rule on the plans. Second, FRA does not have a specific plan to replace its aging inspector workforce. According to FRA officials, in the next 5 years, about 32 percent of FRA inspectors will be eligible to retire. Although FRA officials said that they anticipate being able to replace inspectors, it can take 1 to 2 years to find, hire, train, and certify a new inspector. Finally, FRA faces other ongoing and emerging safety challenges like addressing adverse weather conditions and their impact on railroad operations and equipment, educating the public on the potential hazards of rail-highway crossings, accommodating changes in rail safety risks including new freight flows that affect the need for inspections, and hiring and training a specialized inspector workforce to provide adequate safety oversight for emerging technologies including positive train control (PTC), a communications-based system designed to prevent train accidents caused by human factors.
GAO's work to date indicates that railroads may not be able to fully implement PTC by the 2015 deadline established in RSIA. This is because of the many interrelated challenges caused by the complexity and breadth of PTC implementation. For example, PTC components, such as the back office servers, which are needed to communicate vital information between locomotives and wayside signals, are still under development. In addition, the need to integrate PTC components and field test the system is a time- and resource-consuming process. Finally, some railroads had concerns with FRA's limited resources and ability to verify field testing and certify the system once it is fully implemented. Officials from freight railroads and FRA stated they will not compromise PTC safety functions and will ensure PTC is implemented to meet the requirements of the RSIA mandate. However, in attempting to implement PTC by the 2015 deadline, railroads may be making choices that could introduce financial and operational risks. For example, freight railroad representatives told us that without adequate time for field testing, PTC systems could potentially malfunction or fail more frequently, causing system disruptions.

section_title: Letter
paragraphs: We appreciate the opportunity to participate in this hearing to discuss the  Federal Railroad Administration’s (FRA) rail safety oversight activities.  The rail network is one of America’s safest modes of transportation,  although several recent rail accidents, including the Metro-North  commuter rail accident in Bridgeport, Connecticut, the collision of BNSF  and UP trains in Chaffee, Missouri, and the collision of a CSX train and a  truck in Rosedale, Maryland, have reinforced the need for constant effort  from both the private and public sectors to ensure that rail transportation  remains safe for passengers, the public, and railroad employees. My  statement will discuss our ongoing reviews of FRA’s rail safety oversight  and the implementation of positive train control, a communications-based  system designed to prevent train accidents caused by human factors.
This testimony provides our preliminary observations from our ongoing  work, being performed at the request of this committee and other  Members of the Senate, regarding: (1) FRA’s framework for safety  oversight, (2) existing and emerging challenges to rail safety, and (3) PTC  implementation. Our preliminary assessments of FRA’s rail safety  framework and the quantitative tools FRA uses to implement that  framework are based on our reviews of FRA documentation and  interviews with FRA headquarters and regional officials. In addition, we  interviewed state rail safety officials and freight railroad officials from  selected Class I, II, and III railroads. We selected the railroads based on  the class of railroad (as a proxy for size), types of railroads (long distance  versus local service or a railroad that serves a small area such as a port  or rail yard), and type of ownership (publicly held, privately held, or owned  by a public agency) to get a range of different kinds of freight railroads.  For our assessment of PTC implementation, we reviewed documents and  interviewed officials from FRA and railroad associations, the four largest  freight railroads, commuter railroads that were selected based on PTC  implementation status and ridership levels (among other things), and  Amtrak. We also selected PTC suppliers and independent PTC experts  based on their involvement with PTC and recommendations from FRA,  industry associations, and others.
We conducted our ongoing work in accordance with generally accepted  government auditing standards. We provided a draft copy of this  statement to FRA for their review. The agency had no comment. We plan  to report the final results of our reviews in the fall of 2013.
subsections: section_title: Background
paragraphs: According to FRA data, 2012 was the safest year in railroad history.  Overall, rail safety—measured by the train accident rate per million train  miles—has improved markedly since 1980, as shown in figure 1. In  addition, the accident rate dropped by almost 50 percent from 2004 to  2012.
Even with the significant reduction in accident rates, however, roughly  300 people were injured and 10 people were killed in train accidents on  average each year, from 2003 to 2012. Further, recent rail accidents  underscore the importance of continued, consistent efforts to ensure rail  safety.
FRA provides regulatory oversight of the safety of U.S. railroads, both  passenger and freight. FRA develops and enforces regulations for the  railroad industry that include numerous requirements related to safety,  including requirements governing track; signal and train control systems;  grade-crossing warning device systems; mechanical equipment, such as  locomotives and tank cars; and railroad-operating practices. FRA also  enforces hazardous materials regulations that relate to the safe  transportation of such materials by rail.
