Being adversarial to the FRA is a dead end street.

You said, “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.”
We certainly do share our standards with the FRA at Strasburg. In fact we hold classes for FRA inspectors, 16 at a time, to teach them how to apply the new part 230 rules correctly. If “the Gods of Steam” hadn’t been working with, cooperating, and sharing their standards with the FRA at the time of the Gettysburg accident, God knows what kind of government reaction there might have been, or if any steam locomotive would be running today. Experience and common sense shows that the quickest way to get the FRA down on you is to give them the impression that you are hiding something. However, if you work with them, generally they will work with you.
You said, “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.”
I am a vice president at our operation, with 24 years full time steam railroading to my credit. Moedinger, president of our operation, whose post is a few slots up has 34 years experience.