GEORGIA DEPARTMENT OF TRANSPORTATION

Transcription

1 EXECUTIVE SUMMARY This Special Assessment Cap Log is presented in this format to reflect all of the positive actions taken on the part of the Atlanta Streetcar (ASC) team in responding to the Department s previous comments to their last submittal review. It should also reflect the numerous work sessions that ACS has requested and the technical support the Department has given in a joint effort to effectively respond to the CAPs. As shown in the table below, you will find that the color coding has changed from the last report as a result of the significant work done by ASC to move 100% of the CAP responses to an Accepted status. The timeline of progress is detailed below. / November 2016 On October 25, 2016, the Department completed its formal review of the ASC CAP Log submittal and recommended a series of work sessions be held to provide feedback and technical assistance to ASC. In November 2016, the Department facilitated a series of informal on-site work sessions with ASC and also completed on site verification of numerous supporting records and documentation. As result of these coordination activities, on November 18, 2016, the Department determined the following: 66 Accepted CAPs 57 Open CAPs 9 Closed CAPs December 2016 / On December 7, 2016, the ASC provided an updated CAP log and supporting documentation. Subsequently, on January 19, 2017, ASC provided a revised System Safety Program Plan (SSPP), Security and Emergency Preparedness Plan (SEPP), Sustainability Action Plan (SAP), and other required materials. On January 26, 2017, the Department conducted another informal on-site work session with ASC where the Department received tracked changes versions of the SSPP, SEPP, SAP, and other materials. On January 27, 2017, the Department completed its review and determined the following: # of Required Responses # of Adequate Responses Received Percentage of Progress Completion ACCEPTED % CLOSED 20 30% OPEN 46 The Department acknowledges the vast improvement in both the quality of the submittal responses and the effectiveness of the ASC team. Based upon the improvements shown we are confident in Atlanta Streetcar s ability to address the remaining CAPs in a timely and effective way. Page 1 of 89

2 SA-CAP.OPS.001, Provide Stable and Adequate Staffing for Supervision and Rules Compliance: The Atlanta Streetcar System must provide stable and adequate staffing resources with the requisite training, qualifications and experience to perform the required supervision and rules compliance activities of all operations and maintenance functions as specified within the System Safety Program Plan, Security and Emergency Preparedness Plan, and related plans and procedures. The assignment of duties must ensure clear division of roles and responsibilities between the Superintendent, Supervisor, Dispatcher and Technicians. Atlanta Streetcar must also ensure that the level of supervision for operations and maintenance activities is safely and sufficiently balanced with the level of passenger service delivered. In addition, the Atlanta Streetcar System must follow through with its commitment to review its operations and maintenance job descriptions, to review of the System Safety Program Plan and Security and Emergency Preparedness Plan (and other related plans and procedures as applicable), to revise the plans and procedures accordingly for consistency, and to ensure all roles and responsibilities are clarified to adequately address the issues and concerns raised in the entirety of the Special Assessment Report. Response Accepted / Closed ASC indicated that the Executive Director and Compliance Manager are assigned the task to approve job descriptions, ensure candidates meet qualifications, training, education and knowledge for each position, and verify all current employees are qualified by November 1, The Department is seeking clarification and documentation of what did HR and Leadership confirm in terms of the minimum qualifications and job descriptions if the Executive Director and Compliance Manager have been assigned the task to make this evaluation? Is this not a future task? GDOT: The ASC September 2016 submittal CAP Schedule, p.2, Planned Completion Date of 8/1/2016, notes a minimum staffing threshold methodology that included historical knowledge and other metrics was used; however, the Department also noted the following language in this response and several other CAP responses, ASC confirms that an adequate staffing assessment has not been performed. The Department is seeking clarification as these are conflicting statements; however, the later statement better aligns with another ASC response (CAP.HR.028) noting that a contract was to be issued to conduct a staffing assessment. ASC: ASC has hired a contractor for the performance of the Atlanta Streetcar staffing assessment. The staffing Assessment is scheduled to be completed by the end of December Upon completion of the assessment, a copy of the report will be submitted to the state for review. GDOT: The Department s review of the ASC 3 rd party Staffing Assessment confirmed the adequate staffing of the organization consistent with APTA Standards and the comparison to similarly sized transit organizations. This CAP is therefore closed. Page 2 of 89

