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FRA Releases PTC Guidance for Railroads

FRA Administrator Sarah Feinberg released guidance Nov. 19 regarding compliance with the Positive Train Control Enforcement and Implementation Act of 2015, which requires that covered railroads submit a revised PTC implementation plan (PTCIP) to FRA no later than Jan. 27.

Revised PTCIPs must provide the following:

* A detailed schedule and sequence for implementing a PTC system by Dec. 31, 2018, including a justification for the schedule and sequence;

* The calendar year(s) in which spectrum will be acquired and available for use in each area as needed for PTC implementation, if such spectrum is not already acquired and available for use;

* The total amount of PTC system hardware that will be installed by the end of each calendar year, with totals separated by each major hardware category;

* The total number of employees required to receive training under the applicable PTC regulations and the total number of employees that will be trained by the end of each calendar year;

* A summary of any remaining technical, programmatic, operational or other challenges to PTC implementation (including challenges with public funding availability, interoperability, spectrum, software, permitting, and testing, demonstration and certification);

* A description of how the PTC system will provide for interoperability of the system with the movements of trains of other railroad carriers over its lines; and

* A description of how, to the extent practical, the PTC system will be implemented in a manner that addresses areas of greater risk before areas of lesser risk.

Additionally, in the updated implementation plans, FRA expects to see the same sequence of track segments that was laid out previously in existing PTCIPs, just rescheduled to meet the new Dec. 31, 2018, implementation deadline.

FRA has posted a submission template accessible here.

Following submittal of the revised PTCIP, and within 90 days, FRA will review and notify each railroad, in writing, of its decision to approve or disapprove each revised PTCIP submitted. If FRA disapproves a revised PTCIP, FRA will explain the reasons in writing and the railroad will have 30 days from receipt of FRA’s notification to correct the deficiencies and resubmit its revised PTCIP.

FRA intends to aggressively enforce the deadlines and requirements of the act, officials say. For example, if a railroad fails to timely file or resubmit a revised PTCIP as required, FRA may, among other enforcement actions, assess a civil penalty of at least $5,000 per day.

For questions about this guidance, contact Jason Schlosberg. For t­echnical questions about preparing a revised PTCIP, contact Devin Rouse.

APTA is arranging a conference call in mid-December so officials of APTA member commuter railroads can obtain further guidance.
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