Washington Metropolitan Area Transit Authority: Improved Planning of Future Rehabilitation Projects Could Prevent Limitations Identified with SafeTrack
Published: 2017-03-14T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Recent inquiries into WMATA's Metrorail system have revealed a range of serious safety issues. In response to some of these issues, as well as a backlog of track maintenance, WMATA announced in May 2016 that it was undertaking SafeTrack, a large-scale rehabilitation project. The SafeTrack project is overseen by FTA.
GAO was asked to review a range of safety and oversight issues regarding WMATA. This report examines the extent to which WMATA's (1) planning and (2) implementation of SafeTrack was consistent with leading project management practices as well as (3) the steps taken by FTA to oversee SafeTrack.
GAO reviewed documentation on WMATA's planning and project implementation, and FTA's oversight of SafeTrack. GAO also interviewed officials from WMATA, FTA, and local jurisdictions, and compared WMATA's planning and implementation of SafeTrack to leading project management practices developed by professional organizations.
section_title: What GAO Found
paragraphs: The Washington Metropolitan Area Transit Authority's (WMATA) planning of SafeTrack did not fully align with leading project management practices. While WMATA generally followed leading practices to coordinate with stakeholders, it did not comprehensively collect and use data on the condition of its assets, analyze project alternatives, and develop a project management plan before starting work. WMATA did not follow these practices because it believed it needed to start work immediately to address critical safety issues.
Although WMATA inspected its track assets when planning SafeTrack, those inspections were not comprehensive and did not collect detailed data on the condition of all track infrastructure, such as all “interlockings,” where trains cross from one track to another. As a result, WMATA's decision makers may not have used sufficient information to develop project objectives and to properly prioritize SafeTrack work.
Though WMATA developed three alternatives for SafeTrack, it did not determine the costs and impacts of each alternative, or assess them to determine which approach may have resulted in greater efficiencies, lower costs, or less disruption for riders and local jurisdictions.
Before WMATA began SafeTrack, it lacked a comprehensive project management plan, which is a key tool to ensure a project is completed on-time, within-budget, and according to quality standards.
WMATA does not have a policy that requires, and includes relevant procedures for how to carry out, these planning activities for large-scale rehabilitation projects. Without such a policy and procedures, WMATA lacks a framework to plan future rehabilitation projects so that they achieve their objectives.
WMATA's implementation of SafeTrack generally aligned with leading project management practices. Specifically, WMATA officials collected information on the work performed and the condition of assets repaired during SafeTrack. WMATA officials also collect lessons learned during and after each surge, and use those lessons during subsequent maintenance and planning efforts. Additionally, WMATA developed a new organization-wide quality control and assurance framework and is implementing it for the first time through SafeTrack.
The Federal Transit Administration (FTA) has used safety inspections and other tools to oversee SafeTrack and direct WMATA to undertake safety-critical work. FTA has relied on two different authorities to oversee SafeTrack: (1) FTA's public transportation safety oversight authority, and (2) its project management oversight authority. Prior to the start of SafeTrack and during the project, FTA conducted safety inspections and directed WMATA to make repairs to reduce the risk of smoke and fires on the rail system. After SafeTrack work began and estimated project costs exceeded $100 million, FTA determined SafeTrack to be a major capital project, triggering the statutory requirement that WMATA prepare a project management plan. WMATA did not submit its project management plan until 4 months into SafeTrack. FTA found the plan lacked sufficient detail, and WMATA told GAO it is working to improve the plan.
section_title: What GAO Recommends
paragraphs: GAO recommends that WMATA develop a policy that requires and includes procedures for it to, prior to starting future large-scale rehabilitation projects: (1) use asset data to develop project objectives; (2) analyze alternatives; and (3) develop a project management plan for those projects that may not be designated as major capital projects. WMATA agreed with GAO's findings and said that it is working to address the recommendations.

section_title: Letter
paragraphs: In May 2016, the Washington Metropolitan Area Transit Authority  (WMATA) announced it was undertaking SafeTrack, a large-scale  rehabilitation project for its rail infrastructure. Recent inquiries into  WMATA’s rail system—the nation’s second-busiest—by the National  Transportation Safety Board (NTSB) and others have revealed a range of  serious safety issues in WMATA’s Metrorail system. In response to some  of these issues, as well as its backlog of track work, WMATA intends,  through SafeTrack, to complete three years of track infrastructure  rehabilitation in approximately one year. According to WMATA, SafeTrack  is a unique effort, designed to address urgent safety issues with railroad  track assets. SafeTrack will be funded by federal grants, as well as  contributions from the three local jurisdictions that are signatories to the  interstate compact governing WMATA—the District of Columbia,  Maryland, and Virginia. WMATA’s planning and implementation of  SafeTrack is overseen by the Department of Transportation’s (DOT)  Federal Transit Administration (FTA).
You asked us to review various safety and oversight issues at WMATA,  including how SafeTrack was planned and implemented. We examined:  1.  The extent to which WMATA’s planning of the SafeTrack project was  consistent with leading project management practices;   2.  The extent to which WMATA’s implementation of SafeTrack was  consistent with these practices; and,  3.  The steps that were taken by FTA to oversee SafeTrack.
To address our first two research questions on SafeTrack’s planning and  implementation, we examined documentation on how WMATA planned  SafeTrack, including the alternative plans it developed, as well as how it  carried out work for SafeTrack. We also examined FTA’s project  construction guidelines and its quality management guidelines for their  applicability to SafeTrack work. We also examined WMATA  documentation on the quality control and quality assurance frameworks in  place for SafeTrack as well as the results of WMATA’s own SafeTrack  quality reviews. We also obtained and summarized data from WMATA on  work tasks planned for and completed during SafeTrack. Based on  interviews with WMATA officials, we determined that these data were  sufficiently reliable for our purpose of summarizing work planned and  completed to date under SafeTrack. Further, we examined the results of  FTA’s inspections of WMATA track infrastructure. We also reviewed  recent investigations and studies regarding WMATA, including those from  the American Public Transportation Association, DOT’s Office of  Inspector General (OIG), NTSB, and WMATA’s OIG.
To further address our first two research objectives, we interviewed  officials from WMATA and other organizations. Specifically, we  interviewed WMATA officials about actions they took to plan and  implement SafeTrack. We also interviewed officials from the DOT’s OIG,  FTA, NTSB, and WMATA’s OIG about their work with WMATA and  perspectives on SafeTrack. Additionally, we interviewed officials from  local jurisdictions (the District of Columbia; Montgomery County,  Maryland; and Fairfax County, Virginia) about the coordination and  communication between them and WMATA officials concerning  SafeTrack. We also interviewed officials from the Chicago Transit  Authority (CTA), Massachusetts Bay Transportation Authority (MBTA),  New York City Transit (NYCT, part of the Metropolitan Transportation  Authority), and Port Authority Trans-Hudson (PATH, part of the Port  Authority of New York and New Jersey) about their experiences planning  and implementing large-scale rehabilitation projects. We selected these  transit agencies based on their similarity to WMATA in terms of total  ridership, heavy rail track and passenger miles, as well as whether they  have carried out or are currently undertaking large-scale rehabilitation  projects akin to SafeTrack. In selecting these transit agencies we also  considered geographic diversity and the views of the American Public  Transportation Association officials on WMATA’s “peers.” Though we  believe these transit agencies provided relevant and diverse perspectives  on carrying out transit rehabilitation projects, the information gathered  from these entities is not generalizable to all transit agencies. We did not  evaluate or compare the number or type of safety incidents at these other  transit systems to those at WMATA.
