We are not the only ones complaining about the FRA

The author definitely has a perspective but to me the issue is what does the data show, in terms of whether the FRA's regulations are justified.  This isn't one of those areas where you would be debating the soft, difficult to quantify merits / demerits of regulation such as, for example, whether there has been market failure sufficient to justify some additional environmental regulations.  This strikes me as more akin to an area like highway fatality data, where there are hard numbers showing the fatalities per mile.  For that reason, if FRA is putting this expense on the railroads, then it should have hard data showing why these regulations and requirements are necessary.  If FRA doesn't have this data, then I am surprised that they haven't already been challenged in court. 

I would not place to much stock in this article.  US and European railroads are difficult to compair. They are designed to do entirely different things.  Under the FRA regulations, US passenger only railroads are free to come up with their own crashworthness standards.  Many of the US standards for railroad safety are written in blood.  As for the weight of the locomotive, the horsepower and weight of a locomotive are matched to the intended service.  Frequently locomotives are ballasted to increase the weight to achieve the desired adhesion. 

Reliability and maintenability are frequently not given adequate consideration during the engineering phase of a project. Reliability will speak for itself once track testing starts.  By this time it is usually to late to do much about maintainability.  As for the cost, with out comparing contracts, there is no way to know if costs are in line. There are so many items in a contract other than the locomotives.  Some, like warranty, testing, spare parts, speical tools, test equipment, and training are big ticket items.  And there is value to all of us to maximize US content.   

Only time will tell for sure how well Amtrak did with their new locomotives.  I wish them well.  They are trying to replace a really fine loco.

Since this involves PASSENGER locomotives, the additional expense due to the extreme FRA design requirements, is born by the TAXPAYERS! 

There design requirements for freight locomotives, purchased by the RAILROADS, is MUCH different.

Take a deep breath. Irrespective of whether the cost is placed on Amtrak or on a private firm, the cost will be passed through and if there is no basis for the regulation then such additional costs are not warranted.  So we agree.  In any event, it doesn't take a terribly discerning eye to tell the author has a perspective and that's fine but as a reader I always want to know the other side of the story before reaching any conclusions.

The FRA may not have to much to say about some of their regulations.  Sometimes it is helpful to look beyond the Code of Federal Regulations (CFR) and look at the United States Code (USC) to see what the FRA was tasked to do.  The locomotive inspection regulation was written by the FRA based on two short sentences in the USC.  They said something like this: Locomotives will be inspected to be sure they are safe.  The inspections will be documented. On the other hand the old Safety Appliance and Power Brake rules were written by Congress into the USC and the FRA had no way to change them, but to go back to Congress and ask for changes.

The USC is very difficult to use as a result of the way Congress does business. Usually the FRA regulations are footnoted to the various parts of the USC that give them their authority.  More interesting and even more difficult to research for historical data is the Federal Register.  There you can see who actually said what and see how these regulations are arrived at.  The only way I have been able to use this is to pick up references as things are occurring, and order the referenced Federal Register immediately   I have never been successful I doing historic research in the Federal Register. There is just too much of it to go through.

These regulations are not arrived at in secret.  There public hearings which you can go to and be heard.  I have been to several of them and as you might guess, there is very little public present.  There are usually three groups, the FRA and their staff, the AAR representing the railroads, and the labor union representatives. But everyone gets their turn to talk and I have, on several occasions, made changes in the regulations to benefit my special interest group. 

I particularly like this line:

"The FRA, on the other hand, insists that American trains be bulked up to survive crashes with minimal deformation, "

What about the passengers inside? I could jump off the roof of a 5 story building and be killed just as easily if I were in a safe that was pushed off the roof of a 5 story building. That's what I love about this country, MBA's (and I apologize to the MBA's on this forum) making engineering decisions, like the guys who said that the Challenger could lift off safely or that Columbia should be able to make it back OK. Let the real engineers and designers figure this stuff out and stop poking around in things they don't understand or decide based solely on financial or "gut" feelings.

Jerry

A sobering counterpoint is the recent catastrophic crash and fatalities of a high speed passenger train in Spain. 

so What's the plan for the current workhorse AEM7?

Let me also add that if one wants to fully understand any Federal Regulations, one needs to also take a look at the Preamble to the Regulations.

Federal Regulations are usually published in Draft, then comments are compiled from industry, and anyone else who might have an interest in the regulations.  Each and every comment is evaluated, and a Preamble to the Final Regulations is published along with the Final Regulations.  Once a year, any new final regulations will be codified into the CFR along with any current regulations that haven't been replaced.

There may be times, however, that it is in the public interest (when something needs to be quickly addressed) to skip the draft regulations and just publish final regulations.

Jim

I'm not sure, but I thought the FRA was revising the safety standards for high speed trains to be more compatible with Eurpoean designs - in other words, to allow the option of using crumple zones instead of strucutural stability.  Of course, these engines were ordered before any of the regulation changes were made.  Having run passenger trains for many years, my optinion is that the real problem with the extra weight requirements is in the passenger cars.  Having heavy cars greatly slows the acceleration of any train as it lowers the hp to weight ratio.  On the other hand, having some extra weight on an electric loco isn't a bad idea, as wheel slip on these relatively light engines can cause lost time.  With their high hp to weight ratio vs diesels, electrics can develop massive wheel slip (and lost traction) due to rain, leaves, snow, etc. 

Watching the terrible video of the Spanish crash was that the trailing passenger cars lifted off the rails first, which, of course has to do with their center of gravity, super-elevation and weight, and it looks to me that the trailing cars, not the locomotive left the rails and pulled the locomotive (to a canted position) off the rails. My opinion is like Portas when it came to looking at various factors, rather than one that should be working as a system that either makes for efficiency (in this case, safety) that takes into account the human fudge factor. Over-designing for this seems to be a lost art for the sake of economies seems counter intuitive to me.