Positive Train Control: Additional Authorities Could Benefit Implementation
Published: 2013-08-16T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In the wake of a 2008 commuter train collision that resulted in 25 fatalities, RSIA was enacted. It requires major freight railroads, Amtrak, and commuter railroads to install PTC on many major routes by the end of 2015. PTC implementation, overseen by FRA, is a complex endeavor that touches almost every aspect of train operations on major lines. According to FRA, 37 railroads are required to implement PTC. GAO was asked to examine the status of PTC implementation. This report discusses, among other things, railroads' implementation of PTC to date and the challenges, if any, to meeting the 2015 deadline. GAO interviewed representatives from Amtrak, the four largest freight railroads, and seven commuter railroads, selected to represent a mix of locations, ridership levels, and PTC implementation status. GAO also interviewed PTC experts and suppliers, and reviewed FRA's PTC regulatory impact analyses.
section_title: What GAO Found
paragraphs: To install positive train control (PTC)--a communications-based system designed to prevent certain types of train accidents caused by human factors-- almost all railroads are overlaying their existing infrastructure with PTC components; nonetheless, most railroads report they will miss the December 31, 2015, implementation deadline. Both the Association of American Railroads (AAR) and the Federal Railroad Administration (FRA) have reported that most railroads will not have PTC fully implemented by the deadline. Of the four major freight railroads included in GAO's review, only one expects to meet the 2015 deadline. The other three freight railroads report that they expect to have PTC implemented by 2017 or later. Commuter railroads generally must wait until freight railroads and Amtrak equip the rail lines they operate on, and most of the seven commuter railroads included in this review reported that they do not expect to meet the 2015 deadline. To implement PTC systems that meet the requirements of the Rail Safety Improvement Act of 2008 (RSIA), railroads are developing more than 20 major components that are currently in various stages of development, integrating them, and installing them across the rail network. AAR recently reported that by the end of 2012, railroads had spent $2.8 billion on PTC implementation. To implement PTC, AAR estimates that freight railroads will spend approximately $8 billion in total while the American Public Transportation Association (APTA) estimates that commuter railroads will spend a minimum of $2 billion. Much of the work to implement PTC remains to be done. For example, AAR reported that as of the end of 2012, about a third of wayside interface units, which are needed to communicate data, had been installed and that less than 1 percent of locomotives needing upgrades had been fully equipped.
Most railroads report they will not complete PTC implementation by the 2015 deadline due to a number of complex and interrelated challenges. Many PTC components continue to be in various stages of development, and in order to ensure successful integration of these components, railroads must conduct multiple phases of testing before components are installed across the network. Also, some railroads raised concerns regarding FRA's limited staff resources in two areas: verification of field tests and timely certification of PTC systems. Commuter railroads face additional challenges such as obtaining radio frequency spectrum, which is essential for PTC communications. By attempting to implement PTC by the 2015 deadline while key components are still in development, railroads could be introducing financial and operational risks. For example, officials from railroads and FRA said that without adequate testing, PTC systems might be more prone to reliability issues. To mitigate risks, provide flexibility in meeting the PTC deadline, and better manage limited resources, FRA has requested that Congress amend RSIA to provide additional authorities in implementing PTC. Specifically, FRA requested authority to extend the deadline on certain rail lines, grant provisional certification of PTC systems, and approve the use of alternative safety technologies in lieu of PTC. Flexibility in extending the deadline for certain railroads acknowledges differences in railroads' implementation schedules and may also help FRA better manage its limited resources by, for example, preventing a potential review backlog resulting from most of the railroads' submitting final safety plans at the same time--a concern raised by both freight railroads and FRA.
section_title: What GAO Recommends
paragraphs: Given the implementation challenges railroads face in meeting the deadline, and to help FRA manage its limited resources, Congress should consider amending RSIA as FRA has requested. Specifically, Congress should consider granting FRA the authority to extend the deadline on certain rail lines on a case-by-case basis, grant provisional certification of PTC systems, and approve the use of alternative safety technologies in lieu of PTC to improve safety. DOT reviewed a draft of this report and provided technical comments, which were incorporated as appropriate.

section_title: Letter
paragraphs: In September 2008, a commuter train collided with a freight train in the  Chatsworth neighborhood of Los Angeles, California, resulting in 25  deaths and over 100 injuries. In the wake of this accident, which was  caused by the operator missing a red signal, the Rail Safety Improvement  Act of 2008 (RSIA) was enacted. RSIA mandated the implementation of  positive train control (PTC) systems by December 31, 2015, on  “mainlines” used to transport inter-city rail passengers, commuters, or any  amount of certain toxic materials. PTC is a communications-based  system designed to prevent certain types of rail accidents caused by  human factors, including train-to-train collisions; trains entering  established work zones, which could cause roadway worker casualties or  equipment damage; and derailments caused by exceeding safe speeds.  PTC technology can automatically slow or stop a train that is not being  operated safely due to some types of operator errors or a switch left in the  wrong position.
PTC system implementation is a complex and costly endeavor that  touches almost every part of major rail lines and almost every aspect of  their train operations. Railroad representatives and experts have reported  that PTC implementation is the biggest change in the railroad industry  since it transitioned from steam to diesel locomotives in the mid-20th  century. According to FRA, railroads required to implement PTC must do  so on over 60,000 of approximately 160,000 miles of track nationwide. In  addition, FRA has reported that railroads must design, produce, and  install more than 20 major PTC components, such as data radios for  locomotive communication, locomotive management computers, and  back office servers as part of the PTC implementation.
We, along with the Federal Railroad Administration (FRA), have noted the  challenges railroads face in implementing PTC by the 2015 deadline. In  December 2010, we reported that much work remained for railroads to  meet the 2015 implementation deadline. Likewise, in August 2012, FRA  issued a report to Congress and concluded that, due to many obstacles,  the majority of railroads will be unable to meet the deadline. Congress  has considered, but has not passed, extensions to this deadline.
FRA provides regulatory oversight of U.S. railroad safety and is  responsible for overseeing PTC implementation. As part of its  implementation of RSIA, FRA conducted three rulemakings and analyzed  the economic impact of two final rules. FRA’s economic analyses of these  rules calculated the costs of PTC implementation and discussed various  benefits that railroads may attain by implementing PTC. Such benefits  could include avoided property damage levels due to the avoidance of  accidents and operational efficiencies from PTC that could result in cost  savings to the railroad, known in the industry as “business benefits.”  Railroad industry representatives testified before Congress that PTC will  not result in business benefits and that business benefits can be achieved  through other means, such as technologies independent of PTC.