For the first two research questions, we compared WMATA’s planning  and implementation of SafeTrack to leading project management  practices identified by the Project Management Institute (PMI) in its A  Guide to the Project Management Body of Knowledge (PMBOK®  Guide), and by the Transit Cooperative Research Program (TCRP) in its  Report 157, which focuses on rehabilitation of transit assets. We  compared WMATA’s SafeTrack project to those leading practices  identified by PMI and TCRP that we determined were most relevant to the  planning and implementation of large-scale rehabilitation projects, such  as SafeTrack. We consider these documents to be relevant summaries of  leading project management practices for transit agencies and  appropriate to large-scale rehabilitation projects, such as SafeTrack.  Further, WMATA indicated to us that the PMI PMBOK® Guide and the  TCRP report are appropriate references for the future state of good repair  work. We also evaluated WMATA’s efforts based on internal control  frameworks published by the Committee of Sponsoring Organizations of  the Treadway Commission (COSO), which WMATA uses as criteria for its  internal control evaluations.
To address our third research objective on FTA’s oversight of SafeTrack,  we examined FTA and WMATA documents and interviewed various  officials. We examined: (1) FTA documents related to its oversight of  major capital projects and SafeTrack specifically, (2) relevant federal  statues and FTA regulations governing transit agencies and projects, and  (3) WMATA documents related to FTA’s oversight of SafeTrack.  Additionally, we interviewed FTA and WMATA officials about FTA’s  oversight of WMATA and SafeTrack.
We conducted this performance audit from August 2016 to March 2017 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
paragraphs: WMATA’s Metrorail system has experienced a variety of serious safety  incidents in recent years (see fig. 1 below). On June 22, 2009, one  Metrorail train struck the rear of a second train stopped near the Fort  Totten station on the Red Line, resulting in nine deaths and over 50  injuries. The NTSB report on the incident found that WMATA failed to  institutionalize, and employ system-wide, an enhanced track-circuit  verification test procedure that was developed following near-collisions in  2005. NTSB also found evidence of an ineffective safety culture within  WMATA. More recently, WMATA has experienced smoke and fire  incidents involving the electrical cables and other components supporting  its third-rail system. On January 12, 2015, a Metrorail train stopped after  encountering heavy smoke in the tunnel between the L’Enfant Plaza  station and the Potomac River Bridge on the Yellow Line caused by  electrical arcing resulting from a short circuit on the third rail power  system, causing one passenger’s death and numerous injuries. In a  report on this incident, the NTSB again found a lack of a safety culture  within WMATA. NTSB specifically noted deficiencies in WMATA’s  response to smoke reports, tunnel ventilation, railcar ventilation,  emergency response, as well as the oversight and management of  WMATA. In November 2015, WMATA’s new General Manager began his  tenure and initiated a variety of efforts to address WMATA’s Metrorail  safety issues. On March 14, 2016, an electrical fire occurred near the  McPherson Square station involving the same kind of power cable that  caused the L’Enfant Plaza smoke incident. Following this fire, WMATA  closed the entire Metrorail system for a day for emergency inspections of  the system’s third-rail power cables.
On May 19, 2016, WMATA announced SafeTrack, “a massive,  comprehensive, holistic effort to address safety recommendations and  rehabilitate the Metrorail system on an accelerated basis by expanding all  available maintenance windows.” The primary focus of SafeTrack is  rehabilitating Metrorail’s track infrastructure by replacing over 45,000  crossties, which are the wooden beams that lay across the railroad bed  on above ground sections of the track, and 35,000 fasteners, which  secure rails directly to concrete on underground or aerial sections of the  track where wooden crossties are not used. SafeTrack is being carried  out through a series of “surges” that involve intensive work on specific  areas of track that are either shut down to normal traffic or have only one  of the two tracks open, a type of operation known as “single tracking” (see  fig. 2 below). SafeTrack also involves the reduction of operating hours to  allow additional work to be carried out overnight and on weekends in non- surge areas. Although the primary focus of SafeTrack is track assets,  WMATA is also using the extended outages to address other safety  concerns, such as concerns regarding power cables and other electrical  components raised by NTSB and FTA. According to WMATA’s initial  announcement, the project was designed to bring Metrorail’s track  infrastructure to a “state of good repair,” which WMATA defines as the  condition at which individual railroad assets can be sustained at ongoing,  annual replacement rates under normal maintenance cycles.
WMATA estimates that SafeTrack will cost approximately $120 million.  According to WMATA and FTA officials, these costs will be covered by  about $48 million in federal funding, which includes two FTA formula  grants as well as funding authorized by the Passenger Rail Investment  and Improvement Act of 2008 (PRIIA). The PRIIA funding is also  matched by over $30 million in local funds from the three jurisdictions that  help fund WMATA. Beyond the almost $80 million in federal and local  matching funds, SafeTrack will require an additional $40 million in fiscal  year 2017 funding; according to WMATA, the sources of this funding are  yet to be finalized. Although SafeTrack was not specifically included in  WMATA’s approved fiscal year 2016 or 2017 budgets, WMATA amended  and its board approved its fiscal year 2017 budget, in November 2016, to  include additional funding for the project. WMATA’s track rehabilitation  projects and other capital investments are made through a 6-year Capital  Improvement Program, with the current version covering fiscal years 2017  through 2022.
Other transit agencies with aging infrastructure like WMATA have also  undertaken, or plan to carry out, large-scale rehabilitation projects that  involve extended disruptions to normal revenue service. For example, in  2013 CTA shut down the southern half of one of its lines for 5 months to  completely rebuild the railroad and renovate rail stations on the branch.  Additionally, NYCT is planning to shut down the Canarsie subway tunnel  connecting Manhattan and Brooklyn to facilitate extensive repairs from  damage caused by Hurricane Sandy in 2012. Similarly, the Port Authority  of New York and New Jersey is rehabilitating tunnels used by its PATH  service between New Jersey and Manhattan and installing positive train  control technology, which can reduce the risk of accidental collision  between trains on the same track.
