OCTOBER 3, 2018


Chairman Thune, Ranking Member Nelson, and Members of the Committee on Commerce,
Science, and Transportation, on behalf of the American Public Transportation Association
(APTA) and its more than 1,500 public- and private-sector member organizations, thank you for the opportunity to submit written testimony on commuter railroads’ implementation of positive train control (PTC).

My name is Paul Skoutelas, and I am the President and Chief Executive Officer (CEO) of the
American Public Transportation Association. Prior to joining APTA in January, I served in
leadership positions on numerous boards and committees for transportation organizations,
including on APTA’s Board of Directors and Executive Committee, the Transportation Research
Board, National Transit Institute, Pennsylvania Transportation Institute, and the Transit
Cooperative Research Program. I also served as national director of WSP USA’s Transit & Rail
Technical Excellence Center where I provided strategic direction on public transit and rail
projects. Prior to WSP, I was CEO at two major public transportation agencies: the Port
Authority of Allegheny County in Pittsburgh, Pennsylvania, and the Central Florida Regional
Transportation Authority (LYNX) in Orlando, Florida.

I want to begin by reiterating APTA’s and the commuter rail industry’s long-standing and unwavering commitment to implementing positive train control.

Since the Committee’s last hearing on PTC implementation in March, the nation’s
commuter railroads have continued to make strong and continuous progress in installing and implementing positive train control. This progress is reflected in the Federal Railroad Administration’s (FRA) recently released second quarter PTC Progress report, including reducing by two the number of commuter railroads on FRA’s list of at-risk railroads.

The commuter rail industry has been working continuously with freight partners, third-party
contractors, Amtrak, and FRA to implement PTC and address technical and interoperability
challenges. APTA has also provided a number of forums for collaboration and the sharing of best practices and lessons learned, including through its Commuter Rail PTC Subcommittee, which has been particularly helpful in providing a cohesive push as the industry works toward a
common goal—implementing PTC and making an already safe system even safer.

We greatly appreciate the Committee’s focused attention on the critical issues of rail safety and
PTC, and the challenges and successes that publicly-funded commuter railroads have
experienced in procuring, installing, and implementing this complex signaling and
communications technology.


Safety is Our First Priority

For commuter rail operators and the entire public transportation industry, safety is our first priority. Safety is not simply a value we share; it is a core operating principle and a promise to our riders. The men and women responsible for managing and operating public transportation systems are fully committed to the safety of their systems, passengers, employees, and the general public.

Moreover, throughout our 136-year history, APTA and its predecessor associations have been
leading advocates for safety improvements. We have led the way in creating an effective safety
culture over many decades:

  • creating a Rail Safety Audit Program;
  • developing Safety Management Program Plans; and
  • writing more than 270 standards and recommended practices for public transit, including
    Passenger Rail Equipment Safety Standards (PRESS) for commuter rail cars.

APTA’s PRESS standards help improve the safety of public transportation systems by specifying
safety requirements for vehicle crashworthiness, passenger door systems, emergency lighting and evacuation, and new benchmarks to improve the safety of vehicle interiors including seat
attachment strength and workstation tables.

With regard to positive train control, APTA publicly supported the concept of PTC prior to
enactment of the Rail Safety Improvement Act of 2008 (RSIA), and we advised Members of
Congress and other policymakers of the need for proven technology, adequate resources, and the expanded radio spectrum necessary to put PTC into operation. Since enactment of RSIA, APTA has actively worked to assist the commuter rail industry with PTC research, development, installation, and implementation, including by participating in FRA’s Rail Safety Advisory Committee (RSAC); establishing “user groups” among different types of commuter rail operators to share information and encourage coordinated actions; and conducting PTC
conferences, workshops, and summits with commuter rail chief executive officers, senior
engineering staff, FRA senior staff, and Congressional staff.

As a result of this overriding and sustained commitment to safety, today, public transit is the safest form of surface transportation. Every year, 29 commuter railroads across America safely carry passengers on 500 million trips. And traveling by commuter and intercity passenger rail is 18 times safer than traveling by car.

Positive Train Control Mandate

Moreover, we are working to make commuter rail even safer by installing and
implementing PTC, a complex signaling and communications technology that provides a critical safety overlay on top of already safe commuter rail systems.