To better understand the impact of RSIA and FRA’s associated  rulemakings on railroads, you asked us to examine the status of PTC  implementation and the costs and benefits of the PTC rule, including  business benefits. This report discusses (1) how railroads are  implementing PTC and the challenges, if any, to meeting the 2015  implementation deadline, and (2) FRA’s estimates of the benefits and  costs of PTC and the extent to which railroads might be able to leverage  PTC technology to achieve business benefits.
To examine how railroads are implementing PTC, and any challenges  they are facing, we reviewed documents and interviewed officials from  FRA and representatives from railroad associations including the  Association of American Railroads and American Public Transportation  Association. We interviewed representatives from the four largest freight  railroads—BNSF Railway, CSX Corporation, Union Pacific, and Norfolk  Southern. We interviewed representatives from seven commuter  railroads, which we selected to represent a range of geographic locations,  levels of ridership, PTC implementation status, and operations, including  those operating on tracks owned by all four of the largest Class I railroads  and the National Passenger Railroad Corporation (Amtrak). We also  interviewed Amtrak representatives. We interviewed or received written  responses to our interview questions from PTC suppliers and  independent PTC experts that we selected based on involvement with  PTC and recommendations from FRA, associations, and others.
To determine how FRA estimated the benefits and costs of PTC, we  interviewed FRA officials and experts, among others, and evaluated  proposed and final regulatory impact analyses for the 2010 and 2012  PTC rules. We reviewed the regulatory analyses supporting the rules  using standard economic principles and Office of Management and  Budget (OMB) economic guidance (Circular A-4) as criteria. See  appendix I for more detailed information about our scope and  methodology.
We conducted this performance audit from October 2012 to August 2013  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
subsections: section_title: Railroads and Supporting Infrastructure
paragraphs: The U.S. railroad industry consists mostly of freight railroads but also  serves passengers. Freight railroads are divided into classes based on  revenue. Class I freight railroads earn the most revenue and generally  provide long-haul freight service. Freight railroads operate over  approximately 160,000 miles of track and own most of the track in the  United States; a notable exception is the Northeast Corridor, between  Washington, D.C., and Boston, Massachusetts, which Amtrak  predominantly owns. Amtrak provides intercity passenger rail service in  46 states and the District of Columbia and operates on 21,000 miles of  track. Commuter railroads serve passengers traveling within large  metropolitan areas and most operate over track infrastructure owned by  Amtrak or freight railroads for at least some portion of their operations.  Specifically, 9 commuter railroads operate over Amtrak-owned  infrastructure. Sixteen commuter railroads operate over infrastructure  owned by freight railroads.
U.S. freight and passenger trains often share track, dispatchers, and  signals that control train movement. Some railroads also use additional  technologies to improve efficiency and achieve business benefits.  Currently, dispatchers in centralized offices issue train movement  authorities that allow trains to enter specific track segments, or blocks.  These authorities are communicated to train operators through signals  alongside the track, or in non-signaled territory through track warrants  generally issued by verbal radio communication (see fig. 1).Railroads also  use additional technologies to maximize operational efficiencies. These  include:
Computer-assisted dispatching so dispatchers can, among other  things, optimally synchronize schedules, allowing trains on single  track to “meet and pass” one another safely and efficiently, thereby  minimizing delays and improving on-time performance.
Energy management systems that analyze train location and track  grade and curvature information to calculate the train’s most fuel- efficient speed throughout the trip.
These technologies can lead to business benefits for the railroad as well  as benefits for society at large. As we have reported in the past, diversion  of freight traffic from highways to rail potentially increases highway safety  and reduces highway congestion and energy consumption.
Although train accidents have generally been on the decline in recent  years, human factors such as train operators missing a red signal or  exceeding allowable speeds, or train crews leaving a switch in the wrong  position can lead to significant damage and loss of life. Overall, rail  safety—measured by the train accident rate per million train miles—has  improved markedly since 1980. According to FRA data, 2012 was the  safest year in railroad history. Even with the significant reduction in  accident rates, on average almost 300 people were reported injured and  about 10 people were reported killed in train accidents each year, from  2003 through 2012.
PTC is a computer-based technology that uses a communications system  to monitor and control train movements to minimize human factor errors.  Prior to the enactment of the RSIA in 2008, railroads developed and  tested several PTC systems but deployed them on a limited basis. For  example, in 1998, while Amtrak was upgrading the Northeast Corridor to  enable operation of high-speed passenger trains—a service known today  as Acela—FRA directed Amtrak to install a new train control system on  some portions of the corridor as a safety measure. Amtrak worked with  suppliers to develop a form of PTC—known as Advanced Civil Speed  Enforcement System (ACSES)—and deployed this system on the  Northeast Corridor.
section_title: Railway Safety Improvement Act of 2008
paragraphs: In wake of the Chatsworth rail accident in September 2008 and other  high-profile rail accidents, RSIA was enacted. RSIA, among other things,  required railroads to install PTC by December 31, 2015, on mainlines  used to transport inter-city rail passengers, commuters, or any amount of  toxic-by-inhalation materials. RSIA requires railroads to install PTC  systems, which are designed to prevent train-to-train collisions and  derailments caused by exceeding safe speeds. PTC must also be  designed to protect rail workers by preventing trains from entering work  zones as well as to prevent the movement of trains through switches left  in the wrong position. PTC’s communications-based system links various  components, namely locomotive computers, wayside units along the side  of the track, and dispatch systems in centralized office locations (see fig.  2). Through these components, PTC is able to communicate a train’s  location, speed restrictions, and movement authorities, and can slow or  stop a train that is not being operated safely. For example, a PTC system  could have prevented the 2008 Chatsworth accident by first alerting the  operator that the train was approaching a red signal and then stopping  the train before passing the red signal. However, it should be noted that  there are types of accidents, such as highway-railroad crossing accidents  and trespasser deaths, that PTC technology is not designed to prevent.  According to FRA, highway-railroad crossing and trespasser deaths  account for 95 percent of all rail-related fatalities.