In recent years, FTA has been provided with an expanded role in  overseeing public transportation safety within WMATA and in other transit  agencies. The Moving Ahead for Progress in the 21st Century Act (MAP- 21) expanded FTA’s safety oversight role over public transportation  systems and established the public transportation safety program,  providing FTA with new authority to inspect and audit a public  transportation system. This new authority also required FTA to  promulgate regulations requiring states to establish state safety oversight  programs and agencies for states’ public transportation systems.  Additionally, MAP-21 provided FTA with more safety oversight authority  and more options for enforcement when transit agencies were found to be  out of compliance with federal safety laws. For example, in response to  concerns regarding WMATA’s safety performance over the last decade,  FTA conducted a Safety Management Inspection of the WMATA rail and  bus systems. The Safety Management Inspection evaluated WMATA’s  operations and maintenance programs, safety management capabilities,  and organizational structures. FTA found that, in recent years, WMATA  has implemented new management initiatives and programs to address  safety concerns, but organizational deficiencies and operational concerns  continue to limit WMATA’s effectiveness in recognizing and resolving  safety issues. For example, FTA found that WMATA work crews do not  have sufficient access to the rail right-of-way to perform critical inspection,  testing, and maintenance activities. FTA also found serious safety lapses  in the rail operations control center. More broadly, FTA also reported that  in key areas, WMATA’s organization is not effectively balancing safety- critical operations and maintenance activities with the demand for  passenger service.
In response to WMATA safety incidents, FTA assumed temporary and  direct safety oversight of WMATA in October 2015. Specifically, as part of  its investigation of the January 2015 smoke and fire incident near the  L’Enfant station, NTSB found that the Tri-State Oversight Committee’s  safety oversight of WMATA was deficient and recommended that DOT  seek an amendment to federal law so that the Federal Railroad  Administration within DOT could exercise regulatory oversight over the  WMATA rail system. DOT agreed that the Tri-State Oversight  Committee was deficient and ineffective, but disagreed with NTSB that  the most urgent and effective solution was to transfer safety oversight of  WMATA’s rail transit system to the Federal Railroad Administration.  Instead, in October 2015, DOT directed FTA to take direct and temporary  control of safety oversight at WMATA from the Tri-State Oversight  Committee. To perform direct safety oversight of WMATA, FTA  established the FTA WMATA Safety Oversight (FWSO) office, which is  currently comprised of FTA personnel, inspectors on detail from FRA, and  contractor support staff, according to FTA officials. In February 2016, FTA  found the Tri-State Oversight Committee was incapable of enforcing its  safety findings and thus, using new authority provided by the Fixing  Americas Surface Transportation (FAST) Act, FTA determined that it  would continue with its direct safety oversight of WMATA.
FTA’s FWSO and region three office, which includes the Washington  metropolitan area, have jointly managed oversight of SafeTrack. When  WMATA announced SafeTrack in May 2016, the FWSO was in place and  performed initial safety oversight of the project. However, FTA’s various  regional offices exercise project management oversight over “major  capital projects,” which include, among other things, projects that involve  the rehabilitation or modernization of an existing fixed guideway with a  total project cost in excess of $100 million. Using this project  management oversight authority for major capital projects, FTA can  monitor the project’s progress to determine whether a project is on time,  within budget, in conformance with design criteria, constructed to  approved plans and specifications, and is efficiently and effectively  implemented. According to FTA officials, FTA designated SafeTrack as  a major capital project based upon WMATA’s decision to group together  funding from multiple FTA formula grants, as well as funding authorized  by PRIIA, and to manage those activities as a discrete project estimated  to cost more than $100 million. FTA’s region three office provides project  management oversight of SafeTrack.
FTA has other efforts to improve the safety and performance of public  transportation systems. For example, in July 2016, FTA issued its final  rule establishing a National Transit Asset Management System in  accordance with section 20019 of MAP–21. Transit agencies are  required to have an initial transit asset management plan completed by  October 2, 2018. Transit agencies’ plans must include an inventory of  the number and type of capital assets and a condition assessment of  those inventoried assets for which a provider has direct capital  responsibility, among other elements. In August 2016, FTA also issued  a Public Transportation Safety Program final rule establishing rules to  support its administration of the public transportation safety program.  The rule provides the framework for FTA to monitor and enforce transit  safety.
section_title: WMATA Did Not Fully Follow Leading Practices When Planning SafeTrack Because It Wanted to Address Safety Issues Immediately, but Future Projects Could Benefit from Additional Planning
paragraphs: WMATA’s planning of SafeTrack did not fully align with leading project  management practices, including some that are focused on projects for  rehabilitating transit assets. Specifically, while WMATA’s efforts to  coordinate with local stakeholders after SafeTrack began have generally  been in line with such practices, WMATA did not (1) comprehensively  collect and assess data on its assets, (2) analyze alternatives, or (3)  develop a project management plan before starting work. WMATA did not  follow these practices because it believed it needed to start work  immediately to address critical safety issues. However, by not following  these leading practices, WMATA lacks assurance that the accelerated  approach taken with SafeTrack is the most effective way to identify and  address safety issues. WMATA also lacks a policy that requires, and  relevant procedures specifying how, it follow these leading planning  practices for large-scale rehabilitation projects. Without such a policy and  procedures in place, WMATA lacks a framework to comprehensively plan  future large-scale rehabilitation projects to meet their objectives.
subsections: section_title: WMATA’s Collection and Use of Data in Planning SafeTrack Did Not Align with Leading Practices, Though New Asset Inventory Is Being Developed
paragraphs: Leading management practices for transit rehabilitation projects state that  transit agencies should collect and use data on assets when planning  projects. Public transit agencies have a wide variety of assets to maintain,  including track and third rail infrastructure. The TCRP report on prioritizing  the rehabilitation of capital assets states that transit agencies should  collect detailed information on assets, including data on the age and  condition of infrastructure. The TCRP report also states that agencies  should use data to assess the conditions of assets. This assessment  should then form the basis of prioritizing rehabilitation work. Indeed,  according to TCRP, “the process of evaluating and prioritizing  rehabilitation and replacement work starts with collecting data on existing  transit capital assets.”
Though WMATA collected data on its track assets through inspections  when planning SafeTrack, those inspections were not comprehensive  because they focused on specific items like rail crossties and did not  cover all track-related infrastructure. Specifically, in 2015, WMATA  conducted inspections of its Metrorail track to collect data on the condition  of its track infrastructure and identify the work necessary to bring the track  to a state of good repair. The inspections were carried out by a contractor for WMATA’s Track and Structures department as part of WMATA’s  Track Quality Improvement Program (TQIP). According to WMATA  officials we spoke with, these inspections were necessary under TQIP  because they could not rely solely on track condition data in WMATA’s  existing asset database. Indeed, WMATA’s OIG recently found that  WMATA’s asset database does not have adequate controls and oversight  in place to properly manage assets, among other concerns. WMATA  used the data collected in its 2015 inspections as the primary source for  identification of the most degraded areas of track, which would be subject  to SafeTrack surges. However, the data collected during the inspections  focused on the rail crossties and did not cover all infrastructure in the  Metrorail track area. For example, according to WMATA officials, the  inspections did not include an examination of all interlockings or of all  track power systems, including the electrical cables that power the third  rail system. According to WMATA officials we spoke with, these systems  were not included in the inspections because the Track and Structures  department leading the TQIP effort is not responsible for the maintenance  of other systems. Electrical cables, for example, are managed by  WMATA’s Power Engineering department. Data on the condition of  assets in non-track systems has generally been collected by the  responsible department, but according to WMATA officials, these data  were not used to identify areas for SafeTrack work.