3 ASC reported that amendments to the job descriptions were made. ASC did not provide the documentation of its process to confirm the qualifications, knowledge, skills, and abilities for each position nor did ASC provide the job descriptions. At the same time, ASC indicated this is a future task. The Department is seeking clarification. GDOT: The ASC September 2016 submittal for CAP.OPS.2 included detailed job descriptions for all positions identified in the accompanying Position/Threshold Staffing Matrix. ASC: No comment. GDOT: Closed ASC reported that the organizational chart was revised to reflect the current organizational structure and minimum staffing thresholds, with emphasis on safety critical positions. While ASC provided an organizational chart listing of authorized FTEs, the Department remains concerned about the number of vacancies which was the basis of multiple findings within the Special Assessment. Also, the ASC did not provide a narrative discussion of the criteria and methodology to determine appropriate number of FTEs displayed on the proposed organizational chart. GDOT: The Department accepts the plans included in the CAP schedule to recruit and hire a Contracting Officer. ASC should provide updates on their progress of implementation of their strategy. ASC: As stated in the response issued above, one of the deliverables from the staffing assessment consultant hired by ASC is to provide a narrative that will define the criteria and methodology to determine the appropriate number of FTE shown on the attached revised Future State Organizational Chart. GDOT: Closed ASC must provide a response that addresses the Department s review comments regarding the organizational structure included as Attachment 1, Sustainability Action Plan and Attachment 2, Define and Stabilize the Organizational Structure. In general, the response must address stable and adequate staffing resources for the current organizational phase in addition to the future transitional phases. GDOT: The Department accepts the plans included in the CAP schedule to recruit and hire a Contracting Officer. ASC should provide updates on their progress of implementation of their strategy. Page 3 of 89

4 ASC: In response to your comment, To Define the Sustainability Action Plan and Define and Stabilize the organizational structure, ASC confirms that the response to CAP.MGMT.055 will address the department s concerns. GDOT: Closed Page 4 of 89

5 SA-CAP.OPS.002, Flatten the Organizational Structure: The Atlanta Streetcar System must ensure that any consolidation of duties and responsibilities in order to flatten the organizational structure does not result in any given position being faced with a conflict of interest. To explain, in order to preserve the integrity of the independent auditor function as defined within the Internal Audit Program Plan adopted by the Atlanta Streetcar System, a position may not directly manage a function and also perform compliance audits for adherence to safety and security requirements for that same function. Response Accepted / Closed ASC reported that the positions and functions were reassessed and the organizational chart and job descriptions were revised. While the ASC provided an organizational chart, the ASC did not provide an explanation of its assessment criteria that led to that structure or the corresponding job descriptions. At the same time, ASC reported that the revisions to the job descriptions are a future task. The Department is seeking clarification on the actual status of this activity. GDOT: The ASC September 2016 submittal for CAP.OPS.2 included detailed job descriptions for all positions identified in the accompanying Position/Threshold Staffing Matrix. However, ASC provided no explanation of its assessment criteria. ASC: ASC studied the organizational structure and job descriptions of similar transit agencies, and used those organizational charts and job descriptions as the basis for ASC organizational structure. As referenced in Atlanta Streetcar response to CAP 01 Box 1, ASC has awarded a contractor to a consultant to perform staffing assessment. GDOT: The Department reviewed an updated organization chart during the onsite work session to confirm a flattened organization with clear lines of authority. While ASC provided an organizational chart listing of authorized FTEs, the Department remains concerned about the number of vacancies which was the basis of multiple findings within the Special Assessment. Also, the ASC did not provide a narrative discussion of the criteria and methodology to determine appropriate number of FTEs displayed on the proposed organizational chart. GDOT: The Department accepts the plans included in the CAP schedule to recruit and hire a Contracting Officer. ASC should provide updates on their progress of implementation of their strategy. ASC: Please refer to ASC response to CAP 01 Box 3, regarding the narrative discussion of the criteria and methodology during the staffing assessment. Page 5 of 89

6 GDOT: Closed The ASC must provide a response that addresses the Department s review comments regarding the organizational structure included as Attachment 1, Sustainability Action Plan and Attachment 2, Define and Stabilize the Organizational Structure. GDOT: There were no additional verification documents included to address this area of concern. ASC: Please see ASC response to the department concerns in CAP 1 Box 4. : ASC: During the working session, an updated organization chart was presented to GDOT which showed a flattened organization structure that has been established by ASC. GDOT: Closed Page 6 of 89

7 SA-CAP.OPS.003, Fulfill Organizational Resource for Rail Engineering: The Atlanta Streetcar System must fulfill the organizational resource for a Rail Engineering Consultant with the requisite expertise to support streetcar-specific systems, facilities, and infrastructure as identified in the adopted SSPP for the Atlanta Streetcar System. This corrective action is imperative in light of the findings and recommendations from multiple reports, studies, and inspections performed by subject matter experts retained at the direction of the Atlanta Streetcar System and MARTA. These studies concluded that the Atlanta Streetcar System must provide engineering oversight for configuration management and maintenance support, as there does not seem to be substantial support for maintenance crews. The studies also concluded engineering should be involved in equipment and system failures to assist in determining the nature of the failure and providing recommendations to avoid further failures of the same nature. Yet another study concurred that the Atlanta Streetcar must ensure engineering participation and oversight in maintenance and construction. Response Accepted / Open ASC must provide specific verification of the inclusion of rail engineering services within the O&M RFP. GDOT: Exhibit A which was included as a part of the ASC submittal (p.6 of 11) does not provide sufficient verification of either the short-term or long-term strategies included in the ASC schedule. The cancellation of the O&M RFP eliminates the long-term strategy. The short-term strategy implementation date of 9/9/2016 on the ASC CAP schedule (p.3 of 11) involved submitting a scope of work to six (6) existing engineering firms already under contract with the City of Atlanta; however, The Department could not verify the scope of work had been developed and submitted by ASC to the engineering firms. ASC: ASC acknowledges the current RFP for the O&M services does not include the requirement for providing rail engineering. After careful consideration, ASC has decided not to use the in-house Architectural & Engineering (A&E) contractor for the short-term solution of the rail engineering consultant, and instead ASC decided to issue a separate RFP for a long term General Engineering Consulting services. GDOT: The Department accepts the plans included in the December submittal. ASC should continue to provide regular updates and supporting documentation on the implementation of these actions until closed. Page 7 of 89