The Rail Safety Improvement Act (RSIA) of 2008 was the first  authorization of FRA’s safety activities since 1994 and is due to be  reauthorized in 2013. RSIA overhauled federal rail safety requirements  by directing the FRA to, among other things, promulgate additional new  rail safety regulations and guidance in areas such as railroad risk  reduction plans, track inspections standards, and highway-rail grade  crossing safety.
RSIA also required railroads to develop and submit a plan to FRA for  implementing a PTC system on rail lines that carry intercity or commuter  passengers or toxic-inhalation-hazard cargo by December 31, 2015.  Under RSIA, FRA is responsible for approving railroads’ PTC  implementation plans and certifying PTC systems prior to installation.  PTC is a communication-based system designed to prevent some  accidents caused by human factors, including train-to-train collisions and  derailments caused by exceeding safe speeds. It is also designed to  prevent incursions into work zones and movement of trains through  switches left in the wrong position. By preventing trains from either  entering a segment of track occupied by another train or moving through  an improperly aligned switch, PTC could prevent accidents such as the  one in the Chatsworth neighborhood of Los Angeles, California.  Railroads that are required to implement PTC can choose different PTC  systems; however, railroads’ PTC systems must be interoperable. This  means that the components of different PTC systems must be able to  communicate with one another in a manner to provide for the seamless  movement of trains as they cross tracks owned by different railroads that  may be using different PTC systems.
section_title: FRA’s Rail Safety Framework Includes Data to Inform Its Rail Safety Oversight Efforts but Faces Potential Oversight Challenges
subsections: section_title: FRA’s Oversight Framework Primarily Uses Federal and State Inspectors to Oversee Railroad Safety Efforts
paragraphs: Our work to date indicates that FRA primarily monitors railroads’  compliance with federal safety regulations through routine inspections by  individual inspectors at specific sites on railroads’ systems. This  inspection approach focuses on direct observations of train components,  related equipment, and railroad property—including the track and signal  systems—as well as operating practices to determine whether they meet  FRA’s standards. Inspectors also examine railroads’ inspection and  maintenance records. FRA’s inspectors generally specialize in one of five  areas, called inspection disciplines: (1) operating practices, (2) track, (3)  hazardous materials, (4) signal and train control, and (5) motive power  and equipment. Inspectors typically cover a range of standards within  their discipline during inspections. FRA’s policy is for inspectors to  encourage railroads to comply with federal rail safety regulations  voluntarily. When railroads do not comply voluntarily or identified  problems are serious, FRA may cite violations and in certain instances  take enforcement actions, including the assessment of civil penalties, to  ensure compliance.
Our preliminary work has found that thirty states also employ railroad  safety inspectors, who participate in a partnership program with FRA to  conduct safety oversight activities, supplemental to FRA’s activities,  based on FRA rail safety regulations and to enforce state railroad safety  laws. FRA trains and certifies state inspectors and includes them in its  inspection planning efforts. However, FRA’s relationship and coordination  with each state is unique. For example, according to one state rail safety  administrator we talked to, the federal and state track inspectors have  divided one state’s territory to ensure that the inspectors’ territories do not  overlap. In addition, an FRA regional administrator mentioned that while  his FRA and state inspectors’ territories overlapped, effective coordination  between inspectors avoids duplicative inspections. According to FRA  officials, while state inspectors ensure compliance with state  requirements, state inspectors are also responsible for ensuring  compliance with federal safety regulations.
In addition to federal and state inspectors, the railroads have their own  inspectors who are responsible for ensuring that railroad equipment,  track, and operations meet federal rail safety standards. Each railroad  has its own inspectors or contracts with third parties to conduct the  required inspections depending on the railroad’s resources and FRA- mandated inspection responsibilities.
FRA is a small agency relative to the railroad industry, making the  railroads themselves the primary guarantors of railroad safety. Based on  our work to date, FRA has about 470 inspectors in its headquarters and  regional offices, in addition to about 170 state inspectors. In contrast,  the U.S. railroad system consists of about 760 railroads with about  230,000 employees and 200,000 miles of track in operation. FRA is also  responsible for developing and enforcing regulations for commuter  railroads and Amtrak. Amtrak and commuter railroads operating outside  of the Northeast Corridor operate largely over freight railroad tracks and  carry over 670 million passengers a year over 23 billion miles. The FRA  works with railroads to get their input on proposed regulations and rules  through the Railroad Safety Advisory Committee (RSAC) process.