RSIA does not require railroads to implement the same PTC system;  however, the various PTC systems must meet the PTC system  functionality requirements. There are two primary ways PTC can be  implemented—as an overlay or as a standalone system. An overlay  system involves installing PTC over existing track equipment to work in  conjunction with the existing signal system and the train’s current method  of operations. A standalone system involves taking information currently  communicated through the signal system and putting it onboard the  locomotive, effectively eliminating the need for the existing signal system.  Whatever PTC system a railroad implements, RSIA requires that systems  be interoperable, meaning they must be able to communicate with one  another so trains can seamlessly move across track owned by different  railroads with potentially different PTC systems. Interoperability is  important given that, according to FRA, there are 37 freight, intercity  passenger, and commuter railroads that are required to implement PTC.
To implement the requirements of RSIA, FRA has conducted three  rulemakings that resulted in: (1) a 2010 final rule, (2) a 2012 final rule,  and (3) a 2012 Notice of Proposed Rulemaking (NPRM), which is  currently not finalized (see fig. 3). In the original 2010 rule, FRA used  facts and data known in 2008 to determine where PTC implementation  should occur. Recognizing that traffic levels and routing could change  between 2008 and the statutory deadline in 2015, the 2010 rule provided  railroads with the option to request an amendment to not equip a track  segment where the railroad was initially required to install PTC, but may  no longer be required to do so. In order for certain rail segments to be  excluded, the segments would need to pass two qualifying tests. After  FRA finalized the 2010 rule, the Association of American Railroads (AAR)  challenged the two qualifying tests in a lawsuit, and FRA and AAR  entered into a settlement agreement in which FRA agreed to propose  elimination of the tests. The two qualifying tests were eliminated in the  2012 final rule; as a result, railroads do not have to implement PTC on rail  segments that will not transport toxic-by-inhalation materials or  passengers as of December 31, 2015. The FRA rulemaking that is  currently under way addresses how railroads will handle en-route failures  of PTC equipment, among other things.
In accordance with Executive Order 12866, FRA prepared economic  analyses—also known as regulatory impact analyses—to assess the  benefits and costs of PTC before promulgating regulations. Specifically,  FRA issued two regulatory impact analyses evaluating final rules—one  dated December 2009 evaluating the 2010 final rule and one dated  January 2012 evaluating the 2012 final rule. Executive orders and OMB  guidance direct agencies to assess the benefits and costs of regulatory  alternatives. Agencies should generally select the regulatory approach  that maximizes net benefits to society, unless a statute requires  otherwise. OMB developed guidelines to encourage good regulatory  impact analysis and to standardize the way that benefits and costs of  federal regulations are measured and reported. OMB guidelines  generally direct agencies, in analyzing the impacts of rules, to, among  other things: measure the potential social benefits and costs of regulatory  alternatives incremental to a “baseline,” (i.e., the conditions that would  exist in the absence of the proposed regulation); analyze a range of  alternatives; identify and quantitatively analyze key uncertainties  associated with the estimates of benefits and costs; and provide  documentation that the analysis is based on the best reasonably  obtainable scientific, technical, and economic information available. OMB  guidelines further state that a good regulatory analysis includes  identifying the regulatory alternative with the largest net benefits to  society. It also states that such information is useful for decision makers  and the public, even when economic efficiency is not the only or the  overriding public policy objective.
As part of overseeing railroads’ progress with PTC implementation, FRA  is also responsible for reviewing railroads’ PTC-related plans. Railroads  must submit and FRA must review and approve three plans: a PTC  development plan, a PTC implementation plan, and a PTC safety plan.
The PTC development plan describes, among other things, the PTC  system a railroad intends to implement to satisfy the PTC regulatory  requirements. According to its August 2012 report, FRA’s approval of  the development plans took nearly 18 months to complete.
The PTC implementation plan describes a railroad’s plan for  installation of its planned PTC system. RSIA required railroads to  submit these plans within 18 months (by April 16, 2010), and FRA to  review and approve or disapprove them within 90 days.
The PTC safety plan includes a railroad’s plans for testing the  system, as well as information about safety hazards and risks the  system will address, among other things. By approving a safety plan,  FRA certifies a railroad’s PTC system, a precondition for operating the  PTC system in revenue service. Although FRA set no specific  deadline for railroads to submit the safety plans, according to FRA,  railroads must submit their safety plans with sufficient time for  approval before the December 31, 2015, PTC implementation  deadline. In its August 2012 report, FRA reported to need about 6 to 9  months to review each safety plan.
section_title: Almost All Railroads Are Installing PTC Overlay Systems but Face Challenges in Meeting the 2015 Implementation Deadline
subsections: section_title: Railroads Are Generally Implementing PTC as an Overlay System for Feasibility Reasons
paragraphs: Although there are two primary types of PTC systems—overlay and  standalone— that functionally meet the PTC requirements in RSIA,  almost all railroads required to install PTC are installing overlay systems.  Railroad representatives told us they chose to install PTC as an overlay  system because it was more feasible to meet the PTC implementation  deadline than a standalone system. An overlay system allows railroads to  install PTC components over existing rail infrastructure and operate the  train in accordance with the existing signals and operations in the event of  a PTC system failure.
Of the various PTC overlay systems that have been developed, all seven  major freight railroads in the United States plan to implement  Interoperable Electronic Train Management System (I-ETMS), which will  account for most of the approximately 60,000 miles. Amtrak is  implementing Advanced Civil Speed Enforcement System (ACSES) on  the Northeast Corridor. Although ACSES and I-ETMS are functionally  similar, they differ technologically. To determine train location, ACSES  relies on track-embedded transponders while I-ETMS uses Global  Positioning System (GPS) information (see fig. 4). Since most commuter  railroads run over tracks owned by freight railroads or Amtrak, they are  largely implementing the same systems developed by the freight railroads  or Amtrak. For example, eight commuter rail systems that operate over  Amtrak infrastructure on the Northeast Corridor—including major  commuter systems in the New York City, Philadelphia, and Boston  areas—are installing ACSES.
FRA has reported that in order to implement PTC, railroads must design,  produce, and install more than 20 major components such as data radios  for locomotive communication, locomotive management computers, and  back office servers. Once these components are developed and  integrated, PTC must then be installed on rail lines throughout the  country, which involves upgrading and installing thousands of items, as  well as replacing approximately 12,000 signals (see table 1). Adding to  the complexity of PTC installation is the need to ensure that individual  railroad systems are fully interoperable, which requires that the potential  problems across railroads be identified, isolated, and corrected through  testing in labs and in the field.