8 SA-CAP.OPS.004, Fulfill Organizational Resource for Data Reporting Analyst: The Atlanta Streetcar System must fulfill the organizational resource for a Data Reporting Analyst. In doing so, the Atlanta Streetcar System must ensure the qualifications and experience of this resource enables full compliance with transit agency, state, and federal reporting requirements for operations, maintenance, safety and security as identified in the SSPP, SEPP and related procedures for the Atlanta Streetcar System. This corrective action is important given the lack of timely and accurate reporting to the Department in a number of required areas including the notifications, status reports, final investigation reports, and corrective action plans for reportable accidents, security incidents, and unacceptable hazards. Response Accepted / Closed The Department requests that the next status update for this CAP define the training for Data Reporting Analyst, particularly as it relates to safety, security, emergency management reporting. This is requested, if the intent is to move the reporting relationship for this position to the Director of Safety, Security, and Training. GDOT: There was no update to CAP included in the September submittal. The Department observed that the response does not address how the SSPP will be reconciled. When is job description going to be updated and provided to the Department for review? Provide an updated schedule for these activities. GDOT: There was no update to CAP included in the September submittal. ASC: ASC confirms that a baseline job description is in place; the position has been filled, and will be included in the staff assessment to be provided by the staffing consultant. GDOT: Closed. Page 8 of 89

9 SA-CAP.OPS.005, Fulfill Organizational Resource for Contracting Officer: The Atlanta Streetcar System must fulfill the organizational resource for a Contracting Officer. The rationale for this corrective action is based upon the fact that the Procurement Manager is serving in a dual role because the Contracting Officer position is vacant. This has resulted in the procurement function for the Atlanta Streetcar System being inadequately staffed. As such, there is not a dedicated resource charged with responsibility for ensuring adherence to safety features and standards in the procurement process. Moreover, there is no dedicated Contracting Officer to assist the Procurement Manager with a series of safety-critical procurements, namely the development of a procurement strategy for long-term vehicle maintenance and accurate cost estimation and procurement options for TPSS and OCS maintenance. The issue of cost estimation bears repeating as there has been more than one instance where inaccurate cost estimation has led to the inability of the Atlanta Streetcar to move forward with the award to maintenance contracts for its safety-critical infrastructure. This corrective action is also supported by the circumstances surrounding the roles and responsibilities of the Director of Streetcar Services. While the SSPP and other relevant plans indicate that this position will provide technical assistance to other departments to ensure that assigned equipment/material procurement contracts are implemented in accordance to contractual requirements; this position is in fact not fulfilling these roles as described in the SSPP. This is all the more reason that the Atlanta Streetcar System must ensure that the Contracting Officer resource is filled. Response Accepted / Closed RESPONSE ACCEPTED The ASC should provide supporting documentation for the completed actions steps in the recruitment process for the Contracting Officer. The Department further suggests that the ASC develop a system-wide Recruitment and Hiring Plan for all-staffing related CAPs to enable consolidation, reporting, and tracking to the Department. ASC: Interviews for the position of contracting officer were held the week of November 28, 2016 resulting in an offer being made to the selected candidate. Tentative reporting date is January 12, : ASC: ASC informed GDOT that the Contracting Officer position was filled with the new team member starting today, January 26, Evidence confirming the position was filled was presented to GDOT during the work session. GDOT: Closed Page 9 of 89

10 SA-CAP.OPS.006, Develop a Long Term, Comprehensive Vehicle Maintenance Program: As discussed during the interviews, body repair alone is not an adequate long term, comprehensive vehicle maintenance program for all components and subcomponents of the streetcar vehicle which include, but are not limited to: car body; operator s cab; passenger doors; heating, ventilation and air conditioning; lighting; general electrical equipment; propulsion system and control; truck assemblies; brake systems; vehicle communications, passenger information, closed circuit television; event recorder; and interior and exterior appointments. The Atlanta Streetcar System must ensure that the Maintenance Plan, procedures, checklists, and forms as well as third-party contracts are developed and implemented to address this safety-critical function. Response Accepted / Open PROGRESS UPDASTES: The Department is seeking clarification to its vehicle maintenance questions and discussion within the response that describes the strategy to procure a 3 rd party contractor and how that will impact the O&M Plan, specifically vehicle maintenance, how ASC will sustain the vehicle maintenance program for the current operational phase, and how it will transition. GDOT: The September 2016 submittal adequately addresses how ASC will sustain the vehicle maintenance program in its current phase with screen shots from its FMIS showing ASC assets, inventory, repair codes, inspection status, work orders, and other screens. It does not address any of the other requirements to provide an acceptable response. Specifically, as it relates to the strategy to procure a 3 rd party contractor and how it will impact the O&M Plan, the Department was unable to see a detailed and connected plan. This was particularly difficult given the missing information in the references listed in CAP Schedule, p.5, in completion date entry 9/30/2016 (CAPs 3,7, and 8). ASC: Part of the documentation provided by the light rail vehicle manufacture includes the operations and maintenance manual which is a stand-alone document. This document is currently being used by the maintenance personnel as well as the onsite Siemens technical representative. ASC confirms that heavy repair, such as trucks overhaul, will be performed through the use of interagency agreements with other agencies and/or future contracts with Original Equipment Manufacturers (OEM). ASC plans to perform semi-annual and annual inspections based on a combination of time/mileage (whichever comes first), based on the OEM recommendation. GDOT: The Department accepts the plans included in the December submittal. ASC should continue to provide regular updates and supporting documentation on the implementation of these actions until closed. Page 10 of 89

