We all know FRA people (most come from company ranks) get the companies specification by nook or crook, but they can not use them in a legal way. I'm taking the legal view or reviewing the narrow gauge track and not intending to be adversarial to a service which is valuable in applying their mission as authorized by Congress. They have trained many C&TS employee who should have learned it in advance the right way. AAR interchange rules are public domain.
Regarding "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." Again that applies to boiler but even if it was regarding track specifications, when are the period of public comment, and were is the attempt to settle issues?