Several railroad officials we spoke with thought that the RSAC process  was an improvement over the prior process, that they believe had been  less collaborative and did not promote discussions among FRA, the  railroads, and labor unions to share and understand each other’s views  on proposed federal railroad safety regulations.
In 2006, FRA implemented a risk-based approach, using its National  Inspection Plan (NIP), to allocate its limited inspection resources to  ensure rail safety. The NIP consists of three elements: (1) a baseline plan  that establishes safety goals for each railroad and state, (2) review and  adjustment by regional administrators, (3) monitoring and evaluation of  inspection activity.
The NIP’s baseline plan attempts to minimize the predicted number and  severity of railroad accidents given the number of available FRA  inspectors in each FRA region. The quantitative model uses data  including: 1) the most recent 3 years of accident data from reports that  railroads are required to file about accidents that occur on their tracks; 2)  data from FRA’s inspection activity; and 3) information on railroad  activities such as train miles and other data, to determine the scope of  what FRA’s inspectors should inspect in a given year. In the middle of  each calendar year, FRA updates the NIP with new accident data to  estimate where the highest safety risks are and uses the results to create  annual inspection targets for each inspector.
Our preliminary work indicates that after the baseline is established,  FRA’s regional management propose modifications to the inspection  targets produced for each region using their judgment and knowledge of  which railroads or disciplines may require more FRA oversight than the  NIP’s model indicates. Subsequently, FRA allows for a mid-year  correction of the NIP, based on input from FRA’s regional management.  FRA regional administrators we spoke with indicated that this flexibility  allows them to accommodate new or emerging rail safety risks by  deviating from the original NIP targets. For example, they stated that they  sometimes re-allocate inspectors to railroads that have had recent  accidents, or because inspectors indicate a need for more oversight at a  certain railroad based on assessments made during their regular  inspection duties. Additionally, the effects of hurricanes, storms, or  prolonged periods of adverse weather, such as heat or cold that could  cause track failures, may require the reallocation of inspection resources.  Throughout the year, FRA headquarters and regional management  monitor the inspection activities against the modified inspection baseline  to determine if the inspection targets are being met.
FRA has also developed the Staffing Allocation Model (SAM), which is a  planning and evaluation tool used to assess its inspection resources from  a nationwide perspective. Our work to date shows that FRA uses the  SAM to establish targets for the number of inspectors in each FRA region  and inspection discipline. In using the targets to help allocate and balance  staff among disciplines and regions, FRA expects to minimize the  resulting casualties and estimated costs of train accidents. FRA uses the  SAM results to determine where they may need to adjust the number of  inspectors in a given region and discipline. FRA rebalanced its workforce  using the SAM model in 2007 and officials stated that more recent SAM  results have not indicated the need for major movements of inspectors  between regions or disciplines. However, FRA officials stated that when  the SAM has shown a change in the distribution of their inspectors they  are somewhat constrained from implementing the model’s results due to  budget constraints. FRA officials also told us that while the SAM model  has been refined based on what they have learned from making  improvements to the NIP, the SAM is not designed to take into account  certain changes—such as increasing freight train volume or accidents in a  particular region—as the SAM uses past accident data to provide a  baseline for the nationwide distribution of its inspectors. FRA officials  stated that they handle those types of changes on an as-needed basis  through temporary detail assignment of FRA inspectors from other  regions or headquarters.
In addition, our preliminary review indicates that FRA regional  administrators also can provide input on the model’s results based on  their views on how many inspectors the region needs. However, FRA  regional officials we talked to stated that the staffing decisions based on  SAM results do not necessarily align their inspectors with their  perspective of the needs in their region nor does it take a region’s  geography into account. While FRA headquarters officials anticipate that  there may be minor variations from SAM’s targets as a result of natural  turnovers of inspectors (e.g., retirements), they do not believe that these  variations will have long-term impacts on FRA’s safety activities in the  regions. However, regional administrators expressed concern over the  staffing pressures this can create. For example, one FRA regional  administrator stated that when the staffing decisions did not provide for a  replacement for a certain discipline, he was forced to cover that  discipline’s inspection load with inspectors from other states for 3 years  until a replacement could be approved, hired, trained, and qualified.