Railroads have invested billions in PTC implementation to-date, but  anticipate spending billions more. In May 2013, AAR reported that by  the end of 2012, railroads had spent about $2.8 billion on PTC  implementation. According to AAR, the total cost to freight railroads for  PTC implementation is estimated to be approximately $8 billion. Despite  the billions railroads have invested, much of the work to implement PTC  remains to be done. For example, AAR reported that as of the end of  2012, about a third of wayside interface units— which are needed to  communicate data—had been installed. In addition, AAR reported that as  of the end of 2012, less than 1 percent of locomotives needing upgrades  had been fully equipped.
section_title: Most Railroads Report They Will Miss the 2015 PTC Implementation Deadline Due to a Number of Challenges
paragraphs: Most railroads report they will not complete PTC implementation by the  2015 deadline due to numerous interrelated challenges caused by the  breadth and complexity of PTC. Both AAR and FRA have reported that  most railroads will not have PTC fully implemented by the deadline. Of  the four major freight railroads we included in our review, BNSF is the  only railroad expecting to meet the 2015 deadline. According to BNSF  representatives, it is on schedule to meet the 2015 deadline because of  its extensive experience working on PTC prior to RSIA, its iterative build  and test approach, and the concurrent development of its PTC  dispatching and back office systems. Of the three remaining freight  railroads we spoke to, representatives believe they will likely have PTC  fully implemented by 2017 or later. In addition, while Amtrak officials  report that they anticipate full PTC implementation on their Northeast  Corridor and Michigan lines by the end of 2015, they noted it is unlikely  they will have equipped the approximately 300 locomotives that will run  on I-ETMS freight lines by the deadline. Commuter railroads generally  must wait to equip their locomotives until freight railroads and Amtrak  equip the rail lines that commuter railroads generally operate on. Four of  the seven commuter railroads we included in our review reported that  they will be unable to meet the 2015 PTC implementation deadline.
Challenges to meeting the 2015 deadline are complex and interrelated.  For instance, many of the PTC components had not been developed  before RSIA was enacted, and some continue to be in various stages of  development. In addition, all components, once developed must be  assembled and integrated to achieve the overall safety function of PTC.  Likewise, the steps involved with implementing PTC are interrelated, with  delays or problems with one component or process resulting in additional  delays. Railroad representatives told us that once all the components  have been assembled, integrated, and tested for reliability, rolling out and  phasing in a PTC system into each railroad’s network will take a  considerable amount of time. For example, Amtrak first conducted a  demonstration test of its PTC system on its Michigan line in 1996, but it  was 5 years later, in 2001, when the system was put into service.  Finally, FRA’s resources and ability to help facilitate implementation by  the 2015 PTC deadline are limited. Below is a discussion of these key  interrelated challenges.
Developing system components and PTC installation. Some PTC  components are still in development, most notably the I-ETMS 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 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 critical factors  preventing them from meeting the deadline. In addition to component  development, 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 signals  is another significant reason most railroads cannot meet the 2015  deadline. Railroads have also encountered unexpected delays while  installing PTC. For example, the Federal Communications  Commission (FCC) recently requested railroads halt their construction  of radio antennae towers to allow FCC to consider how to implement  oversight of the towers being installed for PTC. According to FRA and  AAR officials, FCC requested that railroads halt construction on  antennae towers that have not gone through the environmental  evaluation process, including tribal notice, while FCC considers ways  to streamline the process. FRA officials told us they did not  anticipate this issue. AAR and FRA officials report they are working  together with FCC to find a solution that meets the goals behind the  process while still allowing for timely PTC deployment. However, the  impact of halting construction on the towers may result in additional  delays in railroads’ time frames.
System integration and field testing. Successful PTC implementation  will require numerous components to work together, many of which  are first-generation technologies being designed and developed for  PTC. All components must properly function when integrated or the  PTC system could fail. To ensure successful integration, railroads  must conduct multiple phases of testing—first in a laboratory  environment, then in the field—before installation across the network.  Representatives from all of the freight railroads we spoke with  expressed concern with the reliability of PTC and emphasized the  importance of field testing to ensure that the system performs the way  it is intended and that potential defects are identified, corrected, and  re-tested. One railroad representative we spoke with said that in some  field tests, the PTC system components behaved differently than in  the laboratory tests because labs do not reflect field conditions  completely. Identifying the source of these types of problems is an  iterative process; consequently, correcting the problems and re- testing can be time-consuming and potentially 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 staffing resources.  These concerns focused on two of FRA’s responsibilities. First, FRA  officials must verify 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  railroads’ PTC progress. To address the lack of staff to verify field- testing, FRA has taken an audit approach to field testing, whereby  railroads submit field test results for approval as part of their safety  plans and FRA staff select plans to evaluate the accuracy of the  results. Second, before a railroad can operate a PTC system in  revenue service, it must be FRA certified, and FRA must approve the  railroad’s final 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 safety plan, which FRA has approved.  As it reported 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 final safety plans. FRA also reported  that this work covers the 37 railroads implementing PTC on over  60,000 miles of track. FRA and railroads have expressed concern that  railroads will submit their final safety plans to FRA at approximately  the same time, resulting in a potential review backlog particularly  since each plan is expected to consist of hundreds 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 in approvals from FRA. If approvals are delayed, it could  be a further setback in railroads’ PTC implementation.
Generally commuter railroads face these same PTC implementation  challenges, as well as others. First, because commuter railroads are  using the PTC systems developed by freight railroads and Amtrak, they  are captive in many respects to the pace of developments of those  entities and have few means to influence implementation schedules.  Commuter railroads also face challenges in funding PTC implementation  due to the overall lack of federal funding available to make investments in  commuter rail and limited sources of revenue. Most 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 supported capital expenses. In addition, according the  American Public Transportation Association (APTA), commuter railroads  face competing expenses such as state of good repair upgrades, leaving  them with limited funding to implement PTC. According to APTA,  collectively, PTC implementation will cost commuter railroads a minimum  of $2 billion. Finally, commuter railroads report that obtaining radio  frequency spectrum—essential for PTC communications—can be a  lengthy and difficult process. FCC 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 megahertz (MHz) band, which is required to operate  the data radios that communicate information between PTC  components. In particular, railroad representatives said that obtaining  spectrum is a critical challenge in high-density urban areas. Without  acquiring sufficient spectrum, railroads may be unable to adequately test  their PTC systems, potentially causing further delays in meeting the 2015  PTC deadline.