11 SA-CAP.OPS.007, Fulfill Organizational Resource for Track Maintenance: The Atlanta Streetcar System must fulfill the organizational resource for Track Maintenance. The Atlanta Streetcar System acknowledged that there have been recurring track maintenance issues involving the buildup of debris in the switches and the temporary cleaning measures do not represent a long-term track maintenance solution, which may also need to include drainage re-design, in addition to adequate track maintenance and equipment. The Atlanta Streetcar System also acknowledged that the safety hazard of debris in the switches was noted on various track inspection forms, but that the track inspection results have not been reported to Safety nor have they been entered into the hazard management process for assessment, resolution, and tracking the mitigations to closure. In September 2015, senior officials from the FTA Transit Safety Office voiced concern over the proposed organizational structure because it did not identify a track maintenance contract as a resource to the Atlanta Streetcar System. During the MARTA/Atlanta Streetcar Interface meetings, this topic was also raised. MARTA indicated that the procurement of the following must be implemented quickly: spare power truck, OCS, TPSS, and track emergency services to provide reliable uninterrupted service. Nonetheless, the Interim Executive Director opposed executing a track maintenance contract, but provided no rationale for not securing the resource. Subsequently, in response to the assessment team s request for materials, the Atlanta Streetcar System responded that switch inspection by an outside firm can occur at five-year intervals as there is no significant track work for an outside contractor with embedded track. A corrective action that ensures periodic inspection and corrective maintenance (more frequent than five-year intervals), including procedures, training, and equipment is necessary considering the potential safety hazards of derailment and/or injury to patrons and personnel that may result due to improper or inadequate track maintenance. Response Accepted / Open Provide documentation of robust schedule of inspection that was completed by Maintenance Superintendent, respond to questions for clarification regarding technical training and tools and equipment. Clarify how the ASC daily inspection, emergency repair contract, and OCS/TPSS long-term contract are inclusive of all the track inspection and preventative maintenance requirements identified in the training program. GDOT: The ASC September submittal does not include any schedule of inspection. The two samples of daily track inspections had no date, no signature of person completing the inspection, and no signature of a supervisor verifying the inspection. There is no verification of any inspections or repairs and their impact on the inspection and preventative maintenance requirements in the training program. The submittal did include a Track Maintenance Training Module for Rail Defects which is a MARTA document. The module has not been modified, adjusted or incorporated into the ASC training program, and therefore contains information that does not apply to the streetcar system. ASC confirms we have established a RFP for the emergency on call and regular track maintenance services. Page 11 of 89

12 See attachment for Track Maintenance Matrix. ASC confirms that cleaning of switches is performed using a vacuum. ASC confirms that a solicitation will be issued for the performance of track training. See attachment draft Track Training, Atlanta Streetcar Track System. See attached solicitation document, FC-9139 Emergency On Line Repair and Maintenance for Atlanta Streetcar Track System. See attached solicitation document, FC-9139 Emergency On Line Repair and Maintenance for Atlanta Streetcar Track System and See attachment draft Track Training, Atlanta Streetcar Track System. See attached solicitation document, FC-9139 Emergency On Line Repair and Maintenance for Atlanta Streetcar Track System GDOT: The Department accepts the plans included in the December submittal. ASC should continue to provide regular updates and supporting documentation on the implementation of these actions until closed. Page 12 of 89

