Re: C&TS Comm. Has NO EXPERIENCE to estab. FRA ng

The C&TS and the WP&Y can develop specifications on which no train will ever derail, primarily because nothing will operate because you could not afford it. The point is, it took decades of years of experience to set speeds and class of track for standard gauge lines that the industry could afford and be satisfied with the number of derailment and their costs. That experience has never been developed for narrow gauge, ranging from logging lines, tourist trains up to high tonnage passenger carrier like WP&Y. What fits the White Pass would shut down the EBT. Even the D&RGW’s own track standards cannot be used, as they never describe what is a failed tie. Will the narrow gauge want a plate or rail cut tie that is 41% deep into the tie to be a good tie? Maybe Yes! The track diamantes are entirely different with 36” gage and cannot be prorated down from Standard Gauge without experience and cost study to back it up. You cannot maintain to a “NO derailment” standard.
The FRA authority to request such list is questioned, even on a one-company property, as the law does not require it. The FRA only operated by the law decree. There is a on going “Emergency Order” to look for unsafe conditions but “Emergency Orders” are only legal on a temporary basic and the accident at Ely, Nevada is long past. There are no injuries or deaths happening on narrow gauge railroads to justify this continued government intrusion. The FRA costs to the C&TS are beyond justification and it will not be rebuilt into a gold plated cement tie tangent on three feet of ballast.