Amtrak is exploring a corporate restructuring, intending to improve service. There is detailed information on Amtrak’s website. Deadline for feedback is Oct. 30, 2026.

Here is my submittal to Amtrak as an individual, not representing CRA.

Tom White
VTD Rail Consulting
CRA Technical Advisor

In principle, the restructuring plan sounds reasonable. However, there are points that have not been addressed, or sufficiently addressed.

• Amtrak owns 623 of its 21,400 route miles. The presentation material demonstrates the applicability of the infrastructure unit to Amtrak-owned track. The presentation material doesn’t seem to address the condition and requirements of infrastructure that Amtrak operates on but does not own. There must be a mechanism for Amtrak to ensure that it has the infrastructure needed for service on routes it does not own.

• The presentation material does not relate an inter-unit relationship, just that the parent company will coordinate. There have been examples of this kind of structure resulting in the infrastructure and fleet departments operating within their own requirements, leaving service to figure out how to best use what the infrastructure and equipment they are given. The business structure must place infrastructure and operation in the position of providing what service needs.

• Business unit goals must be established in a way that prevents a unit pursuing its goals to the detriment of another unit.

• The service unit addresses an extremely diverse area of responsibility.
  • Amtrak is a tenant on 97 percent of its route miles. Tenancy involves a complex relationship that does not appear to be thoroughly addressed. It apparently falls among the areas of responsibility of the business units, but management of the tenancies does not appear to be fully addressed. Performance failure might be caused by operating/dispatching practices, infrastructure inadequacy, inadequate arrangements for handling mechanical failures while on host railroads, or other causes, exacerbated by propagation due to inadequate arrangements between Amtrak and the host. The proposed structure does not adequately address host relationships.
  • State sponsored services are also a complex arrangement that can involve infrastructure, fleet, and service involvement and coordination as well as host relationships. The proposed structure does not adequately address state sponsored services.
  • Amtrak has an extremely diverse service area. Service in Florida has substantially different characteristics from service in the mountain, desert, northern plains, and eastern Midwest regions, for example. The proposed arrangement does not adequately address the geographically, topographic, and climatic diversity of the Amtrak system.
  • The service unit encompasses customer relationships, the logistics of supplying trains, the logistics of train crew supply and customer service crew supply, which have substantially different requirements and characteristics.

Primary division by regions and secondary division by Infrastructure, Fleet, and Passenger Service could be considered.

• The role of the parent corporation is not clear. Will the parent corporation act on policy at board level or provide direct coordination of the units? For example, a Maintenance Of Way activity may affect train punctuality, which will then affect equipment maintenance and availability. A recoverably late train may affect scheduled Maintenance Of Way activity. Such situations occur regularly. Without a directly involved coordinating entity, decisions may be beneficial to one business unit when an alternative may benefit the company.