Dan,
In my estimation the FRA regs are not the main problem for the Mainline Steam operators, its the insurance issue, and the lack of railroads allowing them to operate(Insurance being the factor there mainly). Most have to operate under the AMTRAK insurance which allows them to operate on a mainline railroad like NS, CSX, BNSF, or CN,and CP in the US. It kinda loses something in my mind when you have to have an Amtrak diesel or two, and some other Amtrak equipment behind a 1930-1950 era Steam engine that runs like a top, but is relegated to being a hood ornament because of insurance!!!! I guess it beats a blank!!??
You are correct though about the similarities in number of operating days. Eureka operating 10 days a year, is more than some standard gauge engines, I would wager!!!
You mentioned that there was no problem operating in Nevada. Is there a place there where you can operate the engine more regularly?
Greg Scholl