Category: FRA

NEC Future: Moving Sideways

The Northeast Corridor high-speed rail investment studies are moving forward, and four days ago the FRA released an early environmental impact study on the subject, as part of the NEC Future program. The study moves in part in the right direction, in that it considers many different segment-level improvements (for example, specific bypasses of curvy segments), but it still isn’t quite going in the right direction. It’s not a bad study in itself, but it does have a lot of drawbacks, and I would like to discuss the ultimate problems with its approach.


The EIS studies three alternatives, as well as an obligatory No Build option.

Alternative 1 includes minimal investment: capacity improvements already under consideration, including new Hudson tunnels; grade-separation of at-grade rail junctions, including Shell interlocking between the Metro-North New Haven Line to Grand Central and the NEC, which imposes a severe speed limit (30 mph, the worst outside major city stations) and a capacity constraint; and a limited I-95 bypass of the legacy NEC route in eastern Connecticut, to avoid the existing movable bridges. The bulk of the expense under this alternative, excluding the predominantly commuter-oriented new Hudson tunnels, involves replacing or bypassing obsolete or slow bridges with faster segments. I have advocated such an approach in certain cases for years, such as the Cos Cob Bridge; if anything, Alternative 1 does not do this enough, but I do appreciate that it uses this solution.

Alternative 2 constructs HSR along the NEC route, except for a major deviation to serve Hartford. It is also bundled with various bypasses and new stations elsewhere: under this alternative, Philadelphia and Baltimore get new stations, with extensive urban tunneling to reach those stations. Alternative 3 does the same, but considers more deviations, including a tunnel between Long Island and New Haven, and an inland route through Connecticut, closer to I-84 than to I-95 and the legacy NEC; it also constructs dedicated HSR tracks between New York and Washington.

The EIS does not include cost figures. It includes travel time figures on PDF-p. 51, which seem to be based on unfavorable assumptions: Alternative 2, called Run 5, does New York-Boston in 2:17 for trains making a few major-city intermediate stops; the Alternative 3 proposals vary widely depending on alignment, of which the fastest, the I-84 inland route, takes 1:51, again making intermediate stops.

The Good

First, the EIS includes service plan elements, stating the projected frequency of regional and express trains using the tracks. It also talks about clockface scheduling and proposes a pulse in Philadelphia, allowing timed transfers in all directions between local and express intercity trains as well as trains on the Keystone corridor. It goes further and discusses regional rail on the intercity tracks in the alternatives that include extensive new construction. In these ways, it focuses on regionwide rail integration far more than previous plans.

Second, in general, the correct way to think about NEC investment is component by component. The EIS gets closer to this ideal, by considering many different route combinations north of New York, and advancing several of them under the Alternative 3 umbrella.

And third, the concept of Alternative 1 is solid. In many cases, it is possible to bundle a trip time or capacity improvement into the replacement of an obsolete structure at very low additional cost. The example I keep coming back to is the Cos Cob Bridge, but it is equally true of the movable bridges east of New Haven. I also greatly appreciate that Alternative 1 recognizes the importance of grade-separating railroad junctions.

The Bad

Ultimately, the EIS does not take the three good concepts – integrated service planning, component-by-component thinking, and bundling trip-time improvements when the marginal cost of doing so is low – to their full conclusion. Thus, there is no attempt at running intercity trains at high speed on shared track with commuter rail with timed overtakes, as I have proposed for both the inner New Haven Line and the Providence Line. On the contrary, the plan for capacity investment on the Providence Line includes extensive three-tracking, rather than limited, strategic four-track bypass segments. This cascades to the trip times, which are quite slow between New York and New Haven (1:08, for an average speed of 103 km/h), and a bit slower than they could be between Providence and Boston (24 minutes, whereas about 21 is possible with about zero investment into concrete).

The concepts of Alternatives 1, 2, and 3 represent bundles of levels of investment. This is the wrong approach. Alternatives 2 and 3 include new tunneled city-center stations in Baltimore and Philadelphia; but wouldn’t we want to consider city-center station tunnels in those two cities separately? It’s possible for one to turn out to be cost-effective but not the other. It’s possible for neither to be cost-effective, but for other improvements included in Alternative 2, such as curve modification around Metropark and Metuchen, to pencil out.

There’s far more interaction between different macro-level alignments, by which I mean such questions as “inland route or coastal route?” and “serve Hartford on the mainline or put it on a branch?”, than between such micro-level investments as individual curve modifications and urban tunnels. This means that instead of discrete alternatives, there should be one umbrella, taking in Alternative 2 and 3 variants, proposing all of those options as possibilities. A future study, with detailed cost figures, could then rank those options in terms of trip time saving per unit of cost, or in terms of social and financial ROI. This way, there would be concrete proposals for what a $5 billion plan, a $10 billion plan, a $20 billion plan, and so on would be.

