Chicago Metra’s board of directors formally called on Congress to extend the Dec. 31, 2015 deadline to install positive train control (PTC), agreeing with a staff analysis that in the current regulatory environment Metra will not be able to legally operate beyond that date.

Although Metra and the rest of the U.S. railroad industry have invested significant time and money and have made significant progress on PTC implementation, they have also warned for years that the deadline can’t be met due to a variety of operational, technological and financial challenges. Congress, however, has yet to act. In a resolution approved on Tuesday, the board again urged Congress to extend the deadline to a date that realistically accounts for the numerous challenges.

If Metra did choose to operate without PTC in place, it would be subject to potential FRA enforcement actions brought by the Department of Justice, including substantial civil penalties, issuance of compliance or emergency orders and injunctions or criminal penalties, according to an analysis by Metra’s Law Department. The analysis concluded that Metra will be unable to legally operate its trains beyond the deadline.

“This board will do all it can to avoid this crisis within the confines of the law as it exists today and continue to work with members of Congress on legislation that is needed to extend this unattainable deadline,” said Metra Board Chairman Martin J. Oberman. “In the meantime, on advice of counsel, Metra cannot operate any of its trains under current law as of midnight on Dec. 31, 2015.”

If Metra is unable to operate beyond December, it will work to ensure an orderly shutdown of its system and communicate with its customers with sufficient time for them to consider the effects of the shutdown, the resolution also states. Metra will also work with its transit partners in the Chicago area to provide alternative transportation but recognizes that feasible alternatives do not exist for the vast majority of Metra customers.

Metra’s current timeline for full PTC implementation is 2019, although the agency expects several lines to be completed before that date.