Officials with other transit agencies we spoke with said that accurate and  comprehensive data on assets are crucial to identifying and prioritizing  rehabilitation efforts. For example, NYCT officials told us that they rely on  data from their transit asset management database to identify track  sections with the greatest number of defects, or areas in need of repair, to  prioritize sections of tracks for rehabilitation activities. MBTA officials we  spoke with said that their agency has developed a state-of-good-repair  database that includes an inventory of the age of assets that managers  can use to prioritize rehabilitation and replacement projects. Officials from CTA said they use a new asset management system, which has detailed  information on the condition of CTA’s assets, to better identify and  prioritize capital projects.
WMATA’s planning of SafeTrack relied on limited data regarding the  condition of Metrorail assets, in part because the agency lacks internal  requirements governing the collection and use of asset information in  planning projects. More specifically, WMATA does not have a policy or  procedures requiring it to collect and use asset data, and coordinate with  other departments on the collection of such data when planning large- scale rehabilitation projects. To ensure that such proper management  practices are consistently carried out, the COSO internal control  framework used by WMATA states that management should set policies  establishing what is expected and relevant procedures specifying the  necessary actions to carry out the policy. As we reported recently, asset  management can help transit agencies optimize limited funding so that  they receive the “biggest bang for their buck” when rehabilitating and  replacing assets. By not gathering and using detailed data on all  aspects of the track infrastructure when planning SafeTrack, WMATA  decision-makers may not have had sufficient information to develop  project objectives and properly prioritize SafeTrack work. Indeed, serious  safety incidents have continued to occur on the Metrorail system during  SafeTrack on assets that were not being addressed in the project. On  July 29, 2016, a train derailed near the East Falls Church station. This  derailment occurred on an interlocking, a part of track not scheduled at  that time for rehabilitation under SafeTrack. As a result of this incident,  WMATA modified the scope of future SafeTrack surges to include the  rehabilitation of interlockings. Additionally, FTA has directed WMATA to  complete safety critical work both prior to starting and during SafeTrack, resulting in changes to the scope and schedule of SafeTrack, as  discussed later in this report.
Though WMATA did not utilize comprehensive asset information in  planning SafeTrack, it is developing a new inventory, as required by  FTA’s 2016 Transit Asset Management final rule. More specifically,  WMATA is currently conducting a Transit Asset Inventory and Condition  Assessment, and is working with FTA to develop its new transit asset  inventory. According to WMATA, this effort will help ensure that it has a  complete, consistent, accurate, and centralized repository of relevant  asset-related data. A reliable repository of asset data can then facilitate  data-driven maintenance and capital investment decision making.  WMATA has completed the first of two phases for this assessment. In the  first phase, WMATA sought to conduct an initial asset inventory and  condition assessment. In the second phase, WMATA plans to further  develop how it will manage its assets and collect additional data, among  other things.
section_title: WMATA’s Analysis of Alternatives for Improving the State of Repair of the Track Did Not Align with Leading Practices
paragraphs: Leading management practices for transit rehabilitation projects state that  transit agencies should have a policy in place for evaluating project  alternatives. The TCRP report on prioritizing the rehabilitation of capital  assets states that agencies should generate alternative plans for  achieving a state of good repair and quantify the costs and impacts of  those alternatives. As noted above, the COSO internal controls  framework used by WMATA also states that management should  establish policies and procedures to help ensure that proper practices are  carried out.
Though WMATA considered different plans for improving the state of  repair of its track infrastructure, it did not quantify the costs and impacts of  each alternative. WMATA currently lacks a policy requiring alternatives  analysis for large-scale rehabilitation projects. After collecting data from  track inspections in 2015, WMATA developed three alternatives for  improving the state of repair of its track infrastructure. These alternatives  included 8, 10, and 22-month work schedules. According to WMATA  officials, these alternatives included different levels of service disruptions,  including extensive single-tracking and track section closures, but generally included the same work tasks. According to WMATA officials,  they ultimately settled on the initially announced 10-month plan, dubbed  SafeTrack, because it best balanced rider disruption with addressing the  urgent safety needs of the system. Additionally, they said that WMATA’s  ability to make effective and efficient use of time on the track was also a  primary consideration. However, WMATA did not fully assess the  alternatives to improving the state of its track infrastructure. In particular,  WMATA did not quantify the effects of the various alternatives on  extending the life of the track assets, on reducing maintenance costs, and  on Metrorail ridership. WMATA also did not quantify the costs or establish  a detailed budget for its alternatives and still has not determined the final  funding sources for its selected alternative. Although WMATA estimates  that the SafeTrack project will cost approximately $120 million to  complete, it has identified funding sources for about $80 million of these  costs and has yet to determine how it will fund the remaining $40 million.
Other transit agencies we spoke with described detailed considerations of  alternatives to carrying out large-scale rehabilitation projects. For  example, CTA officials we spoke with said they developed and assessed  different plans to rehabilitate its Red Line South track, including estimates  of the costs and impacts of each alternative. Further, officials at PATH  told us that they selected a particular approach to upgrading a tunnel they  use for trains that travel from New Jersey to Manhattan, New York,  because it balanced rider disruption and work efficiency. The PATH  officials told us that they conducted approximately one year of planning in  advance of this project and developed seven different scenarios before  finally settling on the current approach.
WMATA did not fully assess alternatives to rehabilitate its track assets  because it believed it needed to start work immediately to address critical  safety issues. At the time SafeTrack was planned, according to officials  we spoke with, WMATA leadership was making critical decisions on how  to address systemic deferred maintenance. Indeed, according to  WMATA’s Chief Safety Officer, in a call on May 10, 2016, a senior official  within FTA’S FWSO office notified WMATA that FTA was considering  taking action to “shut down” the entire Metrorail system due to safety  concerns. According to WMATA officials, SafeTrack was conceived as  WMATA’s unique and necessary response to the state of its track  infrastructure. Further, WMATA officials noted that the agency is  committed to devoting the resources necessary to bring the track to a  state of good repair, and to developing preventative maintenance  programs that would prevent similar safety-critical situations in the future.
Nevertheless, by not having a policy and procedures in place requiring  analysis of alternatives for future large-scale rehabilitation projects,  WMATA lacks a framework to comprehensively plan such projects to  meet their objectives. WMATA plans to spend over $56 million a year on  track rehabilitation projects alone starting in fiscal year 2018. If WMATA  were to make decisions about the scope and prioritization of these  projects without full information about the various alternatives, it may not  select an approach that best balances costs and impacts.
section_title: SafeTrack Work Began Before Key Elements of a Project Management Plan Were in Place, Inconsistent with Leading Practices
paragraphs: Leading project management practices emphasize the importance of  developing project management plans. The PMI PMBOK® Guide states  that a comprehensive project management plan should be developed  before a project begins so that it is clear how the project will be executed,  monitored, and controlled. More specifically, the plan should include the  critical information for managing a project’s scope, schedule, and cost,  according to established baselines and in consideration of project risks,  quality standards, and other items. As discussed below, federal law also  requires that recipients of federal financial assistance for major capital  projects prepare a project management plan.