The Ugly

Two elements in the study are inexcusable. First, the service plan description explicitly keeps Amtrak’s current separation of premium-fare Regionals and even-more-premium-fare Acelas. This is not how the rest of the world structures HSR: even when the HSR fares are substantially higher than the legacy rail fares, as in Spain, the fare per passenger-km is not very high, and is not targeted exclusively at business travelers. In France, the intercity fare (including TGVs, which are the bulk of French intercity traffic) was on average €0.112 per passenger-km in 2011. Premium service is provided on the same TGVs as standard service, in first-class cars. In contrast, Amtrak charges about $0.29 per passenger-km on the Regional and $0.53 on the Acela.

And second, the investment alternatives appear to include more tunneling than is necessary. I will focus on the Hartford-Providence-Boston segment in Alternative 2, since it is less sensitive to assumptions on commuter rail track-sharing than the segments overlapping the New Haven Line. It is possible to go all the way from Hartford to the western margin of the Providence built-up area without any tunneling, and without outrageous bridging; see a past post of mine on the subject here, which concludes that it’s better to just go parallel to I-95 for trip time reasons. In Providence, tunnels are unavoidable, but can still be limited to short segments, mixed with elevated routes along pre-impacted freeway corridors. When I looked at it two years ago, I saw an alignment with just 2 km of tunnel, in Providence itself. In contrast, run A in figure 9 on PDF-p. 56 says that tunnels are about 27% of new construction between Hartford and Boston, which consists of, at a minimum, about 100 km of track between Hartford and Providence.


The EIS is a step in the right direction, insofar as it does consider issues of integrated service planning and prioritizing construction based on where it can be cheaply bundled into bridge replacement. However, it fails to consider cost limitations, as seen in the excessive tunneling proposed even in areas where high-speed tracks can run entirely above ground. It’s considering more options, which is good, but, Alternative 1, while representing a golden concept, is not sufficiently developed.

What I would like to see from a study in this direction is a mixture of the following:

  • Discussion of how to avoid tunnels, including various tradeoffs that have to be made (for example, above-ground construction may require more takings). Generally, I want to see much less tunneling than is currently proposed.
  • A well-developed incremental option, similar to Alternative 1 but more extensive, including for example I-95 bypasses all the way from New Haven to Kingston and along strategic segments of the New Haven Line, such as in Port Chester and Greenwich.
  • Greater integration with regional rail; one litmus test is whether the Providence Line is proposed to be three-tracked for long stretches, or four-tracked at a key bypass station (the options are Sharon and the Route 128-Readville segment), and another is discussion of high-acceleration electric multiple units on the Providence Line and the Penn Line.
  • Unbundling of projects within each alignment – there is no need to, for example, consider the Philadelphia and Baltimore tunnels together (I also think neither is a good idea, but that’s a separate discussion). The view should be toward an optimal set of projects within each alignment, since macro-level decisions such as whether to serve Hartford are more political than micro-level ones of which curves to fix. This permits explicit discussions such as “would you be willing to spend $2 billion and slow through-trains by 9 minutes to serve Hartford?”.

Except for the first, all are kind of present in this study, but in insufficient amount for me to view it as truly a step forward. The ultimate goal must be HSR in the Northeast on a reasonable budget – closer to $10 or even $20 billion than to the Amtrak Vision’s proposed $150 billion – and this requires carefully looking at which scope is required and which is not. The EIS has elements that can be used toward that goal, but ultimately it is a step sideways, not forward or in the wrong direction.

The Magic Triangle: Infrastructure-Timetable-Rolling Stock

In the last month, Amtrak decided not to purchase additional Acela cars, but instead replace the Acela fleet ahead of time, and try to buy trains that aren’t compliant with FRA regulations. More recently, Amtrak and the California HSR Authority decided to bundle their orders together. The latter decision drew plenty of criticism from some good transit advocates, such as Clem Tillier, and even the former decision did. Clem explained,

The whole notion of buying quicker trains for the NEC is ridiculous– the existing Acela Express trains have plenty of oomph (16 kW/tonne) to do anything they need to do. “Lighter” and “faster” isn’t the key to anything on the NEC, and dropping in a higher-performance train will not lead to material trip time improvements. They need to speed up the slow bits first, which isn’t something you do by blowing money on trains.

Clem’s criticism got a fair amount of flak in comments, from me and others, for underestimating how important getting around FRA regulations is. What nobody said in comments, and I only realized after the discussion died out, is how the choice of rolling stock depends heavily on what Amtrak plans to do with infrastructure and service planning in the Northeast. It doesn’t make sense in any case to tether Amtrak’s plans for a corridor that’s in many ways globally unique to the California HSR Authority’s for a fairly standard HSR implementation. But what rolling stock is required, and thus how bad the tethering is, depends on a concrete plan for infrastructure and schedule.

