The C&TS must have specifications and must train their employees to operate to them, just like every railroad in America. I never said or implied that they should not have specification, but only they must not give them to the FRA, and the FRA has no legal right to ask for them. I am retired from a career in management of a major railroad and I learned over the years that management of all railroad never gave their specification to the ICC or FRA and that government agency has no authority to ask for them. The Act of Congress, which gave the FRA a purpose and authority for a mission, made an intended lack of specification for any narrow gauge track. I know for a fact that the FRA is unhappy with that omission and wants Congress to correct it. Let them go to Congress and have it corrected the right way, if safety justifies! But it looks like the Dallas office of the FRA is intending to develop their own Law and have requested the Cumbres & Toltec Scenic RR Commission to turn over their internal information.
To the folks on this list: I have been called here an extremist by E…, who I respect highly, to must ado about nothing. That’s all personal attacks unrelated to the critical subject. It is clear there are no experienced career management railroader in this list or ones who have the foresight to see that the FRA is beyond their legal bounds. Replies have wondered so far away that we have ended up cleaning McD’s jons. Amazing. The Dallas office of the FRA seems to have private addenda to make their own law where Congress, with good reason, never invaded. Once someone from Chama lets the genie out of the bottle, it will not go back and narrow gauge C&TS will never continue to operate to the costly standards that will be the intended law. It would be better that Chama post a warning notice on the station “Travel at your own risk- this narrow gauge track does not come under Federal Inspection or specifications control”. I know from other sources the FRA want to establish national minimum standard for narrow gauge track and they should go to Congress to get the law changed, if safety justifies (the injuries that E.. alluded to were not track related (no brake club-bad piston travel), except the details of the missing-rail one we will not go into). Funny, how when Black Bart coupled a passenger train to a work train and ran it over un-inspected out-of-service track and nearly rolled the #484 on the icy crossing, the Denver office of the FRA said they had not extended jurisdiction over the line as never any need. D&RGW had rules against the coupling of passenger trains to work trains and surely would never haul passenger over track not inspected after a winter of dormancy. I am sure the FRA has not received other narrow gauge railroad specifications and it should not see the one of the C&TS. When they have the Congressional hearing, they can all put them on the table and work it out. The C&TS is not qualified to make the rules for the nation.