By attempting to implement PTC by the 2015 deadline while key  components are still in development, railroads may be making choices  that could introduce financial and operational risks to PTC  implementation. Representatives from freight railroads and FRA officials  told us that railroads will not compromise the safety functions of the PTC  system and will ensure that systems meet the functionality requirements  in RSIA. However, freight railroad representatives told us that in order to  work towards testing and installation, they compressed time frames and  undertook processes in parallel rather than sequentially. For example, to  begin installation while key components were being developed, railroads  took a “double touch” approach to equipping locomotives, which involves  taking locomotives out of service twice to begin installation while software  was being developed. Railroad representatives told us this approach is  more expensive than installing the equipment after the software is fully  mature, as it involves more labor hours and more time that locomotives  are out of service. Our prior work on weapon systems development has  shown that technologies that were included in a product development  program before they were mature later contributed to cost increases and  schedule delays. This work showed that demonstrating a high level of  maturity before new technologies are incorporated into a product  development plan increases the chances for successful implementation.  In 2010, we reported that railroads expected key PTC components to be  available by 2012. Railroads have subsequently reported that PTC  installation has involved many delays, particularly in component  development and many of the essential components are still in  development. Consequently, product maturity remains an issue for some  PTC components and may result in additional cost and schedule  overruns.
The development time frames involved in implementing PTC by the end  of 2015 also potentially introduce operational risks. Representatives from  all of the freight railroads we spoke with expressed concern regarding the  reliability of PTC and noted that adequate field testing was important to  identify and correct problems. These representatives noted that without  adequate testing, PTC systems may not perform as planned and may be  more prone to system reliability issues, possibly causing service  disruptions. FRA officials also expressed concern that if pressured to  meet the 2015 deadline, railroads might implement an unreliable PTC  system that breaks down and leads to operational inefficiencies through  slower trains or congestion.
section_title: FRA’s Request for Legislative Changes to Provide Additional Authority in Overseeing PTC’s Implementation Could Help Manage PTC Implementation
paragraphs: In an August 2012 report to Congress, FRA identified three items for  consideration in the event Congress amends RSIA. FRA officials told us  that if Congress chooses to amend RSIA, additional authority to extend  the deadline on certain rail lines, grant provisional certification of PTC  systems and approve the use of alternative safety technologies in lieu of  PTC would help them to conduct oversight more effectively by providing  FRA flexibility in overseeing PTC. Specifically FRA requested the  authority to:
Extend the deadline on certain rail lines to grant railroads incremental  deadlines on a case-by-case basis. FRA officials told us they do not  want a deadline extension applied to the whole railroad industry.  Rather, FRA would like flexibility to create new deadlines based on an  individual railroad’s circumstances, particularly a railroad’s due  diligence to achieve the 2015 deadline and efforts to mitigate risks.  FRA officials said currently they are unable to approve implementation  plans that give completion dates beyond 2015. FRA officials said that  such a change would require railroads to update their implementation  plans.
Grant provisional certification of PTC systems under controlled  conditions before final system completion to allow railroads to operate  PTC in certain places while they are still developing it in other places.  According to FRA, this would provide assurance that the PTC system  was safe, so that a railroad could begin to use the PTC system while  FRA reviewed the railroad’s full safety plan. FRA and railroads told us  the benefit of this authority is that it would allow railroads and the  public to experience the safety benefits of PTC sooner. FRA officials  said they believed this would provide railroads with additional time to  address issues and would lead to the implementation of a more  reliable system.
Approve the use of alternative safety technologies in lieu of PTC to  allow railroads to improve safety and meet many of the functions of  PTC through other means. FRA officials told us that they would  anticipate using this authority only for commuter and some smaller  railroads and would consider technologies in combination with  operating rules that railroads demonstrate would enhance safety.
Although some freight railroad representatives we spoke with supported  providing FRA with additional authority, others voiced concerns about  how the authorities would be administered. For example, details such as  how FRA will identify and apply criteria to determine which railroads  should receive extensions would need to be addressed. In addition, one  freight railroad representative raised concerns over timeliness of FRA’s  determinations of deadline extensions. Furthermore, representatives from  another railroad suggested that granting deadline extensions to some  railroads unfairly penalizes those railroads that may meet the PTC  deadline. FRA could not provide us with specific information detailing how  these authorities would be applied. However, if Congress were to amend  RSIA in order to provide FRA additional authorities in implementing PTC,  the Secretary of Transportation would need to direct FRA to develop new  regulations or orders, in order to carry out its duties.
At a June 2013 hearing on rail safety, AAR and APTA stated their support  for FRA’s request for additional authority and extending the PTC  implementation deadline to December 31, 2018, for all railroads. In  addition, FRA recommended the Secretary of Transportation be given the  authority to grant railroads extensions beyond a December 2018  deadline. In particular, AAR stated its support for FRA’s request for  flexibility to extend the deadline and previously noted that FRA’s request  to provide provisional certification of PTC systems could reduce delays.  According to AAR, these authorities could provide some relief to railroads  experiencing challenges meeting the deadline. APTA, representing  commuter railroads, also supported FRA’s request for additional authority  and specifically stated its support that FRA be allowed to consider  alternative technologies in lieu of a PTC system on specified line  segments. According to APTA’s testimony statement, some commuter  railroads already have collision avoidance systems in place that protect  against train-to-train collisions. According to APTA, allowing FRA to  examine the feasibility of alternative technologies to PTC for some of the  smaller railroads on a line-by-line basis could provide opportunities to free  up PTC components for other railroads to expedite their PTC  implementation.
While an extension of the PTC implementation deadline may provide  railroads with additional time to implement PTC, it is not clear that all  railroads would be able to meet a revised December 31, 2018 deadline  proposed by AAR and APTA. For example, AAR’s May 2013 report  predicts that, while PTC could be in operation on most mandated PTC  routes by December 31, 2018, the date PTC will be in operation on all  routes would vary by railroad. One freight railroad we spoke to anticipated  it would not be able to fully implement PTC until 2020. In addition, given  that many commuter railroads are waiting for freight railroads to develop  and implement PTC, many commuter railroads will likely have PTC fully  installed after the freight railroads. Furthermore, in a hearing statement,  AAR recommended flexibility beyond December 2018 due to the  unprecedented nature of PTC and the uncertainties — both known and  unknown—of implementation.
