Dear Sir, you state the railroads never handed there standards over to the ICC or FRA. Then I ask you how AAR interchange standard books are kept out of the FRA's possesion considering the FRA likes to hire people with railroad experience? How does a railroad get their engineer certification approved today as required by law? Mr. Moedinger and others others saw problems years ago with the regulation of steam engines. They very carefully developed a plan and saw it though. The FRA was interested in updating and improving their code. A code was developed with different representatives from different parts of the industry. Several hearings were held on the new steam locomotive code including one in Corpus Cristi, TX that was attended by representatives from UP, TVRM, Austin Steam Train, and Grand Canyon Railway.
The FRA has several classes of track standards. Not all are for ballasted mainlines with continus welded rail but rather different standards for different types of service.
The FRA realizes that there are differences with regulations that is why you see periods of public comment pior to a codes implimentation, the waiver section of the code, and ultimately the ability to settle issues that come up higher whithin the FRA/DOT and finaaly at the representative level.
To here this confrontational additude with the FRA is unfortunate. Often times the FRA can be a valuable alli in getting things done. I hope that some far sighted people take this opportunity to work with the FRA. The C&TS brings uniqe challenges to all involved. Equipment that is of an era that has for the most part passed in railroading. The FRA has done a lot to promote safety in the industry. I for one am glad they are there. Many people are alive today due to ICC/ FRA regulation. It does not need to be us vs. them.
P.S. I at the age of 31 have 18 years of experience working with the FRA.
