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, 30 commuter railroads across America safely
carry passengers on more than 500 million trips. And traveling by
commuter and intercity passenger rail is 18 times safer than traveling
Positive Train Control Mandate
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 date:
- 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
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-to-train collisions, over speed derailments, incursions into established
work zone limits, and the movement of a train through a switch left in the
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
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
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 Amtrak-developed 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
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.
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. The status of the components is transmitted
via WIUs to the locomotive to enable the PTC system to take action as necessary.
(Spectrum and Towers)
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.2 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.
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.
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
The commuter rail industry continues to make substantial progress
in implementing PTC according to updated analyses conducted by APTA, and as of June
- 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.
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
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 publicly-funded agencies that
rely on federal, state, and local funding, as well as passenger fares to
operate their service, these costs are staggering.
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
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
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.
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.
(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.
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
also 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.
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
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.
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 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
Overall, there are 30 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 more than 500 million trips per year.
Experience Implementing PTC
Finally, I would like to outline SEPTA’s experience
implementing PTC. Despite a period of historically low capital funding at the
Authority, our Board was committed to implementing PTC. The Board’s support,
coupled with proactive decision making and planning, and some good
circumstances, combined to drive SEPTA’s PTC implementation efforts. Following
our implementation plan, SEPTA received FRA approval to operate ACSES II PTC
provisional revenue service on our Warminster Line in April 2016, and SEPTA
commuter trains have been operating under PTC on all 13 of its Regional Rail
Lines since May 1, 2017.
SEPTA began designing its PTC system in November 2009
without really knowing how we were going to pay for it, but we were fortunate
to have several circumstances fall into place, and we were positioned to take
- In 2013, SEPTA received a $10 million U.S. Department of Transportation TIGER Grant and worked with CSX to physically separate freight and commuter rail operations to address PTC interoperability in a congested corridor where SEPTA’s West Trenton Line operated over the freight carrier’s Trenton branch.
- Counter to industry trends, we had a qualified and highly skilled in-house team that remained intact throughout implementation; and
- Most importantly, at the end of 2013, Pennsylvania enacted Act 89—Pennsylvania’s landmark multi-modal transportation funding bill—which gave SEPTA a future, doubling our annual capital program. The bill provided critical funding to allow SEPTA to begin to address its $5 billion state-of-good-repair backlog while making it possible for SEPTA to aggressively finish PTC implementation.
Without Act 89, and the other good circumstances, SEPTA’s
PTC story would be very different.
Implementing PTC at SEPTA has required a series of
innovative solutions to myriad challenges—cost, limited federal funding,
interoperability, radio spectrum, equipment installation and training, and a
limited number of qualified vendors to accommodate the simultaneous,
industry-wide implementation of PTC. SEPTA’s in-house team has distinguished
themselves in responding to the complexities of implementing a new safety
system across our extensive network in a finite period of time and maximizing
opportunities to install, test, and implement our system. But we would not have
been able to execute our plan without close and productive working
relationships with Amtrak, CSX and Norfolk Southern, our third-party contractor
Hitachi (formerly Ansaldo), and the Federal Railroad Administration.
At a total project cost of more than $344 million,
completing the installation of PTC for a system as large and complex as SEPTA
was, and continues to be, a hard and challenging project. After working through
a number of technical and operational challenges, SEPTA continues to address
interoperability with freight tenants operating on various segments of our
To date, SEPTA has already invested more than $337 million
to implement PTC, following a strategic approach:
- successfully separating SEPTA from CSX on the West Trenton Line;
- systematically rolling out PTC on SEPTA territory beginning in April 2016 and completing PTC implementation on 12 distinct segments by January 2017; and
- activating PTC on the three lines that operate on Amtrak-owned track on May 1, 2017.
SEPTA is proud of its record implementing PTC for our
customers and employees, and yet we still have work to do.
With three major phases completed, and with SEPTA trains
operating with PTC on all 13 Regional Rail Lines, the final major focus is
completing the task of establishing interoperability with the freight lines—CSX
and Norfolk Southern—operating along portions of SEPTA territory. Working with
our freight partners, this phase of the program is scheduled to be completed by
Although we have had success in our implementation efforts,
no two commuter railroads are the same—each has different operating
environments, equipment, host-tenant relationships, and ridership—so no two PTC
experiences are going to be alike. What we do have in common, though, is a
commitment to safety and implementing PTC on our systems. That commitment is
shared by our employees—who embraced SEPTA’s PTC efforts during training and
installation and now in revenue service—and our customers—who experienced
schedule adjustments and service changes during implementation. SEPTA’s PTC
effort would not be where it is without their professionalism and patience.
Safety is the shared responsibility of every commuter
railroad in the country, and the current nationwide effort to implement
positive train control is a critical initiative that reflects the industry’s
commitment to strengthening safety. 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.
APTA is grateful
for the work that this Subcommittee 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
- 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 I-ETMS on February 4,
- 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.
- 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.