Given the uncertainties in implementing PTC and the unexpected delays  already encountered, additional challenges could prevent railroads from  meeting a new deadline. However, FRA’s request for additional authority  could provide railroads the flexibility to implement PTC on individual,  case-by-case deadlines, either instead of or in addition to an overall  deadline extension. Additional authority could also assist FRA in  managing its limited staff resources and help railroads mitigate risks and  ensure PTC is implemented in a safe and reliable manner. For example,  although at the June 2013 rail safety hearing concerns were raised that  providing railroads deadline extensions on a case-by-case basis would be  resource-intensive and could provide additional challenges and delays,  we found that railroads were at various stages in their implementation.  Flexibility in extending the deadline for certain railroads acknowledges  these differences and also may help FRA better manage limited  resources by, for example, preventing a potential review backlog resulting  from final safety plans being submitted at the same time—a concern  raised by freight railroads and FRA. In addition, according to FRA,  allowing provisional certification of PTC systems not only helps to  manage limited resources, it also reflects good engineering practice in  implementing wide-ranging, complex systems and is a well documented  risk mitigation strategy. Finally, as outlined in APTA’s testimony at the  June 2013 hearing on rail safety, allowing some railroads to use  alternative technologies on certain lines could provide relief to other  railroads struggling to procure certain PTC components.
section_title: FRA Found the Costs of Implementing PTC Outweigh the Safety Benefits, but Opportunities May Exist to Pursue Future Business Benefits
subsections: section_title: FRA Estimated That the Costs of PTC Implementation Far Outweigh the Safety Benefits
paragraphs: FRA’s final regulatory impact analysis for the 2010 final rule estimated  that the costs of PTC installation far outweigh the safety benefits. FRA’s  regulatory impact analysis presents an analysis of the costs and benefits  associated with implementing a PTC system on qualifying rail segments.  FRA estimated the total costs of implementing PTC to be about $13.2  billion and the total safety benefits to be about $674 million. Costs FRA  anticipated to accrue to railroads through the implementation of PTC  included: development of implementation plans and administrative functions  related to the implementation and operation of PTC systems,  including the information technology and communication systems that  make up the central office; hardware costs for onboard locomotive-system components, including hardware costs for wayside system components, including installation; maintenance costs for all system components.
FRA expects that PTC implementation will generate safety benefits from  the reduction in the risk of certain types of accidents and the number and  severity of casualties caused by train accidents on lines equipped with  PTC systems. FRA also estimated benefits related to accident  preventions that are anticipated to accrue, such as reductions in property  damage, equipment cleanup, environmental damage, train delays  resulting from track closures, road closures, emergency response, and  evacuations. In addition to these safety benefits, FRA’s regulatory impact  analysis stated that after PTC systems are refined, business benefits  resulting from more efficient railroad operations could be forthcoming.  FRA did not, however, include business benefits in its impact analysis  estimates because of significant uncertainties regarding whether and  when such benefits would be achieved.
section_title: FRA Generally Followed OMB Guidance in Assessing the Benefits and Costs of PTC Implementation
paragraphs: We found that FRA generally followed OMB guidance in assessing the  benefits and costs of implementing PTC, and although we generally  agree with FRA’s estimation that costs likely outweigh benefits, we are  not confident in the precision of the specific estimates of costs and  benefits. Specifically, we compared FRA’s regulatory impact analyses  with key elements of OMB guidelines, including establishing a baseline,  considering alternatives, analyzing uncertainty and quantifying key  categories of costs and benefits. We identified some limitations in the  analyses, for example, analyses are not comprehensive in some respects  and the source and quality of some of the underlying data is unclear.  According to FRA officials, the limitations in its analysis and data do not  affect the primary outcome of the analysis— that total costs are expected  to exceed total safety benefits (i.e., that there are negative net societal  benefits). Based on our review, we also believe the limitations we  identified were not significant enough to affect FRA’s general  determination that PTC’s implementation costs outweigh benefits. (See  app. II for more detail on our assessment of FRA’s regulatory impact  analyses and findings.)
The PTC mandate limited the flexibility and time available to FRA to  develop a rule and analyze its economic impacts; nonetheless, more  thorough analyses and better quality data could have made the benefit  cost analysis more useful in discussions of PTC implementation. FRA’s  PTC rulemaking was initiated to implement PTC, as required by RSIA.  Specifically, RSIA mandated the installation of a PTC system, which can  achieve certain safety benefits, and specified the system’s functional  requirements and the 2015 implementation deadline. FRA had little  latitude to implement other, non-PTC alternatives that may have been  less costly to achieve the same safety benefits. In addition, FRA officials  told us that because the PTC rulemaking process was expedited, they  had to use the information that was available to them at the time to  conduct their analysis. However, we found that some information was up  to 10 years old and the quality of some of the underlying data was  unclear. Finally, FRA excluded business benefits from its estimates,  instead opting to include a discussion of potential business benefits in an  appendix to its analysis. FRA officials said that they excluded business  benefits from their analysis due to uncertainty about whether and when  business benefits could be achieved. While we found this decision was  appropriate, we found limitations to the discussion of business benefits.  For example, FRA assumed that railroads would achieve business  benefits associated with a standalone PTC system, but did not include  supporting evidence that railroads would likely install such a system.
section_title: PTC Alone Is Unlikely to Generate Business Benefits, but Opportunities Might Exist to Pursue Business Benefits over Time and with Additional Investment
paragraphs: Although an overlay PTC system alone is not expected to generate  business benefits, over time and with additional investments, there may  be opportunities for railroads to achieve some business benefits. PTC  implementation involves upgrades that railroads could integrate with  existing technologies to provide operational enhancements. As previously  discussed, railroads are making substantial investments in their rail  network infrastructure to implement PTC. These investments include (1)  upgrading existing wayside and office subsystem components; (2)  installing a new communication infrastructure to facilitate the  communication of train speed, train location, work zone and switch  information; (3) and developing detailed geographical information  systems (GIS) mappings of an entire rail network. The first two  investments can help to generate information that can be shared with  other applications, such as train dispatching software and energy  management systems to potentially produce business benefits while the  detailed GIS mapping can be used to support a railroad’s state of good  repair.