According to WMATA officials, WMATA did not develop a comprehensive  project management plan before beginning SafeTrack because they  believed a project management plan was not appropriate for such a  project. WMATA considers SafeTrack to consist of accelerated but  normal maintenance activities. According to WMATA officials, a project  management plan is best suited for new construction projects. WMATA  therefore chose to manage SafeTrack using tools that they considered  more appropriately suited for managing coordinated maintenance tasks.  For example, WMATA uses detailed “march charts” to plan and coordinate its various maintenance tasks within surge work areas.  However, according to WMATA officials, they did not develop a plan that  clearly defined the budget, execution, monitoring, and control of the  project before beginning SafeTrack. According to FTA officials we spoke  with, FTA has discretion regarding when it determines a project is major  and when a project management plan must be submitted. As discussed  later in this report, WMATA developed a project management plan during  the initial months of SafeTrack implementation, though FTA has not yet  approved WMATA’s plan.
Other transit agencies we spoke with said that they generally developed  extensive plans for their large-scale rehabilitation projects. For example,  CTA officials we spoke with said that they conducted extensive planning,  and developed a project management plan, for their Red Line South  reconstruction project, even though they did not use federal funds and  therefore were not required by FTA to develop such a plan. Additionally,  in planning for the shutdown and rehabilitation of the Canarsie tunnel,  NYCT is developing a detailed plan that reflects its risk assessments and  analysis of lessons learned from previous work, according to the officials  we spoke with.
Though WMATA developed SafeTrack as a unique response to the state  of its track infrastructure, future large-scale rehabilitation projects  undertaken by the agency would benefit from the development of a  comprehensive project management plan prior to the start of the project.  As discussed above, WMATA officials told us that they implemented  SafeTrack to respond to a critical safety situation and that they could not  postpone this track work to develop a project management plan.  SafeTrack, though, involves an unprecedented amount of track work  performed over an extended period, significantly disrupts ridership, and is  estimated to cost well over $100 million. WMATA currently lacks a policy  and procedures requiring the development of a project management plan  for large-scale rehabilitation projects like SafeTrack, according to WMATA  officials, regardless of whether the work is to be completed in response to  an emergency situation or within WMATA’s normal state of good repair  efforts. The COSO internal controls framework used by WMATA states  that management should have policies establishing what is expected of  management and employees, to help mitigate risks to achieving goals.  Although WMATA told us that it has a manual on project implementation  that is focused on the implementation and close-out phases of a project, it does not yet cover the planning phase. Further, although a project  management plan is required for public-transportation-related major  capital projects receiving federal financial assistance, WMATA may  undertake future large-scale rehabilitation projects that do not meet the  major capital project definition or that do not use federal funds at all. Such  projects could still benefit from having a project management plan in  place before beginning the project—consistent with leading practices—to  manage the project’s scope, schedule, costs, and other factors. Without a  policy and procedures that require the development of a plan for future  large-scale rehabilitation projects, WMATA lacks a key tool to ensure its  projects are completed on-time, on-budget, and according to quality  standards.
section_title: WMATA Provided Little Notice of SafeTrack to Local Stakeholders but Communication and Coordination during Surges Generally Align with Leading Practices
paragraphs: Leading management practices and other transit agencies we spoke with  state that identifying and coordinating with external stakeholders is part of  proper project planning. The PMI PMBOK® Guide states that agencies  should identify stakeholders for their projects, communicate and work with  stakeholders to meet their needs, address issues as they occur, and  foster stakeholder engagement in project activities. FTA project  guidelines also note that communication with the public can be crucial for  receiving the necessary buy-in to move a project forward. Other transit  agencies we spoke with said that they generally began stakeholder  engagement weeks, if not months, prior to the beginning of projects. For  example, the PATH officials we spoke with said that they began  communicating with government officials and the public about the  proposed tunnel weekend shutdowns 2 months before the project started.  Similarly, according to NYCT officials, they presented various schedule  alternatives for rehabilitating the Canarsie tunnel to the local communities  directly affected by the tunnel’s closing to explain NYCT’s rationale for  completing the work, as well as to discuss the benefits and challenges of  different plans.
According to WMATA officials, urgent safety concerns necessitated an  accelerated planning process, which precluded advanced notice of  SafeTrack to local jurisdictions, other regional transit agencies, and the  public. Officials from one local county we spoke with said that they had  about a month between when they first heard about SafeTrack and when the first surge began in June 2016. According to local officials we spoke  with, little advanced notice of SafeTrack caused some miscommunication  between local jurisdictions as well as difficulty identifying funding for  mitigation efforts. Specifically, one local county official told us that the  county had to quickly develop a plan to bring 25 recently retired buses  back into service to provide options to Metrorail riders affected by  SafeTrack surges. The county estimated that it incurred approximately $1  million in bus driver labor and other costs as a result of SafeTrack. The  county official told us that it expects to be compensated by the state for  these expenses.
Nonetheless, as the SafeTrack project has progressed, WMATA’s efforts  to coordinate with local stakeholders have generally been in line with  leading practices. WMATA officials identified stakeholders for the  SafeTrack project, including local transit agencies and elected officials.  WMATA utilized a variety of methods to communicate and coordinate with  local transit agencies and jurisdictions during SafeTrack. For instance,  one local official we spoke with said that WMATA’s Joint Coordinating  Committee—which brings local officials together to plan for major events  affecting regional transportation—is an effective mechanism for sharing  information, such as local plans for the use of shuttle buses in areas  affected by surges. Local officials also said that communication and  coordination between WMATA and jurisdictions has been effective,  especially after the first few months of SafeTrack. For example, one local  official told us that WMATA has provided the jurisdiction with prompt  information about the upcoming surges through weekly planning meetings  at WMATA headquarters, as well as through informal coordination with  WMATA staff on specific surges.
WMATA has also effectively communicated with the public, according to  the local officials we spoke with. WMATA officials told us that they have  used a variety of measures to communicate SafeTrack plans to the public  including press releases issued to local news media outlets; postings on  social media, such as Facebook, YouTube, and Twitter; and a SafeTrack  web page that includes details about the overall project and each surge.  Officials from one jurisdiction said that WMATA has provided good  information on its website and that having additional WMATA staff at  SafeTrack-affected stations and bus areas has also been useful. As a  result of such efforts, one local official told us that Metrorail riders have  demonstrated a high level of awareness about SafeTrack.
section_title: WMATA Is Using Several Leading Practices to Implement SafeTrack and Improve the Quality of Completed Work
paragraphs: WMATA’s implementation of SafeTrack generally aligns with leading  project management practices. Specifically, during the course of each  SafeTrack surge, WMATA officials collect and document information  about the work performed and the condition of assets. WMATA officials  also develop lessons learned during and after each surge period, and use  those lessons during subsequent maintenance and planning efforts. Last,  WMATA developed a new organization-wide quality control and  assurance framework that it is implementing for the first time through  SafeTrack.
subsections: section_title: WMATA Has Consistently Collected and Monitored Work Performance Data and Information
paragraphs: Leading project management practices emphasize the importance of  collecting and monitoring work performance data and information. The  PMI PMBOK® Guide states that throughout the lifecycle of a project,  organizations will generate a significant amount of work performance  data and work performance information that is collected, analyzed,  documented, and shared with stakeholders. This data and information is  typically created and documented after a project begins, and is a key  element in controlling a project’s scope, schedule, cost, and risk.  Organizations can collect work performance data and information to  identify trends and process improvements. Work performance data are  also a key factor in an organization’s overall quality management for  projects, as they provide a foundation for implementing quality control and  quality assurance practices, as well as stakeholder engagement, since  they inform discussions on project performance. The TCRP report on  prioritizing the rehabilitation of capital assets also states that transit  agencies should define data collection and inspection protocols, and  ensure the data are detailed and current enough to support decisions on  asset rehabilitation or replacement.
