Thanks, JAC. What you say makes all the sense in the world to me.
What I recalled was that there was some discussion about replacing the boiler since it would have to be raised. There was also some discussion about 476 being different from the other active D&S locomotives because it was not in service and no extensions had been filed when the new FRA rules went into effect.
It's probably not a complicated situation in reality. We often seem to make simple things seem impossible on the NGDF, and impossible things seem like they should be child's play.
just thought I'd raise the question.