As we continue our on-going work on rail safety oversight, we will further  assess how FRA officials use these tools to accommodate changing rail  safety risks and allocate inspectors across regions and inspection  disciplines.
section_title: FRA Faces Several Potential Challenges to Its Rail Safety Oversight Mission
paragraphs: Based on our work to date, we have identified several potential  challenges affecting FRA’s rail safety oversight, including lack of a final  rule requiring the submission of Risk Reduction Plans by specified  railroads, lack of succession planning to ensure sufficient staff numbers  and expertise, and other ongoing and emerging challenges.
RSIA required FRA to develop a rulemaking requiring certain railroads to  submit risk reduction plans, within 4 years of enactment, which was  October 2012. Our preliminary work has identified several reasons why  a final rule has not yet been issued, according to FRA, including the need  to resolve the issue of protection of sensitive business and safety  information in the railroad’s risk reduction plans. FRA officials told us that  these plans would allow them to have a more proactive view of rail safety  for these railroads that will complement FRA’s current compliance-based  approach. FRA officials also told us that they anticipate issuing a final rule  in September 2014 and that they expect that the railroads will have risk  reduction plans in place by 2016.
Our work to date has found that FRA does not yet have a specific plan to  replace its aging inspector workforce. According to FRA officials, in the  next 5 years, 150 of FRA’s 470 inspectors (about 32 percent) will be  eligible to retire. FRA officials told us, however, that they have been able  to find and hire qualified candidates in the past. However, other FRA  headquarters officials and regional administrators we spoke with stated  that replacing qualified inspectors is difficult, especially for the signal  discipline, and getting inspectors fully qualified takes time. For example,  FRA regional officials stated that it takes about 1 to 2 years to find, hire,  train, and certify a new experienced inspector and 3 to 4 years to get an  inexperienced trainee certified by FRA as a qualified inspector.  Additionally, FRA officials stated that budget constraints may prohibit their  current practice of hiring new inspectors before retiring inspectors leave  so that some overlap can occur to facilitate the transfer of knowledge.
Our preliminary work has identified several other ongoing and emerging  rail safety challenges that FRA faces.
The effects of weather on railroad operations are an ongoing  challenge. FRA and the railroads continuously keep abreast of  adverse weather conditions that can cause accidents, such as high  temperatures that can cause tracks to go out of alignment and cause  a derailment. FRA has issued several weather-related regulations  concerning tracks, operating practices, and railroad equipment, and  the railroads we spoke with adjust their operating practices to account  for adverse weather.
All rail safety stakeholders face the continued challenge of trying to  reduce highway-rail grade crossing and trespasser incidents.  Reducing these kinds of accidents represents a different challenge to  FRA’s current rail safety framework. Rail safety stakeholders stated  that this involves educating the general public about the potential  safety hazards that trains represent to cars, trucks, and pedestrians at  grade crossings as well as cooperating with several other federal,  state, and local government agencies that have responsibility for  funding road projects or closing those crossings. Changes to freight  flows, such as the recent increase in train and truck traffic  experienced due to increased gas and petroleum drilling in the upper  Midwest, can add train or truck traffic to previously low traffic areas  increasing the risk of highway-railroad grade crossing accidents.
New technologies, such as PTC systems, are another challenge that  FRA will have to incorporate into its rail safety oversight framework.  For example, because PTC systems are extremely complex  command, control, and communications systems, the FRA believes it  will require a specialized inspector workforce—which FRA currently  does not have—to provide adequate safety oversight.
As we continue our on-going work, we will further assess the extent to  which FRA is incorporating these existing and emerging challenges into  its safety oversight framework.
section_title: Most Railroads Report They Will Miss the 2015 PTC Implementation Deadline Due to a Number of Challenges
paragraphs: Our work to date indicates that most railroads will not complete PTC  implementation by the 2015 deadline due to numerous, interrelated  challenges caused by the breadth and complexity of PTC. Of the four  major freight railroads we included in our review, only one railroad  expects to meet the 2015 deadline. Of the three remaining freight  railroads we spoke to, representatives believe they will likely not have  PTC fully implemented until 2017 or later. Commuter railroads, which  primarily operate on routes that are owned and managed by freight  railroads, generally must wait for freight railroads and Amtrak to roll out  their PTC systems. Our preliminary analysis indicates that freight and  commuter railroads’ inability to meet the 2015 deadline is due to a  number of challenges.