13 SA-CAP.OPS.008, Fulfill Organizational Resource for Long-Term OCS Maintenance: The Atlanta Streetcar System must fulfill the organizational resource for long-term OCS Maintenance. While the Atlanta Streetcar System procured the emergency services of a qualified electrical contractor for OCS maintenance, the term of the services expires in approximately 60 days, February During the MARTA/Atlanta Streetcar Interface meetings, MARTA, the active manager of the Atlanta Streetcar System, identified the need for OCS long term inspection, repair, and maintenance contract as a priority. A corrective action that ensures periodic inspection and corrective maintenance (more than in the case of emergencies), including procedures, training, and equipment is crucial considering the potential safety hazards of shock, catastrophic injury to patrons or personnel, and the loss of system service or major delays that may result due to improper or inadequate OCS maintenance. Response Accepted / Closed The Department is seeking a response that assures a comprehensive, long-term OCS / TPSS maintenance program beyond the three specific tasks outlined in the contract scope (emergency repair, seasonal adjustment, annual inspection), provides a feasible schedule for implementation including training activities. GDOT: The September 2016 submittal does not include any actual or proposed amendments to the longterm OCS / TPSS solicitation that assures for a comprehensive maintenance program beyond the three specific tasks previously outlined. The was unable to verify that the contract scope adequately reflects the existing maintenance requirements detailed in ASC s maintenance SOPs. ASC: As part of the long-term solution, The Atlanta Streetcar is in the process of soliciting a for the Traction Power Training, Atlanta Streetcar Overhead Contact System and Traction Power Substations (OCS/TPSS) that address the maintenance requirements of ASC maintenance SOPs. See attached Request for Quotations for Traction Power Training, Atlanta Streetcar Overhead Contact System and Traction Power Substations. GDOT: The Department confirmed during its onsite work session the execution of a new two (2) year contract with two one (1) year extensions with C3M for its OCS maintenance and emergency repairs program. This CAP is closed. Page 13 of 89

14 Response Accepted-Action Required / Closed GDOT: The Department accepts the plans included in the December submittal. Page 14 of 89

15 Page 15 of 89

16 GDOT: Closed Page 16 of 89

17 SA-CAP.OPS.010, Integrate Transit Signal Maintenance into Daily System Management: The Atlanta Streetcar System must integrate the transit signal maintenance program into its day-to-day performance management, operations, maintenance, and system safety activities, particularly the hazard management process. This corrective action is important for several reasons, including the circumstance where Atlanta Streetcar System operators were experiencing a daily failure of a transit signal at a specific location and at the time of the assessment there was no coordinated process between the third party contractor, the City s contract administrator, and the Atlanta Streetcar System s operations and safety personnel for the identification, reporting, and resolution of signal defects and hazards. This corrective action is equally important because of the need to develop and implement a comprehensive and integrated maintenance management information system for all safety-critical assets, including transit signals. The corrective action plan must ensure that the tracking and reporting of safety deficiencies and defects from routine inspections and maintenance performed by third party contractors as well as daily observation reports from Atlanta Streetcar operations personnel, are effectively coordinated with the hazard tracking log managed by Atlanta Streetcar safety personnel. Atlanta Streetcar System must update the System Safety Program Plan and related operations and maintenance plans and procedures to describe the processes, roles, and responsibilities for transit signal maintenance. Response Accepted, Action Required / Closed ASC must respond to the Department s questions and provide verification of completed corrective actions taken which include the MMIS modification to capture transit bar signal maintenance data, and a formal, signed Signal QA Defect Procedure. GDOT: The September submittal included verified proof of the 3 rd party maintenance work being uploaded into the ASC MMIS. According the CAP Log Schedule, p.5, completion date 9/15/2016, the signed Signal QA Defect Procedure was not completed at the time of the submittal and was planned to be submitted to the SCSC on 9/15/2016. ASC: Please see attached QA Defect SOP. ASC reported that traffic signal equipment maintenance including transit signal is the responsibility of DPW. ASC reported that maintenance is performed directly by DPW or through third-party contractor arrangements. During the Special Assessment, the Department confirmed that transit signal maintenance was being performed by a contractor to ADID. Is this still the case, and how does this relate to the ASC s report that transit signal maintenance is the responsibility of DPW. Please clarify. GDOT: In the September 2016 submittal, CAP Log Schedule, p.4, 8/23/2016 Completion Date, ASC notes that an agreement was executed between COA and ADID who in turn contracts with a 3 rd party. However, there was no proof provided that would allow the Department to verify the existence of this formal agreement which would make ADID responsible for a safety critical component of the streetcar system. Page 17 of 89

18 ASC: Please see attached Agreement b/w ADID and City regarding DTOP. GDOT: Based upon the wok session, the Department confirmed the presence of the required procedures in existing SOP s. This CAP closed. Page 18 of 89

19 SA-CAP.OPS.011, Identify/Evaluate Decision-Making Groups and Committees: The Atlanta Streetcar System must identify all of the decision-making groups and committees (internal and external) that have authority to make decisions related to the implementation of the System Safety Program Plan, Security and Emergency Preparedness Plan, and related operations and maintenance plans and procedures. Once identified, the Atlanta Streetcar System must evaluate the quality and effectiveness of these groups, restructure as required, and revise the System Safety Program Plan and other related plans to describe each committees roles and responsibilities. Response Accepted / Open ASC reported that the SSPP (3.0, 3.6, 3.7, 3.8), SEPP (1.6,1.7), and IGA (relevant sections) will be updated by January 31, GDOT: There were no new updates provided for this CAP. Due date remains as January 31, ASC: ASC confirms that the due date for the submittals of revisions to the governance remains on track for January 31, GDOT: The Department accepts the plans included in the December submittal. ASC should continue to provide regular updates and supporting documentation on the implementation of these actions until closed. Page 19 of 89