More specific train location and speed data for use in other applications  such as precision dispatching could help to improve train dispatching,  potentially increasing network capacity.  The PTC overlay systems  railroads are installing require changes to most dispatching systems to  account for more precise train location information. For example,  according to AAR and FRA, most railroad dispatching systems, which  currently require location information within one-tenth of a mile, are being  upgraded as part of PTC to require location information of up to a ten- thousandth of a mile. According to a freight railroad representative we  spoke to, using the more detailed train location information from PTC  could help dispatchers better prioritize train movements based on a train’s  delivery schedule and better manage “meet and pass” operations (when  two trains approach each other on a single track). PTC, however, is not a  prerequisite for precision dispatching. For example, one freight railroad  representative told us that their railroad is already using alternative  means independent of PTC to enable real-time train position reporting to  improve dispatching. Nonetheless, the PTC system that is being installed  is also expected to provide this information. In addition, according to a  supplier we included in our review, PTC could enable development of  additional features, such as precision dispatching. Representatives from  another supplier we spoke with said they anticipate that railroads will use  PTC-generated train location information for improved dispatching in the  future after the initial rollout of PTC.
PTC-generated information and data also could help railroads achieve  greater fuel savings than they are currently achieving with their energy  management systems. An energy management system is an on-board  technology that uses a variety of information, including train location and  track elevation and curvature, to calculate a train’s most fuel efficient run  and make throttle and braking recommendations to the operator to  minimize a train’s consumption of fuel. PTC can generate information  that could assist energy management systems in two ways. First, PTC  systems are being designed to enforce compliance with safety  parameters, such as speed restrictions, that trains encounter when  traveling from origin to destination. According to an energy management  system supplier and freight railroad representatives we spoke with, these  parameters could be used to make train movement calculations based on  the PTC safety parameters governing the route, which is information  currently unavailable to such systems. Second, railroads are developing  more detailed mapping of their rail networks, including its critical features  such as signals and switches and putting this information into a track  database as part of PTC implementation. According to an energy  management system supplier we spoke with, this more precise  information, which is needed for the PTC system to calculate train safety  stopping distances could enhance railroads’ existing fuel-management  systems’ performance through more accurate information on track  features.
Representatives from all of the freight railroads we spoke with reported  already achieving fuel savings through energy management systems but  noted that there may be potential for additional savings by integrating  these systems with these PTC components. For example, one freight  railroad representative reported that the railroad’s energy management  system currently provides annual fuel savings of 4 to 6 percent, but that  integrating the system with PTC could lead to an additional 1 to 2 percent  in fuel savings.
Freight railroad officials we spoke with generally expressed interest in  pursuing PTC-related business benefits, but noted they are currently  focused on installing PTC and are devoting their time and resources to  that effort. For example, one freight railroad representative told us the  railroad has not had time to fully think through how to achieve business  benefits using the PTC system since all resources are currently focused  on implementing PTC and noted that these benefits were incremental and could likely be achieved outside of PTC. However, railroad  representatives from the four freight railroads we spoke with said they  would explore ways to leverage the safety investment they are making in  PTC to obtain additional business benefits once the PTC system is fully  implemented and operating. These railroads emphasized that pursuing  business benefits will involve additional investments beyond their current  investments in PTC installation.
Nevertheless, railroad representatives also identified a number of  concerns about attempting to achieve business benefits through PTC  systems. First, some business benefits are already being achieved  through existing technologies. Second, the potential for significant PTC  business benefits is still not clear. For example, according to one railroad  representative, despite his railroad’s long history with PTC, it is still  unsure of the potential for PTC to achieve business benefits. PTC is a  new technology, and system components are still being developed. After  the safety functionalities of the system have been tested and deployed,  representatives will be able to determine what additional functionality  (e.g., operational efficiencies) can be achieved through PTC  implementation. In addition, additional functionalities to achieve PTC  business benefits must be done in a way that would not compromise the  system’s underlying safety functions. FRA officials told us that when  integrating PTC with other systems to achieve business benefits,  railroads must be careful not to compromise the integrity of PTC system’s  underlying safety functions. According to a PTC supplier, delaying the  introduction of any business benefit features to the PTC system may help  railroads avoid complicating the initial deployment of PTC.  Representatives from one freight railroad we spoke with anticipated that  railroads would, with additional investment, begin to achieve business  benefits through PTC over the next two decades as PTC is fully installed  and operational.
section_title: Conclusions
paragraphs: In the wake of the 2008 Chatsworth commuter rail accident that resulted  in 25 deaths and over 100 injuries, RSIA was enacted, marking a public  policy decision that rail safety warranted mandatory and accelerated PTC  system installation. PTC implementation is a massive, complex, and  expensive undertaking. Amid numerous implementation challenges, it  appears that most railroads will not fully implement PTC by the December  31, 2015, deadline. Given the state of PTC technology and the myriad of  PTC components that must seamlessly work together, the potential risks  railroads may be taking in attempting to meet the deadline should be  considered. Accordingly, FRA has requested additional authorities which  could allow FRA to better manage its limited resources and give railroads  the flexibility to take a more measured approach to PTC implementation,  potentially mitigating some implementation risks. AAR and others have  proposed extending the PTC implementation deadline to December 31,  2018, and agree that providing FRA with additional authorities could  increase flexibility in managing PTC implementation. Given all the  uncertainties in implementing PTC technology, it is not clear 2018 will be  sufficient time for railroads to fully implement PTC. Consequently,  Congress, the railroads, and FRA may end up in the same position they  are currently in, with an impending deadline and not enough flexibility to  ensure that all railroads fully implement PTC both reliably and  expediently. Regardless of whether the deadline is extended for the  industry as a whole or FRA is given the flexibility to grant extensions to  railroads on a case-by-case basis—upon consideration of railroads’ due  diligence in implementing PTC—action is needed to help FRA better  manage its limited resources and address the reality of PTC  implementation, which is that different railroads are at different stages.
section_title: Matters for Congressional Consideration
paragraphs: To help ensure that the Federal Railroad Administration manages its  limited resources and provides flexibility to railroads in implementing PTC,  Congress should consider amending RSIA as requested in the FRA’s  August 2012 PTC Implementation Status Report to Congress, including  granting FRA the authority to: extend the deadline on individual rail lines—when the need to do so  can be demonstrated by the railroad and verified by FRA—to grant  railroads incremental deadlines based on a case-by-case basis; grant provisional certification of PTC systems under controlled  conditions before final system completion; and approve the use of alternative safety technologies in lieu of PTC to  allow railroads to improve safety and meet many of the functions of  PTC through other means.
section_title: Agency Comments
paragraphs: We provided a draft of this report to the Secretary of Transportation for  review and comment. DOT provided technical comments, which we  incorporated as appropriate.
As agreed with your office, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to the Secretary of  Transportation and other interested parties. In addition, the report will be  available at no charge on the GAO website at http://www.gao.gov.
