Dan, one point that I am not sure has been mentioned is regarding engineer qualification for an FRA "Lite" operation. While I have been largely out of the loop (no pun intended) the last couple years as I recall the FRA did require SVRR to have an engineer training/qualification program. This was a painless requirement at SVRR as the program was already in place before FRA asserted juridiction and they found our program to be acceptable. 2 or 3 years back I believe an FRA or was it ODOT inspector suggested a canned training program that was available that would make our engineers who qualified under it also elgible to be qualified under FRA for the general system. I don't believe this change in programs was mandated and to my knowledge not acted upon. I wonder if the Loop now under operating under FRA oversight is required to have a formal training program in place?
It seem to me a year or two ago FRA instituted a requirment that targeted shortlines regarding qualification of brakeman/conductors which required documentation of some level of training. I haven't heard anything more about this and I think I read it on RYPN. I wonder if FRA is enforcing something along these lines on the FRA "Lite" operations? This also probably be painless at SVRR at least as progressive training has been in place for many years starting at "rear" brakeman going on through the various crew postions.