Re: Eureka

Hi Greg,
You asked a great question. The fact is that I was told by FRA personnel,(I believe it was in early July) that if I wanted to run Eureka at Railfest I had better take care of these requests before the event. Up till that point, I never thought there was a need to do anything. But if I'm told by them that something is needed before I run, I am going to take care of the matter immediately. That it did not turn out as I expected is another matter.
As for the 15 year/1472 day rule, from what you noted about some other engines, it sounds like they have similar problems. I would think they might want to apply for a waiver as well. As to the merits of the rule, I think it makes great sense if you rack up a lot of operation over the period that the tubes be pulled and the inspection done. A person doesn't need a rule to come to that conclusion. However, experience is showing that there is a special class of engines out there that do not fit neatly into the rule because they operate so infrequently. A rule should be flexible take into account unique circumstances. Otherwise no one in their right mind will restore a locomotive for ungodly sums of money and run it only a few days in that 15 years only to be told to do it all over again. Frankly, if there is no room for some flexibility, I think it will ultimately be the death knell of rare historic railroad artifacts ever operating. A rule may have meritorious reasons behind it, but it must also have a nexus with the reality of operation. If not, then the rule is merely an arbitrary one. I believe those that drafted this rule had the best of intentions. However, I do not think that all situations were considered. What I have asked, is for something to cover that unique situation when use very infrequent. Consider, that even if the waiver is granted, extending the time to pull the tubes for 5 years, that is only about 5 more weeks of operation. It ain't much. Even then, Eureka would have a total time of about 160 days.
Dan