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American Public Transportation Association

 To Senate Committee on Commerce, Science, and Transportation to Clarify APTA’s Position on Positive Train Control (PTC)

 3/23/2015

​The Honorable John Thune
Chairman
Senate Committee on Commerce, Science, and Transportation
560 Dirksen Senate Office Building
Washington, DC 20510

The Honorable Bill Nelson 
Ranking Member
Senate Committee on Commerce, Science, and Transportation 
560 Dirksen Senate Office Building
Washington, DC 20510 ​

​(Download Document in Adobe PDF format)

Dear Chairman Thune and Ranking Member Nelson:

The Rail Safety Improvement Act of 2008 (RSIA, P.L. 110-432), mandates that all passenger railroads and certain freight railroads install Positive Train Control (PTC) technology by December 31, 2015. With the recent introduction of S. 650, a bill to extend the PTC system implementation deadline, by Senators Blunt, McCaskill, Thune, and Nelson, the American Public Transportation Association (APTA) on behalf of the nation’s commuter railroads submits this letter to clarify APTA’s position on PTC.

APTA’s commuter railroads are committed, as a national safety priority, to implementation of PTC on all commuter and intercity passenger rail lines. Commuter railroads have spent hundreds of millions of dollars on the implementation of the PTC systems as the statutory deadline fast approaches. Like commuter railroads, the nation’s freight railroads have worked to install PTC on their railroads and to make those systems interoperable with those on passenger railroads, and they have invested enormous sums in that effort.

Notwithstanding the efforts and expenditures to install PTC by the statutory deadline, both APTA and the Association of American Railroads, on behalf of freight railroads, have repeatedly expressed concern to the Congress about the ability to fully implement PTC on all of the covered commuter and freight systems by the current deadline.

Implementation of PTC on commuter railroads, and on freight railroads, has been dependent on the development of much new technology, including software, various hardware including radios, and roadway worker protection. Access to necessary radio spectrum, requisite PTC towers and antennas, all of which are subject to Federal Communications Commission (FCC) approval, and budget constraints at many public funded commuter railroads, have further complicated the task of PTC installation. Even the testing of new equipment before it is operational for revenue service, and getting Federal Railroad Administration (FRA) approval of systems prior to the deadline, add to the challenges. As a result of all of these factors, APTA believes that nationwide implementation of PTC systems on commuter and freight railroads remains almost impossible by the end of 2015.

In an effort to see PTC implemented on the nation’s railroads as safely and as quickly as possible, and recognizing that it is extremely unlikely to be fully implemented by the current deadline, APTA urges Congress to provide the Secretary of Transportation authority to extend the PTC implementation deadline for individual agencies on a case-by-case basis provided they have effectively demonstrated good faith in the implementation of PTC at their agency and an extension is necessary due to factors beyond their control. We also urge Congress to provide federal funding to cover at least 80 percent of implementation costs, including reimbursement of previous investments, for PTC, and we support FCC authority to provide required radio spectrum, without cost, for commuter and intercity passenger railroads.

Commuter rail is a critical component of our national public transportation system and the industry looks forward to working with Congress. Please have your staff contact Brian Tynan of APTA's Government Affairs Department at (202) 496-4897 or email btynan@apta.com with any questions.

​Sincerely,


Michael P. Melaniphy
President & CEO

MPM/bt

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