Developing PTC components and PTC installation: Some PTC  components are still in development—most notably the PTC back- office server. One or more of these servers will be installed in over a  dozen railroads’ back offices and are needed to communicate vital  information between the back office, locomotives, and waysides.  According to the Association of American Railroads (AAR) and the  railroads, back office system delays are due to system complexity,  interfaces to other systems, and lack of supplier resources. Nearly all  of the freight railroads included in our review anticipate they will not  have a final version of the back office system until 2014 and have  identified it as one of the significant factors preventing them from  meeting the deadline. In addition, PTC installation is a time- and  resource-consuming process. For example, railroads collectively will  have to install approximately 38,000 wayside interface units.  According to AAR and freight railroads, the volume and complexity of  installing these units is another significant reason most railroads  cannot meet the 2015 deadline. Our ongoing work has found that  railroads have also encountered unexpected delays while installing  PTC. For example, in May 2013, FRA officials told us the Federal  Communications Commission (FCC) recently requested railroads to  halt their construction of radio antennae towers to allow FCC to clarify  regulatory oversight of the towers being installed for PTC. According  to FRA officials, FCC halted the construction of these towers to  ensure proper installation procedures were being followed including  consulting with either the tribal or state historical authorities prior to  the towers construction and installation. FRA officials told us they did  not anticipate this issue but are working with FCC to resolve it as  quickly as possible. However, the impact of halting construction on the  towers may result in additional delays in railroads’ time frames.
System integration and field testing: Our work to date indicates that  successful PTC implementation involves several components working  together, many of which are first-generation technologies being  designed and developed. All components must function both  independently and together, or the PTC system could fail. To ensure  successful integration, multiple testing phases must be conducted by  the railroads—first in a lab environment, then in the field—before  components are installed across the network. Most of the freight  railroads we spoke with expressed concern with the reliability of PTC  and emphasized the importance of field testing to ensure the system  performs the way it is intended. Multiple phases of testing must take  place to identify any defects, which then must be analyzed and  corrected, and the system re-tested. One railroad representative with  whom we spoke said that the PTC system components behaved  differently in some field tests than in the laboratory tests. Identifying  the source of such problems, correcting them, and re-testing could  further contribute to railroads not meeting the 2015 deadline.
FRA resources: Although most railroads we spoke with said they have  worked closely with FRA throughout the PTC implementation process,  some railroads cited concerns with FRA’s limited resources and the  agency’s ability to help facilitate railroads’ PTC implementation. Our  work to date indicates that these concerns were based around two  activities: field testing and certification. First, FRA officials must verify  the field testing of PTC. However, FRA reported that it lacks the  staffing resources to embed a dedicated FRA inspector at each  railroad for regular, detailed, and unfiltered reporting on a railroads’  PTC progress. To address the lack of staff to verify field testing, FRA  has taken on an audit approach, whereby railroads submit field test  results for approval as part of their safety plans. Second, a PTC  system must be certified before a railroad can operate it in revenue  service. FRA certifies a PTC system by approving a railroad’s safety  plan. FRA set no specific deadline for railroads to submit the safety  plans, and according to FRA, to date only one railroad has submitted  a final plan, which FRA has approved. As FRA stated in its 2012  report to Congress, FRA’s PTC staff consists of 10 PTC specialists  and 1 supervisor who are responsible for the review and approval of  all PTC system certification documentation for 38 railroads. FRA has  expressed concern that railroads will submit their safety plans to FRA  at roughly the same time. Our initial analysis suggests that this timing  creates the potential that FRA’s review of these plans will become  backlogged, since each of the railroad’s plans will consist of  hundreds, perhaps thousands, of pages of detailed technical  information. FRA officials told us that they are dedicated to the timely  approval of safety plans and that their oversight will not impede  railroads from meeting the deadline. However, railroads report that  their time frames are based on a quick turnaround from FRA; if quick  turnaround does not occur, it could further delay PTC  implementation.
Based on our work to date, it appears that commuter railroads face these  same PTC implementation challenges as well as others. First, because  commuter railroads are generally using the PTC systems developed by  freight railroads and Amtrak, they are captive in many respects to the  pace of development of these entities and have few means to influence  implementation schedules. In addition, commuter railroads also face  challenges in funding PTC implementation due to the overall lack of  federal, state, and local funding available to make investments in  commuter rail. According to the American Public Transportation  Association, PTC implementation will cost commuter railroads a minimum  of $2 billion. Commuter railroads are non-profit, public operations that are  funded by passenger fares and contributions from federal, state, and local  sources. Economic challenges such as the recession have eroded state  and local revenue sources that traditionally support commuter rail capital  expenses, and competing expenses such as state of good repair  upgrades, leaving the commuter railroads limited in their funding to  implement PTC.