At the highest level, the unique issue with the Northeast Corridor is that significant parts can’t be feasibly upgraded to more than 200-250 km/h or easily bypassed, while others can. This means that there’s a tradeoff between top speed and cant deficiency, and the optimal choice depends on how much investment there is into speeding up segments. In any case it’s critical to improve station throats, interlockings, and railroad junctions, but after the 50 and 100 km/h zones are dealt with, the remaining questions are still nontrivial.

The more money is invested, the less it makes sense to run a 270 mm-cant deficiency, 250 km/h Pendolino, and the more it makes sense to run a Talgo AVRIL or E5/E6, both of which are capable of 350 km/h but only about 180 mm of cant deficiency (or N700-I, which is on paper capable of 330 km/h and about 135 mm and in practice could probably be run at 360 km/h and 175 mm). If there’s one segment that tilts the decision, it’s New Haven-Providence: using the legacy Shore Line, even with heavy upgrades, limits speeds and favors high cant deficiency, while bypassing it on I-95 favors high top speeds. But even the New York-Washington segment of today has a few curves strategically located at the worst locations, which make higher tilt degree a benefit.

In medium-speed territory, the Pendolino versus E5/AVRIL/N700-I decision is the muddiest. I ran rough simulations on an upgraded New Haven Line, with bypasses including those I advocated as a first step but also additional ones in the more difficult Stamford-New Haven segment. A train with E5 cant deficiency and N700-I acceleration did New York-New Haven in 32 minutes, and a Pendolino with all cars powered did it in 30. Neither is a standard trainset, though the former is very close to standard (and the Talgo AVRIL is also quite close). The Pendolino as it is, with about half the cars powered, has low power by HSR standards, and this is a problem for accelerating back from a slow zone at medium speed. With all cars powered (which is feasible, at higher acquisition cost) it’s still far from turbocharged, but can change speed more easily. An off-the-shelf Pendolino would not beat an E5 or AVRIL or N700-I on such a corridor, and of course would not beat it south of New York or north of New Haven.

Since nonstandard trains cost more, it’s important to also decide whether they’re worth the cost. Bearing in mind that Amtrak said a new noncompliant trainset costs $35-55 million, which is above the range for 8-car trains (China pays about $4 million per 350+ km/h car), so it may already be factoring in a premium, paying more for trains is worth it whenever the benefits to passengers are noticeable enough. This, like choosing very high-speed rolling stock rather than a Pendolino, is the most effective at high levels of infrastructure investment. An off-the-shelf Pendolino is good enough for most applications. So is an off-the-shelf N700-I without tilt. It’s okay to be 15 minutes slower than the cutting edge if the cutting edge is too expensive. But the effect of 15 minutes on ridership is more pronounced if it’s the difference between 1:35 and 1:50 than if it’s the difference between 3:00 and 3:15. In addition, the faster the service is, the more revenue each train earns, and this allows spreading the extra acquisition cost among more passengers.

Another factor that’s neglected, at least in public statements, is the service plan. Amtrak service is heavily padded: the fastest northbound Acela is scheduled to do Providence-Boston in 47 minutes, but in the opposite direction it’s 34. Remove the Route 128 stop and this can get close to 30 or even below it. About the fastest trains can go with no schedule padding is 19.25 minutes, and reasonable but not onerous padding raises it to about 20.5. Clearly, more of the difference comes from operating efficiencies than from any speed raising; the Acela already goes 240 km/h between Providence and Boston and already has about 180 mm (7″) cant deficiency.

The limiting factor here is more MBTA ownership and operating culture. A good service plan would make it clear how trains can share the corridor (and the same is true on the New Haven Line, another unduly slowed commuter-owned segment), and because MBTA trains are so slow, any cooperation would involve public statements regarding upgrades to the MBTA. The Acela has level boarding at every stop except New London, which is the easiest to cut out and should be bypassed together with the rest of Shore Line East. It’s the MBTA that has non-level boarding, which remains one of the biggest schedule risks, requiring plenty of recovery time to deal with possible long dwell times coming from above-average crowds.

The problem is that Amtrak has made no statements regarding how to integrate the three legs of the magic triangle. It proposed the Vision plan, which even political transit bloggers like Ben Kabak note the extreme cost of; there’s no funding, and the first segment for which it’s trying to obtain funding, the Gateway Tunnel, is very far from the top priority for speed or even for intercity rail capacity. It now proposes new rolling stock, but is unclear about what the trains are supposed to do except be very fast. (Bundling with a new-build line like California makes sense only if all curves are straightened to a radius of 4+ kilometers, even extremely expensive ones.)