20 SA-CAP.OPS.012, Finalize Job Descriptions for All Personnel: The Atlanta Streetcar System must finalize job descriptions, including the minimum qualifications, training, and experience required for all personnel, particularly Superintendents, Supervisors, Dispatchers and pending positions under review. The corrective action is necessary because the Atlanta Streetcar System has not established the minimum qualifications and training standards of supervisory personnel who are responsible for ensuring compliance to safety, operations, and maintenance rules and procedures. For example, while in recent months leading up to the assessment the street of Streetcar Services, Operations Superintendent, Maintenance Superintendent, Dispatcher, and Director, Safety, Security and Training performed ride checks, none of these positions shared Operator qualification and certification classroom and field training as a minimum qualification and training standard set by the Atlanta Streetcar System. Moreover, at the time of the assessment, an Operations Supervisor was experienced in maintenance rather than operations, and because of his lack of qualifications and training in operations, he was not performing the rules compliance activities mandated by the System Safety Program Plan. The Atlanta Streetcar System admitted this was an issue that their intent was to reclassify the Dispatchers to Service Supervisors and transition the current Supervisors into Maintenance Supervisors only, aligning their jobs with their skill set. The corrective action must ensure that the Atlanta Streetcar fulfills these organizational commitments. Response Accepted / Open ASC must provide documented evidence of its analysis of the organizational chart and job descriptions to demonstrate minimum qualifications, training, and experience for safety critical positions (including some narrative discussion). ASC must provide a complete set of job descriptions that correspond to the organizational chart. ASC must coordinate the organizational chart and job descriptions with the Department s comments to the Sustainability Action Plan and Operations and Maintenance Plan. GDOT: The September 2016 submittal, CAP Log Schedule, p.3, 8/01/2016 Due Date Entry, states that ASC confirms that an adequate staffing assessment has not been performed. Three job descriptions were missing from the CAP.OPS.002 submittal: Manager-Streetcar Services, Dispatchers, and Director of Safety Security & Training. Also, the Operations Supervisor position was not included on the Position/Threshold Matrix, but the job description was included. ASC: Please refer to response to CAP.OPS.001. GDOT: The Department accepts the plans included in the December submittal. ASC should continue to provide regular updates and supporting documentation on the implementation of these actions until closed. Page 20 of 89

21 SA-CAP.OPS.013, Reconcile MARTA Active Management for Operations with IGA, SSPP, SEPP: The Atlanta Streetcar System must review the organizational chart and the implementation of the active management duties and responsibilities of MARTA for operations, namely the Director of Streetcar Services and Deputy Director of Streetcar Services, to make certain that their roles and responsibilities are accurate and consistent with the adopted agreements and plans, including the System Safety Program Plan and Security and Emergency Preparedness Plan. This corrective action is significant because of the inaccuracies in the actual practices for executive decision-making and day-to-day management of the Atlanta Streetcar by MARTA with the organizational structure, roles and responsibilities described within the IGA and adopted SSPP and SEPP. In other words, the Atlanta Streetcar System must rectify the many instances throughout the SSPP that assigned operations responsibilities to MARTA that were not what MARTA understood its role and responsibilities to be and ensure appropriately trained and qualified personnel fulfill these responsibilities. Response Accepted / Open ASC must expand its response to provide clarification on what the purpose and intent of the proposed revisions will be to the SSPP and SEPP with respect to MARTA active management positions (which from this response include the MARTA COO, Director of Streetcar Services, and Manager of Streetcar Services) throughout all applicable sections of these plans. GDOT: The September 2016 submittal, SSPP/SEPP Revision Matrix, p.7, ASC minimized or eliminated the Director of Streetcar Services position and MARTA s role as active manager instead of expanding and clarifying MARTA s role as required by the Department. ASC: ASC confirms the Director of Operation & Safety, with the assistance of the Director of Streetcar Services, is fully responsible for the management of Atlanta Streetcar. GDOT: The Department accepts the plans included in the December submittal. ASC should continue to provide regular updates and supporting documentation on the implementation of these actions until closed. Because the SSPP and SEPP also include by reference 4 other sub-plans, these plans must also be addressed CAPP, IAPP, AIP, and HMP. GDOT: The CAP Log Schedule, p.3, 9/19/2016 Completion Date indicates that the revisions to the subplans were scheduled after the submittals were provided to the Department. ASC proposed submission date for changes to the SCSSC is October 10, Page 21 of 89

22 [Note: In all instances where the Department references any given plan such as the SSPP or SEPP, it is understood that the requirement extends to the relevant sub-plans and procedures]. ASC: ASC confirms that section 5 of the SSPP will be revised to include an appendix for the Sustainability Action Plan which will describe implementation activities, roles and responsibilities. GDOT: The Department accepts the plans included in the December submittal. ASC should continue to provide regular updates and supporting documentation on the implementation of these actions until closed. Page 22 of 89