In 2015, Congress recognized the implementation challenges that the Government
Accountability Office had outlined since RSIA implementing regulations went into effect. In
enacting the Positive Train Control Enforcement and Implementation Act of 2015, Congress
identified specific installation and implementation milestones. Under current law (49 U.S.C.
20157), commuter railroads are required to implement PTC by December 31, 2018, or,
alternatively, to meet the following milestones (as defined in 49 U.S.C. 20157(a)(3)(B)) by that

  • Installed all PTC hardware (wayside and onboard equipment);
  • Acquired all necessary spectrum for PTC implementation;
  • Completed all employee training required under the applicable PTC system regulations;
  • Initiated revenue service demonstration (RSD) on at least one territory subject to the PTC requirement (or other criteria); and
  • Submitted a plan, schedule, and certification to the Secretary of Transportation for implementing a PTC system.

Upon reaching these milestones by the end of 2018, the commuter railroads must implement
PTC as soon as practicable, and no later than December 31, 2020.

APTA supports these statutory deadlines and is committed to assisting all our commuter railroads in implementing PTC.

PTC: Unparalleled Technological Challenge

As defined in statute, a positive train control system is a “system designed to prevent train-totrain collisions, over speed derailments, incursions into established work zone limits, and the
movement of a train through a switch left in the wrong position.”

Implementing PTC requires changes to four main system components—vehicles,
communications, signals, and the back office/control center—and each has to be fully
functioning and integrated with the other systems.

When RSIA was enacted in 2008, there was no universal off-the-shelf technology capable of
achieving these safety objectives. Although many commuter railroads have long used collision
avoidance systems to help protect against certain accidents, these systems did not have all of the required attributes of PTC. Since the enactment of RSIA, APTA and its member commuter
railroads have aggressively pursued both the funding and technology necessary to implement the PTC mandate by the statutory deadlines.

PTC is a predictive enforcement system of subsystems overlaid on existing systems. Although
commuter railroads are currently in the process of installing these systems, a one-size-fits-all
approach to implementation does not exist. Each commuter railroad has its own unique and
complex operating environment and PTC systems must be tailored to meet those specific
operating requirements.

For instance, commuter railroads interoperating with freight railroads typically use a variant of
PTC called I-ETMS. Railroads that operate on the Northeast Corridor are installing an Amtrakdeveloped system known as ACSES. Railroads without extensive freight interoperability
requirements may use a different PTC variant called E-ATC.1 As such, what works for one
commuter railroad may not work for another. Thus, each passenger rail system needs to build its own unique PTC solution, and it is that absence of a proven, off-the-shelf technology that creates uncertainty about whether a new solution will work as intended.

In general, the following components are required for implementation of PTC:

Locomotive Hardware
All locomotives and other operating equipment must be fitted with onboard computers, radios,
display units, and event recorders. Numerous configurations of commuter rail equipment are in
service including self-propelled cars and push-pull equipment adding to the complexity and cost of deploying these onboard systems.

Wayside Hardware
The wayside equipment that needs to be installed is also extensive and includes Wayside
Interface Units (WIU), switch monitors, wayside radios, base stations, and transponders. Thestatus of the components is transmitted via WIUs to the locomotive to enable the PTC system to take action as necessary.

Communications (Spectrum and Towers)
PTC implementation typically requires a robust wireless infrastructure that is used for
transmission of data between the various subsystems including the onboard, wayside, and back
office equipment. The communications architecture includes data radios, antennas, wayside
towers, and spectrum. After enactment of RSIA, many commuter railroads chose to adopt the
PTC protocol developed for freight railroads or intercity passenger (Amtrak) operations instead
of investing the time and money to develop their own PTC protocol.

Back Office
The back office stores millions of rail network data points as encrypted information (e.g., speed
limits, track layouts, speed of other trains on the system, and train compositions) and transmits
the authorization for individual trains to move into new track segments. Operating PTC on
commuter railroads presents a variety of back office requirements. Railroads that dispatch trains need to invest in a complete set of upgraded dispatch systems and Back Office Servers.

Employee Training
All employees who perform dispatch, operations, and signaling, as well as roadway workers and
supervisors, must be trained and are essential for successful PTC implementation and operation. The commuter rail industry must train approximately 15,000 employees for full PTC operations.