Based on procedures WMATA has established, officials have collected  and documented information about the work performed and the condition  of WMATA’s assets in SafeTrack surge areas, consistent with leading  project management practices. Prior to each surge, WMATA officials from  relevant departments have conducted inspections on the conditions of  both the track infrastructure and other non-track assets. WMATA officials  have used this pre-surge inspection data to develop the overall scope of  work for each surge, as well as to identify each component planned for  maintenance or replacement. According to WMATA officials, although  prior to SafeTrack inspections focused solely on track assets such as the  condition of crossties, pre-surge inspections have since included  assessments on the condition of both track and non-track assets, such as  power cables. However, the number of assets planned for maintenance  or replacement in each surge varies depending on the conditions of the  assets in question. WMATA officials told us that during each surge, they  regularly discuss progress with departments that are responsible for  ensuring completion of scheduled work, as well as monitoring teams’  work quality and site safety. At the end of each surge, WMATA officials  have compiled totals for all work completed, after verification and  completion of the various departments’ quality control processes.  WMATA has then compared the completed work against the pre-surge  work plan. WMATA has used the completed work data to develop its  surge progress reports, which it issues to stakeholders and makes  available to the public at the end of each surge. However, although  WMATA is collecting information on the condition of assets repaired  through SafeTrack, WMATA does not have a policy or procedures  requiring it to use asset data when planning future large-scale  rehabilitation projects, as previously discussed.
WMATA has also used work performance data and information to identify  the amount of rehabilitation work that can be performed during a given  maintenance window. For example, WMATA is not replacing all crossties  within a given SafeTrack segment; rather, its goal is to ensure that 75  percent of the ties in a surge area are in good condition so that it will not  need to replace all of them at the same time in the future. WMATA officials stated they believe that this approach will allow them to move to a  more sustainable crosstie replacement model, eliminate maintenance  backlog, and achieve a state of good repair for those assets. WMATA has  also incorporated other types of data, such as logistical constraints for  available work crews and equipment, to inform its assessment of how  work will be accomplished during each surge. See figure 3 for select track  assets that have undergone repair or replacement during SafeTrack.
The work performance data collected by WMATA demonstrate that  WMATA has renewed or replaced a substantial amount of track  infrastructure, as well as other non-track assets, during the course of  SafeTrack. According to WMATA officials, SafeTrack work crews have  been able to complete work more efficiently than is possible during  normal, shorter, maintenance windows. For example, WMATA reported  that by limiting service for 13 days on the Red Line from Shady Grove to  Twinbrook, it was able to replace over 3,500 crossties; this work would  have taken more than 2 years to complete if performed only after the end  of the rail system’s service each day. As shown in table 1, through the  first 10 surges, WMATA has replaced more than 26,000 crossties, with its  goal being to replace over 45,000 crossties when the project is  complete. Through surge 10, WMATA has also replaced more than  4,300 insulators, which support the third rail. WMATA plans to replace  more than 11,800 insulators through SafeTrack, and has replaced over  700 power cables as well.
section_title: WMATA Has Collected and Implemented Lessons Learned throughout SafeTrack
paragraphs: The collection of lessons learned is a key project management step that  helps inform an organization’s planning and evaluation of its projects,  programs, and portfolios, as well as supports process improvements. The  PMI PMBOK® Guide states that organizations should identify and collect  lessons learned during the course of executing a project to complement  their overall knowledge base, particularly with respect to project selection,  performance, and risk management. FTA Quality Management Systems  Guidelines also state that corrective actions for nonconforming work  common to most projects should be recorded as lessons learned and  disseminated throughout an organization.
In accordance with leading project management practices, WMATA  officials have developed lessons learned during and after each surge  period, and have used those lessons during subsequent maintenance  and planning efforts. For example, WMATA officials said that over the  course of the initial SafeTrack surges, they evaluated their work  procedures and refined their approach to replacing rail crossties. In  particular, they acquired new machines to remove ties and install rail  spikes, and implemented better scheduling of the machines and work  crews to facilitate more efficient crosstie replacement. As another  example, during the course of the initial SafeTrack surges, WMATA  officials learned to define clear work limits prior to each surge to improve  work efficiency. More specifically, during the initial planning of SafeTrack,  officials did not clearly define surge work areas by specific chain  markers and instead labeled the ends of the surge areas by Metrorail  station. Furthermore, WMATA officials recognized the need to make detailed scope and work plan documents available before the start of  each surge in order to prevent confusion regarding expectations, work  inefficiencies, and unachieved objectives.
WMATA has also used project meetings to capture and disseminate  lessons learned among its work teams. Before every surge period,  WMATA stakeholders have met to discuss the intended scope of work for  the surge, prioritize work tasks, and agree upon a work plan. WMATA  officials have then incorporated this information into a 90-day “look  ahead” schedule that is used to plan material purchases and verify track  rights for work crews. According to WMATA officials, once a surge has  ended, WMATA holds “closeout” meetings with its internal stakeholders  (including quality assurance officials) to discuss the work performed and  lessons learned, which are then included in an official closeout report.  The use of closeout meetings after a project work period ends is also  consistent with leading project management practices.
section_title: WMATA Is Establishing and Implementing Policies to Improve the Quality of Work Performed through SafeTrack
paragraphs: Leading project management practices emphasize the importance of the  management, assurance, and control-of-quality issues. The PMI  PMBOK® Guide states that organizations should establish policies and  procedures that govern quality management for their projects and  deliverables. Quality management refers to key processes that comprise  a quality framework, including identifying quality requirements and  standards, performing quality audits, and monitoring and recording results  of executing quality activities in order to assess performance and  recommend necessary changes. PMI notes that having a quality  management framework in place can ensure that project requirements  are met and process improvement initiatives are supported.