23 SA-CAP.OPS.014, Develop Written Process for Management Meeting Action Items/Concerns: The Atlanta Streetcar System must develop a written process that ensures the action items and concerns resulting from the weekly and monthly management meetings with MARTA, are prioritized, have management accountability assigned to manage their implementation, have timely due dates for completion, have adequate resources allocated to resolve them, and are sufficiently documented and tracked to closure. At the time of the assessment, examples of these action items and concerns included the following: Management Ensure Manager of Streetcar Services has flexibility to actively manage the operating budget to support small-to-medium administrative, operational, infrastructural and maintenance procurements, to avoid shortages of basic consumable materials and supplies. Ensure Atlanta Streetcar System has adequate policies and procedures and support documentation for governing the unique aspects of a transit operation, including fare collection. Procurement Quickly procure spare power truck, OCS, TPSS, and track emergency services to provide reliable uninterrupted service. Determine track, long-term OCS, vehicle body, and TPSS procurements. Maintenance Complete development of maintenance program process and procedures. Complete the Maintenance Action Plan to bring preventative maintenance programs current. Address staffing shortages that are negatively impacting the performance of scheduled maintenance. Operations Ensure staffing levels are sufficient to safety meet the required level of service. Incident Investigations Provide timely incident notification and reports. Initiate a call system to ensure required individuals are notified of incidents. Training Ensure Operator training is performed by certified trainer. Response Accepted / Open ASC reported effective July 1, 2016, action items will be assigned and tracked through meeting minutes; safety and security items will be escalated to SCSC. ASC reported that the Management of Weekly and Monthly Meeting Process and Procedures will be updated by August 2016; a tracking matrix will be used to track open items to closure. ASC will update the SSPP, section 3.9, Safety Committees, to reference the revised Management of Weekly and Monthly Meeting Process by. Page 23 of 89

24 To close this CAP, ASC must revise this policy and ensure consistency with the decision-making authority defined in the IGA, SSPP, and SEPP. ASC must submit 3 completed weekly meeting minutes and 3 completed monthly meeting minutes, including the action item tracking matrix. The Department expects that the action items/concerns discussed in this CAP will be included and addressed on the action item matrix. ASC must update the SSPP, section 3.9, Safety Committees. GDOT: The September 2016 submittal includes a spreadsheet titled, Progress Report on ASC Accepted CAPs. ASC states her that on 9/15/16, they revised the Management of Monthly and Weekly Meeting to include the decision-making authority as defined in the ASC governing documents and a tracking matrix which captures action items to closure. It further states that ASC has included a copy of six (6) months of monthly SCSC meeting minutes, the revised ASC/ ESC meeting minutes template, and the revised Management of Monthly and Weekly Meeting as supporting documentation for FTA SSO Finding 8. ASC states that a reference of the Management of Weekly/ Monthly Procedure will be included in section 3.9 of the SSPP dated for 9/31/16. The Department did not receive any proofs that allowed them to verify the alignment of the decision-making authority. The Department also found deficiencies with the proofs submitted for FTA SSO Finding 8. ASC: Please see attached copies of six (6) SCSC meeting minutes. GDOT: The Department accepts the plans included in the December submittal. ASC should continue to provide regular updates and supporting documentation on the implementation of these actions until closed. Page 24 of 89

25 SA-CAP.OPS.015, Establish and Implement Comprehensive Training Program Plan and Standards: The Atlanta Streetcar System must establish and implement a formal, written and comprehensive Training Program Plan and standards of proficiency for the Operations Superintendent, Operations Supervisors, Maintenance Superintendent, Maintenance Supervisors, Maintenance Technicians, Dispatchers, and Operators. This corrective action is based upon several factors including the determination by MARTA s training subject matter experts that there is a need for the development (and redevelopment) of training courses that must be delivered by a certified trainer. The corrective action is further supported by the general consensus of Atlanta Streetcar and MARTA personnel that there is a lack of knowledge, equipment and training to adequately perform the wide range of job duties and responsibilities necessary to safely operate and maintain the Atlanta Streetcar System. This deficiency to adequately train staff and provide the required equipment extends to all areas of operations and maintenance, explicitly track, OCS, traction power substations, and vehicles. In addition, the corrective action is validated by the assessment team s review of the training records for the Operations Superintendent, Operations Supervisor, Maintenance Technicians, and Operators against the requirements of the SSPP. None of the training required by the SSPP had been fully completed or documented in a consistent manner. Specifically, no supervisor, maintenance technician, or operator had completed all of the training as specified in the SSPP. In addition, there were no standards identified for job specific safety training. Finally, across the board for all positions, training-related documentation was missing such as streetcar operating cards, random drug and alcohol testing, and medical renewal exams. To the extent possible, the Atlanta Streetcar System must update and complete its training records to address the gaps identified in Appendix A and develop a process to ensure that training records are accurately maintained and routinely audited against the requirements to the System Safety Program Plan. This may involve coordination with Human Resources. With respect to procedural training for operations, maintenance and safety, the Atlanta Streetcar System must ensure that the Training Program includes training for flagging as there are rules that indicate a need for flagged moves and flagged moves are happening, yet there is no flag person initial or refresher training curriculum. The Training Program Plan must ensure that Operators build the competencies for line of sight operations, operating at restricted speeds, and know the safe actions to take when there are obstructions on the track. The Training Program Plan must also build the corresponding supervisory and management skills necessary to ensure adherence to the rules and procedures. Response Accepted / Closed ASC must provide clarification on the training scopes for OCS / TPSS and the third-party O&M contractor, and the role of the SCSC, and provide a response that includes the minimum content for a Training Program Plan and standards as defined in this CAP. GDOT: The Department acknowledges receipt of proposed revisions to section 16 of the SSPP within the CAP Log Schedule, pp.5-12 submittal on. It reflects training modules that cover an array of safety critical positions within the ASC. The modules appear to be more robust and comprehensive to appropriately train ASC staff. ASC notes on p.4 of the schedule, 9/10/2016 completion date, that CAPs 007 and 008 address the scope of the training requirements for OCS and Track. However, the Departments review found no list of training modules in CAP 007 that were consistent with the observations found in Page 25 of 89

