What I will be looking for, now that the STB Passenger OTP statistics are being gathered and published, will be Amtrak's willingness to file complaints. Mr. Matthew's accurately pointed out the DOJ only filed suit once, what is not there in his statement is Amtrak has traditionally been quite reticent to even threaten the hosts with going to DOJ, or publicly complain about OTP. They often have a taken a "go along to get along" approach in their relationship with the host railroads they are yoked together with.
As most who are here regularly are aware, I am not a fan of of Amtrak's current and recent executive management teams, to say the least. One point in their favor is that they have been much more willing to publicly call out the host railroads on their OTP issues than Amtrak had been in the past. Issuing public "grades" of host railroad performance is one example.
I really don't expect the STB to self-move in filing actions, but I do expect Amtrak to file complaints. Whether they will will be a key test of these new regs. Based on Amtrak's current management's willingness to call out the host railroads, I am cautiously optimistic.