WMATA has developed an agency-wide quality control and assurance  framework that is in line with best practices. According to WMATA  officials, the agency is implementing a new quality assurance framework  for the first time during SafeTrack. In March 2016, WMATA officials  established a new, independent quality team called Quality Assurance,  Internal Compliance, and Oversight (QICO) that reports directly to the  WMATA General Manager. In addition to serving as an independent  reviewer of the SafeTrack project, the QICO team is responsible for  developing and implementing a new quality framework for the entire  organization. According to WMATA officials, this framework has three  levels of review for work performed by maintenance groups. Maintenance  groups are to provide the first level of review, with managers assessing  the quality of the work completed by crews, such as installation and  maintenance of assets, and documenting their findings on quality control  checklists. Second, QICO is responsible for assessing the overall quality  of completed work by reviewing a sample of work tasks competed during  the surge, and providing feedback for work teams on quality and safety  concerns. This feedback includes preparing surge closeout reports that  document any quality, safety, or other concerns and reporting them to  WMATA leadership and the relevant work teams involved. The work  teams must then address and close out any quality deficiencies through  ongoing maintenance activities. Last, the WMATA OIG and Board of  Directors are responsible for monitoring internal performance at the  agency and approving manager-level decisions regarding quality control  and assurance. In addition to this review structure, the QICO team is also  developing an enterprise-wide Quality Management System, in  accordance with the FTA’s Quality Management Systems Guidelines, that  is intended to clearly define WMATA’s organizational objectives with  respect to quality assurance. The QICO team has also developed training  programs for maintenance supervisors as well as certification  requirements for quality assurance staff.
In implementing procedures, WMATA’s QICO team has identified a  number of work-related issues (referred to as “discrepancies”) during its  quality control and quality assurance inspections of SafeTrack work,  discrepancies that WMATA is working to address. Specifically, according  to SafeTrack surge’s closeout reports through the first eight surges, QICO  inspectors identified a total of 413 discrepancies for WMATA teams to  address. Officials are to document these discrepancies in “punch lists” of  work tasks that WMATA workers must complete during the course of  upcoming routine maintenance. FTA officials told us that the QICO  closeout reports are useful in order to see work completed during each  surge as well as to inform post-surge inspections. Through surge 8,  WMATA has closed 231 of the 413 discrepancies identified by QICO,  including 93 percent of the safety concerns, 57 percent of the quality  concerns, and 53 percent of site condition concerns (see table 2).
section_title: FTA Has Used Inspections and Other Tools to Direct WMATA to Make Safety Repairs and Oversee SafeTrack
subsections: section_title: FTA Has Conducted Inspections and Directed WMATA to Make Safety Critical Repairs before and during SafeTrack
paragraphs: Prior to WMATA’s announcement of SafeTrack in May 2016, FTA  conducted many inspections of WMATA’s track infrastructure and internal  inspection program. These have informed its oversight of the project. As  previously discussed, FTA established the FWSO office in October 2015  to provide temporary and direct safety oversight of WMATA in the  absence of an effective state oversight authority, according to FTA. When  WMATA first notified FTA of its plans to implement the SafeTrack project  on May 6, 2016, the FWSO had been conducting inspections on the  integrity of WMATA’s track since March 2016. The FWSO was in the  process of developing a directive requiring WMATA to take corrective  actions to address concerns with its track construction, maintenance, and  inspection resources, among other issues. According to FTA, FWSO  inspectors conducted 76 inspections of WMATA’s Metrorail system from  October 2015 through May 2016. For example, in March and April of  2016, FTA inspected over 60 miles of track on all six Metrorail lines, with  additional follow-up inspections between late April and June. FTA found  that WMATA’s track inspection program did not fully account for  differences in track types, locations, and train traffic volume when  WMATA prioritized its inspections. In addition, FTA found that WMATA  maintenance departments did not jointly review inspection results to  develop coordinated mitigations and assign limited resources to highest  priority issues.
Since the start of SafeTrack work in June 2016, FTA has conducted  additional inspections and observations of SafeTrack work for each  surge. According to FTA inspection data from June 2016 through  September 2016, FTA inspectors conducted a total of 102 individual  inspections of WMATA rail assets, including 49 inspections that covered  SafeTrack-related work. For example, FTA officials told us that from the  first SafeTrack surge, FTA officials accompanied WMATA staff on pre- surge inspections to identify repair items and observe work tasks during  each surge to assess the quality of the repairs. FTA officials said they  also conferred with WMATA staff after each surge to identify work not  completed, which WMATA compiles into a prioritized “punch list” of critical  repairs to be completed during the course of upcoming routine  maintenance. FTA officials told us they have been monitoring WMATA’s  completion of punch list items and were working with WMATA to ensure  progress in completing these tasks.
As a result of its inspections, FTA directed WMATA to complete safety  critical work both prior to starting and during SafeTrack, specifically:  In response to WMATA’s initial SafeTrack plan provided to FTA on  May 6, 2016, FTA sent a letter on May 11, 2016, directing WMATA to  make urgent repairs to reduce the risk of smoke and fire events and  the occurrence of arcing insulators on certain sections of the rail  system. FTA’s letter directed WMATA to repair power cables,  insulators, and the electrified third-rail system on certain portions of  the Red, Blue, Orange, and Silver lines, before beginning SafeTrack.
In response to WMATA’s proposed schedule changes after the July  29, 2016 derailment of a Silver Line train near the East Falls Church  station, FTA sent WMATA another letter on September 1, 2016,  encouraging WMATA to also include additional safety-related work in  SafeTrack, including: (1) prioritizing additional repairs to arcing  insulators on the Red Line; (2) completing unfinished track work from  the third surge on the Blue and Yellow lines; and (3) addressing poor  tie and fastener conditions on certain sections of the Orange and Blue  lines, including a section of the Orange Line that was not originally  part of WMATA’s SafeTrack surge plan.
WMATA took several actions to address FTA’s concerns. First, WMATA  adjusted the order of early surges in its initial SafeTrack plan and has  replaced insulators, repaired power cables and third-rail components, and  assigned a dedicated work crew to improve drainage on the sections of  the Red Line between Medical Center and Van Ness stations, as cited in  FTA’s May 11 and September 1 letters. Second, WMATA officials told us  that Metrorail completed unfinished work from the third surge on the Blue  and Yellow lines during an additional single-tracking event. Finally, in  January 2017, WMATA scheduled an additional surge from May to June  2017 to address FTA’s concerns regarding poor track condition on a  certain section of the Orange Line.
FTA reported that WMATA’s actions taken in response to FTA’s concerns  have helped reduce safety incidents. According to an FTA report,  WMATA has reduced the prevalence of electrical arcing incidents on the  Red Line between Medical Center and Van Ness station as a result of  WMATA’s additional maintenance activity in that section of track.  Specifically, FTA reported that between March 1, 2016, and June 14,  2016, WMATA had experienced 18 electrical arcing incidents between  Medical Center and Van Ness, including 4 major events at the end of  April and early May. Since taking additional maintenance actions,  WMATA experienced 8 arcing events over the 4 month period from mid- June 2016 through mid-October 2016, and FTA has characterized these  events as relatively minor.
section_title: FTA Has Required WMATA to Prepare and Refine Its SafeTrack Project Management Plan
paragraphs: In addition to FWSO inspections of WMATA infrastructure and safety  procedures, FTA has also exercised its project management oversight  authority over SafeTrack since July 2016. FTA’s project management  oversight includes monitoring a major capital project’s progress to  determine whether a project is on time, within budget, and in  conformance with design criteria, and whether it is constructed to  approved plans and specifications, and is efficiently and effectively  implemented. As noted previously, major capital projects include,  among other things, projects involving the rehabilitation or modernization  of an existing fixed guideway with a total project cost in excess of $100  million. FTA found that SafeTrack met the $100-million criteria for a  major capital project when it approved an additional $20 million in safety- related federal funding for the project in mid-June 2016, during the first  surge. As a result, FTA announced that it would exercise its project  management oversight authority over SafeTrack in a July 1, 2016, letter  to WMATA.