26 CAP.OPS.015. What was found was a MARTA training module for Track Defects only. There were no proposed training modules for OCS or TPSS included in CAP.OPS.008. Specifically, the 3 rd party O&M contractor requirements and the role of the SCSC were not adequately covered. ASC: Atlanta Streetcar is in the process of issuing (2) solicitations for training of ASC staff. One solicitation will be for providing training on the ASC track systems and an additional one for training on the ASC OCS/TPSS systems. Please refer to attached documents in response to CAP.OPS.007 and CAP.OPS.008 December 2017 GDOT: The Department confirmed the existence of the OCS, Track, and Operations training during the December 1, 2017 work session. This CAP is closed. Page 26 of 89

27 SA-CAP.OPS.016, Ensure SCSC Reviews, Accepts, Resolves Safety Hazards and Security Threats: The Atlanta Streetcar System must coordinate with MARTA System Safety and Quality Assurance to develop implementation strategies and tools to effectively identify issues, including unacceptable safety hazards and security threats, which must be elevated to the Safety Certification and Security Committee for management review, risk assessment and resolution. Response Accepted / Open The ASC must submit a response that confirms the conduct of the required investigation activities, preparation of the final investigation reports, receipt of SCSC review and approval on those reports, and submittal to the Department for the 27 hazards on the Hazard Tracking Log from May 2016 (and any subsequent hazards, not including the June 8 hazard) and the schedule of completion for these tasks. The ASC must also provide a response that ensures the hazard SOP and training include steps for SCSC and SSO approval of the hazard investigation reports and the hazard tracking log. The ASC must also provide a response that confirms that the hazard SOP and training fulfill the FTA hazard management activities defined in FTA SSO Finding 10 (over a 6-month period). GDOT: This CAP remains unchanged as ASC has requested a work session with the Department before addressing the 27 existing hazards. ASC: ASC will provide completed investigation reports for the eight (8) unacceptable incidents identified within the Hazard Tracking Log by January 31, GDOT: The Department accepts the plans included in the December submittal. ASC should continue to provide regular updates and supporting documentation on the implementation of these actions until closed. Page 27 of 89

28 SA-CAP.OPS.017, Update Rule Book: The Atlanta Streetcar System must coordinate with MARTA to complete the review and update of the Rule Book, paying special attention to the incorporation of Special Notices, Bulletins, or corrective actions identified within this report, as new or revised rules. Response Accepted / Open ASC reported that the SSPP and SEPP are scheduled for submittal January 21, ASC reported that restricted areas in the VMF will be defined. ASC reported that the visitor access SOP will be revised by July 30, 2016 with training in August GDOT: For the September 2016 submittal, there was no updated information for this CAP. ASC: ASC confirms we are on track to submitting the revised SSPP and SEPP by January 31, GDOT: The Department accepts the plans included in the December submittal. ASC should continue to provide regular updates and supporting documentation on the implementation of these actions until closed. Page 28 of 89

29 SA-CAP.OPS.018, Reassess Frequency of Field Observations and Rules Compliance Checks: Atlanta Streetcar System must reassess the frequency of field observations and rules compliance checks to ensure adequate field supervision and the daily assurance of safe operations. Response Accepted / Closed ASC must provide verification of completed corrective actions taken which includes the Operations Superintendent s evaluation of the current staffing levels, existing practices, challenges with those practices, and operational changes to be compliant with the rules compliance which resulted in an increase to 4 ride checks/month and maintenance checks remaining at 2 checks/month. The Department also requests a response to its suggestions for revisions to the Ride Check SOP and form. GDOT: In the September 2016 submittal, the Department acknowledges ASC s inclusion of the draft language to update the SSPP and its reconciliation with the Rulebook on p. 5 of the CAP Schedule. Department notes that in the CAP.OPS.012 responses, ASC confirms that an adequate staffing assessment has not been performed. Therefore, the requirement to verify the evaluation of the current staffing levels remains the same. We acknowledge ASC s plan to create a Quarterly Ride Check Compliance Checklist as noted in the CAP Schedule, p.5, 9/8/2016 Completion date. The Department also acknowledges ASC s plan to revise the Ride Check SOP as noted in CAP Schedule, p.5 9/7/2016 Completion Date. However, the language for both of these documents was not included as a part of this submittal for the Departments review and concurrence. ASC: Please refer to ASC response provided in CAP.OPS.001 regarding all staffing related issues. ASC confirms the procedures for Ride Check SOP were reconciled to reflect the 4 ride checks. GDOT: Closed Page 29 of 89