If you or your staff have any questions about this report, please contact  me at (202) 512-4431 or flemingS@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made major contributions to  this report are listed in appendix III.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: This report discusses (1) how railroads are implementing positive train  control (PTC) and the challenges, if any, to meeting the PTC  implementation deadline; and (2) FRA’s estimates of the benefits and  costs of PTC and the extent to which railroads might be able to leverage  PTC technology to achieve business benefits.
To obtain information about how railroads are implementing PTC and the  challenges to meeting the PTC implementation deadline, we interviewed  representatives from the four largest Class I freight railroads—BNSF  Railway, CSX Corporation, Norfolk Southern, and Union Pacific—and  Amtrak. We also interviewed representatives from seven commuter  railroads:
Massachusetts Bay Transportation Authority (Boston, Massachusetts)
Metropolitan Transportation Authority (MTA) Long Island Railroad  (New York, New York)
MTA Metro-North Railroad (New York, New York)
Southern California Regional Rail Authority, also known as Metrolink  (Los Angeles, California)
Southeastern Pennsylvania Transportation Authority (SEPTA)  (Philadelphia, Pennsylvania),
Utah Transit Authority (Salt Lake City, Utah)
Virginia Railway Express (Washington, D.C.)
We selected the commuter railroads to represent a range of geographic  locations, levels of ridership, and PTC implementation status, while  selecting railroads that had a mix of operations, including those operating  on tracks owned by all four of the largest Class I railroads and Amtrak.  We also interviewed or received written responses from representatives  from selected rail supply companies (New York Air Brake, Wabtec,  MeteorComm, and Parsons); railroad industry associations (the  Association of American Railroads (AAR), the American Short Line and  Regional Railroad Association, and American Public Transportation  Association (APTA)); the Chlorine Institute; six experts; and FRA. We  selected the railroad supply companies based on the types of products  and services provided, railroad clients, and recommendations from FRA,  associations, and experts. We selected experts based on their experience  working on PTC, independence from current PTC work, and  recommendations from associations and other experts. We also reviewed  PTC development and implementation requirements in the Rail Safety  Improvement Act of 2008 and FRA regulations; FRA’s 2012 report to  Congress on Positive Train Control Implementation Status, Issues, and  Impacts; and prior GAO reports. We attended the Railway Age  International Conference on Communications-Based Train Control in  Washington, D.C., and the National Transportation Safety Board Forum  on Positive Train Control Implementation. We visited and met with  officials at Southern California Regional Rail Authority, in Los Angeles,  California, and Amtrak officials in Wilmington, Delaware, to witness  computer simulations of PTC and view PTC track side components. In  addition, we visited and met with officials at SEPTA in Philadelphia,  Pennsylvania.
To understand how FRA estimated the benefits and costs of PTC in its  rulemakings we reviewed the 2010 and 2012 PTC rules and the  supporting proposed and final regulatory impact analyses, and  interviewed representatives from the FRA. To review the quality of the  regulatory impact analyses, we used key elements in the OMB economic  guidelines (Circular A-4) as criteria, including: use of appropriate baseline  from which to estimate benefits and costs; assessment of a range of  alternatives; inclusion of all key categories of benefits and costs; use of  best available information in analyzing benefits and costs; and analysis of  uncertainty. In addition, to better understand the potential economic effect  of the rules, and the changes that FRA made in response to comments,  we reviewed public comments submitted to FRA in response to the  rulemakings, and we interviewed FRA officials, stakeholder groups (AAR,  the Chlorine Institute), PTC technology and railroad industry experts,  economists, and railway supply companies. We did not independently  analyze the benefits and costs of FRA’s PTC regulations. Since the  rulemaking is in response to a mandate, we focused on the information  contained in the benefit cost analyses and did not comment on the overall  rule.
To determine the extent to which railroads might be able to leverage PTC  technology to achieve business benefits we interviewed representatives  from the previously mentioned Class I freight railroads, Amtrak, 7  commuter railroads, association officials, experts, railroad supply  companies, and FRA to learn about plans to leverage PTC to achieve  business benefits as well as existing technologies that could potentially  be used to achieve business benefits. We reviewed documentation from  an array of sources, including FRA, AAR, the Chlorine Institute, and PTC  experts to determine the types of technology that could potentially be  used to achieve PTC business benefits and the extent railroads can  leverage PTC technology to achieve business benefits.
section_title: Appendix II: Observations on the Quality of FRA’s Regulatory Impact Analyses Used in PTC Rulemaking
paragraphs: FRA issued regulatory impact analyses that examined the economic  impact of the implementation of RSIA and generally found that the costs  far outweighed the benefits of PTC installation. Specifically, the  December 2009 final regulatory impact analysis concluded that the costs  to comply with the regulation far exceeded the safety benefits of PTC.  The January 2012 final regulatory impact analysis evaluated the costs  and benefits of the final rule (i.e., to eliminate the two risk-based tests for  exempting certain rail segments from the PTC requirement) and found  that the benefits, which were the costs saved by installing PTC on fewer  rail lines, outweigh the costs, which were the increased risk for train  incidents as a result of PTC no longer being required along 10,000 miles  of track. However, this final rule did not alter the conclusions of the  December 2009 analysis conclusion that the costs of PTC far outweighed  the safety benefits.
We reviewed FRA’s 2009 and 2012 regulatory impact analyses using  OMB guidance for developing regulatory impact analyses and found that  although FRA generally followed OMB guidance in assessing the costs  and benefits of implementing PTC, the quality of some of the underlying  data suggests some limitations in the analyses. Specifically, we found:
Although FRA established a baseline and considered one alternative,  an analysis of other alternatives in the implementation of PTC may  have been useful.
FRA analyzed uncertainty associated with cost estimates, but not with  safety benefit estimates.
FRA included key costs in its analysis, but excluded the cost of  implementation to the government.
Data and computations underlying the analysis were not clearly  sourced and explained, and for some data, the quality was unclear  resulting in a lack of transparency.
See Table 2 for a discussion of these findings, including the OMB  guidance, what FRA did in the December 2009 analysis, what FRA did in  the January 2012 analysis, and our analysis.
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Sharon Silas, Assistant Director;  Richard Bulman; Tim Guinane; Delwen Jones; Emily Larson; Sara Ann  Moessbauer; Josh Ormond; Madhav Panwar and Crystal Wesco made  key contributions to this report.