After FTA designated SafeTrack as a major capital project based on  criteria established in law, WMATA became subject to the statutory  requirement to complete a project management plan. Federal law  requires that recipients of federal financial assistance for a major capital  project related to public transportation prepare a project management  plan approved by the Secretary of Transportation, and carry out the  project in accordance with the project management plan. FTA  guidelines state that a project management plan provides a functional,  financial, and procedural road map for the project sponsor to effectively  and efficiently manage a project on-time, within-budget, and at the  highest quality and safety. According to federal regulations, as a general  rule, a major capital project’s project management plan must be  submitted during the grant review process and is part of FTA’s grant  application review. These regulations also state that if FTA determines  that a project is major under its discretionary authority after the grant has  been approved, FTA will inform the recipient of its determination as soon  as possible. In the case of SafeTrack, due to WMATA’s desire to begin  SafeTrack work immediately, and FTA’s determination of SafeTrack as a  major capital project after work had already commenced, WMATA did not  submit its project management plan to FTA until 4 months into the project.  On July 1, 2016, FTA requested that WMATA submit its project  management plan to FTA by July 29, 2016. WMATA requested and was  granted an extension, and submitted its project management plan to FTA  on September 30, 2016.
As of January 2017, FTA has yet to approve WMATA’s project  management plan because key elements lacked sufficient detail. FTA  officials told us that WMATA’s plan did not provide adequate information  on the SafeTrack budget and costs of the work being conducted, as well  as information to identify and manage project risks, or assess the  performance of the project against defined metrics. FTA provided  WMATA with detailed comments on WMATA’s plan covering these and  other issues. As previously noted, WMATA officials told us that they do  not consider the project management plan to be the most appropriate tool  to manage SafeTrack tasks, which are primarily maintenance activities.  However, WMATA officials also told us that they were working closely  with FTA to improve the quality and level of detail in the plan.
section_title: Conclusions
paragraphs: WMATA’s recent record of significant safety incidents demonstrates that  its Metrorail system faces serious safety and infrastructure challenges.  Through SafeTrack, WMATA has accomplished a substantial amount of  repair work to bring its track infrastructure closer to a state of good repair.  WMATA is also learning some important lessons in implementing  SafeTrack that could better equip it to identify and address issues in  future large-scale rehabilitation projects. Perhaps more importantly,  SafeTrack indicates that WMATA is now committed to preventative  maintenance, including the repairing of track assets before they break  and cause more cost and safety impacts on Metrorail riders. Though  SafeTrack consists largely of routine maintenance work, the intensity,  length, cost, and disruption of the effort distinguishes it from normal  maintenance work. As a result of the urgent need for work on the track  infrastructure and the unique nature of SafeTrack, WMATA’s planning of  SafeTrack did not fully align with leading practices, and WMATA likely  experienced some early challenges as a result. These challenges  highlight the importance of comprehensive planning and project  management for large-scale rehabilitation projects to minimize the  impacts on riders and ensure work is completed efficiently and according  to quality standards. Indeed, SafeTrack is not a comprehensive approach  to addressing WMATA’s safety needs and additional efforts will be  needed to bring the entire Metrorail system to a state of good repair.  Without a policy requiring planning processes that are more consistent  with leading project management practices, which call for thorough  analysis, planning, and informed decision-making, WMATA’s ability to  effectively address future infrastructure challenges may be limited. This  situation is particularly true for future large-scale rehabilitation projects  that may not be designated as major capital projects and subject to FTA’s  project management oversight authority, but which could still benefit from  having a project management plan in place before beginning the project,  consistent with leading practices. Furthermore, documenting these  planning requirements, and the relevant procedures for carrying them out,  would help ensure that they are carried out consistently, in order that staff  and management can be held accountable for them.
section_title: Recommendations
paragraphs: To ensure future large-scale rehabilitation projects are in line with leading  project management practices, WMATA should develop a policy that  requires and includes relevant procedures specifying that the following  three actions be taken prior to starting large-scale projects: use detailed data on the conditions of assets to develop project evaluate and compare alternative ways of accomplishing the project  objectives, including estimates for the alternatives’ costs and impacts;  and develop a comprehensive project management plan for the selected  alternative—to include key elements such as detailed plans for  managing the project’s scope, schedule, and cost—for those projects  that may not be designated major capital projects.
section_title: Agency Comments
paragraphs: We provided a draft copy of this report to DOT, NTSB, and WMATA for  review and comment.
In written comments, reproduced in appendix I, DOT said that, since  exercising oversight authority, FTA has guided and examined WMATA’s  work toward improving its safety culture, infrastructure, and operations.   DOT also said that FTA will continue to provide safety oversight of  WMATA and help it build upon improvements made in the last year.
In comments provided in an e-mail, NTSB noted that it shares our  concern that WMATA’s interlockings, and other track work, were not fully  considered in planning SafeTrack.  NTSB also said that FTA’s public  transportation safety oversight approach lacks the necessary standards,  expertise, and resources.  This report focused on FTA’s oversight of the  SafeTrack project specifically, so we did not evaluate FTA’s overall public  transportation safety model.  We do, however, have planned work to  examine FRA and FTA safety oversight programs.
In written comments, reproduced in appendix II, WMATA agreed with our  findings and conclusions, and said that it is working to address the  recommendations.  WMATA also said that the draft report did not reflect  the urgent safety state of the Metrorail system prior to beginning  SafeTrack, which precluded comprehensive project planning.  We  acknowledge throughout the report that, at the time SafeTrack was being  developed, WMATA faced significant safety issues and leadership was  making critical decisions on how to address systemic deferred  maintenance.  Nevertheless, by not fully carrying out leading project  management practices, WMATA lacked assurance that SafeTrack was  the most efficient and least disruptive approach to accomplishing the  track repair objectives.  Having a policy and procedures in place requiring  these project management practices for future large-scale rehabilitation  projects will ensure that WMATA plans such projects so they best meet  their objectives.
As agreed with your offices, 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, Chairman of NTSB, General Manager of WMATA,  WMATA Board of Directors, and the appropriate congressional  committees. In addition, the report will be available at no charge on  GAO’s website at http://www.gao.gov.
If you or your staff have any questions about this report, please contact  me at (202) 512-2834 or goldsteinm@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. Individuals that made key contributions to this  report are listed in appendix I.
section_title: Appendix I: Comments from the Department of Transportation
section_title: Appendix II: Comments from the Washington Metropolitan Area Transit Authority
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, Matt Barranca (Assistant  Director), Kyle Browning (Analyst in Charge), Jason Blake, Lacey  Coppage, Hannah Laufe, Sara Ann Moessbauer, Malika Rice, and  Michelle Weathers made key contributions to this report.