PTC Implementation Progress

Commuter railroads are making strong and continuous progress in implementing positive train
control. These railroads have faced, and continue to face, a variety of complex challenges in
implementing PTC including financial, technological, and logistical challenges. Some commuter
railroads have overcome these significant hurdles, but other railroads continue to grapple with
PTC implementation issues. Moreover, these railroads are faced with installing, testing, and
implementing PTC on an enormous and complicated network of interconnected railroads while
still providing daily service to millions of Americans, in and around many of our nation’s most
important metropolitan regions.
The commuter rail industry continues to make substantial progress in implementing PTC
according to updated analyses conducted by APTA, and as of June 30, 2018:

  • 91% of spectrum has been acquired;
  • 85% of 13,698 pieces of onboard equipment have been installed on locomotives, cab
    cars, etc.;
  • 79% of 14,083 wayside (on-track equipment) installations have been completed;
  • 78% of back office control systems are ready for operation;
  • 74% of 14,847 employees have been trained in PTC; and
  • 34% of commuter railroads are in testing or revenue service demonstration; or service is fully operational.

These percentages represent significant increases from the status of PTC implementation on
commuter railroads compared to six months ago (the end of calendar year 2017).

Overcoming Challenges to PTC Implementation

Total Cost—More than $4 Billion
PTC will cost commuter rail operators approximately $4.1 billion to implement, and an
estimated additional $80 million to $130 million each year to operate and maintain. For publiclyfunded agencies that rely on federal, state, and local funding, as well as passenger fares to operate their service, these costs are staggering.

Moreover, these costs are in addition to the existing $90 billion backlog needed to bring the
current public transportation system into a state of good repair, as estimated by the U.S.
Department of Transportation. A recent survey of commuter railroad agencies found that many
commuter railroads have state-of-good-repair needs that far outweigh their capital budgets, even before including the additional costs associated with implementing PTC. As a result, to fund PTC, commuter railroads have had to divert funds from other critical infrastructure and safety projects, such as replacing bridges (some of which that are more than 100 years old),
rehabilitating outdated locomotives, and upgrading tracks and safety systems.

Limited Federal Funding
The enactment of RSIA coincided with the 2008 global financial crisis and a multi-year period of short-term SAFETEA-LU extension acts and transportation appropriations continuing
resolutions making it difficult for public transit agencies to plan and fund major projects like
PTC. Since Congress mandated PTC, the federal government has directly provided barely one-tenth ($435 million) of the necessary funding for commuter railroads to implement PTC.
Moreover, more than 80 percent of this funding ($360 million) has only been awarded in the last 16 months (since May 2017). In addition, two commuter rail operators have also secured federal loans to help pay for PTC implementation. While this financing has been helpful, the burden of repaying these loans still falls on public agencies that are already under financial pressure.

We urge Congress and the administration to consider these costs and provide additional funding to enable publicly-funded commuter railroads to quickly implement, operate, and maintain PTC, as well as address the massive backlog of other deferred critical infrastructure and safety projects. Additional funding would not only help commuter railroads continue to achieve the necessary milestones to implement PTC, but it would also allow them to address critical and costly interoperability challenges and system-wide reliability improvements after PTC deployment. As previously noted, the annual ongoing cost of PTC for publicly-funded commuter railroads is estimated to be between $80 million
and $130 million.

Limited Vendors and Expertise
PTC is specialized rail signaling and communications equipment and there are a very limited
number of manufacturers of this technology. A limited number of PTC-qualified vendors are
simultaneously in demand by freight, intercity passenger, and commuter rail operators to
develop, design, and test this complex safety technology, and it has been a significant challenge
for the industry. In addition, the procurement process employed by public transit agencies is
more rigorous and time intensive, which hindered some agencies’ ability to advance contracts.
Moreover, the scale of large freight railroad PTC procurements made it difficult for commuter
railroads, which typically contract for much smaller procurements, to compete in the limited

Installing and commissioning PTC requires highly-qualified signaling, communications, and
software engineers. Workforce development is a critical issue in public transportation generally. With so many railroads implementing PTC at the same time, worker retirements and limited available expertise in the specialized communications and signaling fields, where institutional knowledge is crucial, has taxed the nationwide implementation effort.

Communications (Spectrum and Towers)
Many commuter railroads have also faced significant issues in accessing and acquiring the
necessary radio spectrum. Railroads often attempted to secure spectrum on the secondary market, only to encounter issues such as questions about ownership and legal authority to sell,
unavailability in required geographic areas, and cost-prohibitive contractual requirements. Some railroads contracted their spectrum usage to the host railroads on which they operate, which created other issues that needed to be addressed.

Commuter railroads also may be subject to contractual constraints imposed by state and local
governments. For instance, receiving government approval to use a sole-source procurement to
acquire spectrum can take a very long period of time.

Finally, after spectrum is acquired, commuter rail PTC systems are subject to radio interference
from freight railroads operating on or near commuter rail territory that can overwhelm commuter rail PTC signals and render the system vulnerable to failure. Complex, and sometimes costly, solutions must be developed to mitigate this operational problem.