Finally, commuter railroads report that obtaining radio frequency  spectrum—essential for PTC communications—can be a lengthy and  difficult process. The FCC has directed commuter railroads to secure  spectrum on the secondary market. According to the FCC, spectrum is  available in the secondary market to meet PTC needs. While freight  railroads have secured most of the spectrum needed for PTC  implementation, commuter railroads have reported difficulty acquiring  spectrum in the 220 MHz band, which is required to operate the data  radios that communicate information between PTC components. In  particular, railroad officials have said that obtaining spectrum is a critical  challenge in high density urban areas. Based on our preliminary work,  without acquiring sufficient spectrum, railroads may be unable to  adequately test their PTC systems, potentially causing further delays in  meeting the 2015 PTC deadline.
Our work to date also indicates that by attempting to implement PTC by  the 2015 deadline, railroads may be making choices that could introduce  financial and operational risks to PTC implementation. Representatives  from freight railroads and FRA told us railroads will not compromise the  safety functions of the PTC system and will ensure that PTC is  implemented meeting RSIA requirements. However, freight railroad  representatives also told us that they compressed time frames and  undertook processes in parallel rather than sequentially— potentially  increasing the financial and operational risk of PTC implementation. For  example, railroads took a “double touch” approach to equipping  locomotives, which involves taking locomotives out of service twice in  order to begin installation while software was being developed. Railroad  representatives told us this approach is more expensive than installing  the equipment once after the software is fully developed, as it involves  more labor hours and more time that locomotives are offline rather than in  operation. In addition, representatives from all freight railroads we spoke  to expressed concern regarding the reliability of PTC and noted the  importance of field testing as much as necessary to identify and correct  problems. These representatives noted that without adequate testing,  PTC systems could potentially malfunction or fail more frequently,  causing system disruptions. FRA officials also expressed concern that if  pressured to meet the 2015 deadline, railroads may rush through field  testing and potentially implement a PTC system that is not entirely  reliable leading to operational inefficiencies through slower trains or  congestion.
In its August 2012 report to Congress, FRA identified areas for  consideration in the event that Congress chooses to amend RSIA.  Specifically, FRA requested the authority to extend the deadline for  certain rail lines, grant provisional certification of PTC systems and  approve the use of alternative safety technologies in lieu of PTC. FRA  officials told us these authorities could enable them to conduct oversight  more effectively by acknowledging the current state of PTC  implementation and better manage FRA’s limited resources. Although to  date there are few details on how these authorities would be applied,  according to FRA officials, these authorities could assist in better  managing resources allowing the agency to oversee and manage PTC  implementation past the current deadline of December 31, 2015.
Based on our preliminary work, it appears unlikely that PTC will be  implemented by more than a few railroads by the December 31, 2015,  deadline. As we have discussed, PTC implementation is a massive,  complex, and expensive undertaking—with valid challenges to meeting  the deadline. However, although most railroads will not meet the PTC  deadline, it does not necessarily suggest that they have not made a  concerted effort to make progress in the implementation of PTC.  Railroads and FRA both report continuing to search for ways to speed  progress while maintaining safe rail operations in order to achieve  complete deployment as soon as possible. Nonetheless, given the state  of PTC technology and the myriad of PTC components that are required  to work seamlessly in order for PTC to work reliably, concerns regarding  the potential risks railroads may be taking in attempting to meet the  deadline should be considered. Accordingly, FRA has requested  authorities that could provide railroads the flexibility they need to  successfully implement PTC.
Chairman Blumenthal, Ranking Member Blunt, and Members of the  Committee, this concludes my prepared remarks. I am happy to respond  to any questions that you or may have at this time.
section_title: GAO Contact and Staff Acknowledgments
paragraphs: For further information regarding this testimony, please contact Susan  Fleming at (202) 512-2834 or flemings@gao.gov. Contact points for our  Office of Congressional Relations and Public Affairs may be found on the  last page of this statement. Individuals who made key contributions to this  statement include Susan Zimmerman (Assistant Director), Melissa  Bodeau, Richard Bulman, Aisha Cabrer, Robert Ciszewski, Tim Guinane,  Greg Hanna, Emily Larson, Sara Ann Moessbauer, Faye Morrison, Josh  Ormond, Sharon Silas, and Crystal Wesco.
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