Are CATS T&E employees subject to FRA engineer and conductor certification? Do they carry licenses? I suspect they do - and it's likely they're also subject to FRA rules on drug and alcohol tests, so-called "efficiency testing" by a trainmaster or DSLE, and a host of other compliance matters. I've been told the Federal Hours of Service law applies.
However, because CATS is insular, and not part of the national network, it doesn't come under Surface Transportation Board jurisdiction. Also, employees aren't considered railroad workers under the Railroad Retirement Act.
Due to its unique status, CATS is something of a hybrid when it comes to the regulatory environment.