Equipment Installation and Training
Commuter railroads do not have surplus equipment or personnel, and the impact of PTC
implementation on daily service has been significant. It is extremely difficult to operate the level of service that our customers rely upon when railroads must remove railcars and personnel from service for onboard equipment installation and training and work on multiple territories simultaneously.

Most locomotives and other operating equipment must be reconfigured to accommodate the
installation of PTC components, which has led to higher costs and longer schedules to implement PTC than initially predicted. To provide an example of the level of effort required to install this hardware, it generally takes one person working for one complete month to equip one locomotive or similar controlling equipment. Moreover, this example does not take into account the design and proof-of-concept work that is needed prior to equipage. Similarly, many railroads must upgrade track components such as switches and signals to be reported by the Wayside Interface Units. Commuter railroads face the same challenges in equipping the wayside components as private-sector freight railroads, but with far more limited development and testing resources.

In addition, railroads installing I-ETMS must maintain extensive back office capability to
interact with the overall PTC network. Recognizing this requirement as a key resource constraint for commuter railroads, APTA, in conjunction with FRA, worked with suppliers to develop a cloud-based back office system. In 2015, FRA provided approximately $5 million for this initiative. The shared back office provides for efficient operations, software maintenance,
communications software updates, train initialization, and other key features. Several suppliers
now offer this service.

Commuter railroads face different operating environments. Railroads operate as hosts on tracks they own, as tenants on other railroads tracks (e.g., freight railroads, Amtrak), or a combination of the two environments. PTC must have the ability to interface and function with different operators that share use of a section of track. In metropolitan areas, several different rail carriers often operate on one section of track. For instance, Metra, a Chicago-area commuter rail operator, has 13 required rail partners for its service area. Moreover, interoperability requirements are very complex for both testing and implementation. It continues to be a challenge to ensure compatibility and requires close coordination and communication between host and tenant railroads. Commuter railroads continue to diagnose and resolve software issues and address complex interoperability issues as they begin testing the system in RSD.

Overall, there are 28 commuter railroads vying for a limited number of resources related to PTC. As you can imagine, the systems are at various stages of the process. It is important to note that commuter railroads must continue to serve their customers during this process. Each day, systems must delicately balance PTC installation and serving their customers as they work to continue to safely carry passengers on 500 million trips per year.


On behalf of APTA, I want to reiterate the public transportation industry’s long standing and
continued commitment to install PTC. The nation’s commuter railroads are aggressively working to implement PTC by the statutory deadlines, and right now, thousands of workers across the country are working trackside or in back offices to make that happen.

As a former CEO of the Pittsburgh and Orlando public transit systems, I know first-hand how
passionate public transportation leaders are about the safety of our riders, employees, and
communities. We joined this industry to make a difference in the lives of millions of people by
providing access to opportunities. We don’t just move people; we connect people to what they
need, love, and aspire to achieve—and we do it safely and reliably.

APTA is grateful for the work that this Committee has done to make our nation’s railroads safer. We look forward to continuing to work with you and your staff on this and many other issues that face public transportation agencies.

Enclosed is an APTA Fact Sheet on Commuter Rail and Positive Train Control


PTC is deployed by commuter railroads in three basic forms:
1. I-ETMSTM (Interoperable – Electronic Train Management System): In general, railroads that share track with freight railroads are installing and implementing a system known as I-ETMS, a GPS-based technology heavily dependent on the nationwide 220 MHz radio network. All wayside elements are monitored and reported to the locomotive. Track conditions and restrictions are delivered to the locomotive and reported to the operator for action. The system monitors the action of the operator and reacts if safety is compromised. I-ETMS supports interoperability with freight railroads. FRA granted type approval to IETMS on February 4, 2015.

2. ACSES (Advanced Civil Speed Enforcement System): In general, railroads that operate on the Northeast Corridor are installing and implementing an Amtrak-developed system known as ACSES, which uses track-mounted transponders to deliver information to the locomotive. ACSES monitors actions of the train operator and intervenes if safety is compromised. It facilitates interoperability among operators on the Northeast Corridor. FRA granted type approvals to ACSES variants between 2010 and 2013.

3. E-ATC (Enhanced Automatic Train Control): In general, small commuter railroads that do not require complex interoperability with other operators are installing and implementing E-ATC, a track circuit-based system that is less complex and therefore less expensive than either I-ETMS or ACSES. FRA granted type approval to E-ATC on March 11, 2016.



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