The Class Is continue to express serious cost concerns about mandated positive train control (PTC) implementation. I recently shared Norfolk Southern Corp. CEO Wick Moorman’s take on it. Now, here is Union Pacific Railroad’s stance courtesy of a letter Executive VP of Marketing and Sales Jack Koraleski wrote to customers on Jan. 27.

The Federal Railroad Administration’s (FRA) final implementation rule will increase the cost of “this already expensive mandate,” Koraleski wrote.

“In fact, the FRA itself calculates that the cost-to-benefit ratio is an astonishing 22 to 1, meaning that most of this huge investment will be unproductive,” he said. “Since we must comply with this mandate by 2015 across our network, and have agreed to implementation by 2012 in the Los Angeles basin area, we are already focusing resources on this project — consuming about $200 million of this year’s capital investment.”

As other Class I have noted of late, other infrastructure projects might be “pushed further down our priority list” because of limited capex resources, Koraleski wrote. For example, during CSX Corp.’s earnings conference last month, CEO Michael Ward said $200 million of the railroad’s capital expenditures in 2010 will be “diverted from other worthy capital improvements” because of PTC implementation.

I presume we’ll continue to hear about the “tough choices” Class Is are making in their capex programs as the year — and PTC roll out — move along. A federal tax credit, grant or some other form of government funding would go a long way toward relieving Class Is’ PTC sticker shock. Expect them to make a case for such funding later this month at Railroad Day on Capitol Hill, the rail industry’s full-court-press lobbying exercise in D.C.

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