Perhaps it’s a feature of opaque government, that Amtrak refuses to say how much money it needs to meet each timetable and capacity goal. For example, it could say that if Congress gives it $10 billion it could reduce travel time from Washington to Boston from the present 6:45 to 5:45 while also running a peak of 4 long trains per hour at that speed. (I think for $10 billion it’s possible to get down to 3:30 or at worst 4:00, but this is a matter of cost control and not just transparency, though transparency can indirectly lead to better cost control.) This would involve heavy cooperation with the commuter railroads that share its tracks and joint plans, as well as detailed public plans for how much to spend on each segment and for what purpose. This is routine in Swiss rail infrastructure planning, since all major projects have to be approved by referendum, but does not happen in the US. It could be that Amtrak knows what it’s doing but acts like it doesn’t because the structure of government in the US is such that these decisions are made behind closed doors.

But more likely, Amtrak doesn’t know what it’s doing, and is just proposing new initiatives that make it seem forward-looking. Changing FRA rules is an unmixed blessing. Bundling an order with California HSR is not. The fact that Amtrak is doing so, while keeping mum about even what kind of rolling stock it thinks it needs, suggests that it reverses the usual way reform should be: instead of a need for reform producing good results and thence good headlines, a need to get good headlines about reform produces reform ideas that sound good. Some of those good-sounding ideas really are good, but not all are. It’s important for good transit advocates to distinguish the two both privately and publicly.

I feel like in the last two years, we’ve seen important American transit and railroad managers say correct things. Shortly after I started making noise in comments about New York’s outsized subway construction costs, Jay Walder said as much in a report entitled Making Every Dollar Count. Joe Lhota proposed through-running on commuter rail as a solution to improve efficiency. Scott Stringer, too, talked publicly about comparative construction costs, and for all of my criticisms of transit managers who say that, I thought it was enough for him to say that as a political candidate for a medium-term office to deserve my endorsement for the mayoral election, which he unfortunately bowed out of. The FRA proposed to start working on new rules for rolling stock last year. At Amtrak, we’ve just now seen Joseph Boardman propose noncompliant rolling stock. Perhaps I’d be more optimistic if Walder and Lhota had stayed at the MTA for longer to implement their positive reform ideas, instead of using it as a springboard to secure a higher-paying job or run for mayor, but increasingly it looks like the good reform talk is not generally accompanied by good actions.

This is, again, where good transit advocates can have the most influence. We more or less know which reforms are required and which are not. There are disagreements at times (Clem, for one, has much better credentials as a good transit activist than I do), but on most of the agenda items there’s agreement. We already know what details we might want to see from a good plan of action, and the advantage of this is that we can check proposed plans against them. That Amtrak’s gotten so many details wrong suggests that it still doesn’t know what the best practices for rail construction are, even if the basic idea of getting around FRA rules is sound. I wish I didn’t have to say it, but I’ll believe Amtrak’s improved when I see it.

Quick Note: Good News Week

Via Systemic Failure, I learn that the FRA is finally reforming its train safety regulations on its own. This is an amazing development, partial as it is. This appears to derive from the FRA’s previous research into crash energy management, which concluded that buff strength alone did poorly at protecting train occupants. This development is especially good for the MBTA and Metra, as agencies that could make large orders, especially of EMUs if they electrify (and both have good reason to); this will allow them to obtain better EMUs, for example measured by weight, than currently run in New York and Philadelphia.

Unfortunately, the reforms are partial, and lack two elements. First, they start from past crash tests, rather than from good rolling stock, and may still require imports to undergo substantial modifications; this is not a problem for large orders, but tends to raise the unit cost for small orders. That said, the rules are being developed in consultation with representatives from many rolling stock vendors, not only the large ones as with Caltrain’s waiver application but also smaller ones such as Nippon Sharyo and Stadler. Second, they do nothing about operating rules as opposed to procurement rules; these include brake tests, cant deficiency rules (only partially reformed), and so on. Still, count this as a positive development for the FRA.

The other good transit news: the Florida East Coast Railway, a Class II railroad primarily carrying intermodal traffic between Jacksonville and Miami, is announcing a privately-funded $1 billion project to build a medium-speed line from its mainline to Orlando and run passenger trains between Orlando and Miami, making the trip in 3 hours. This corresponds to an average speed of about 80 mph, just under 130 km/h, or in other words the same as that achieved by the supposedly high-speed Acela between New York and Washington.

Train Weights, Bilevel Version

My previous table of train weights covered single-level trains, with the exception of the ultralight (for a bilevel) TGV Duplex. By request, here is a similar version for bilevels. Note that very light trains such as the E231 or DB’s Class 423 are inherently single-level – though a bilevel Green Car trailer version of the E231 is quite light, even at 50% heavier than a single-level trailer.

Recall that Lng is length in meters, Wt is empty weight in (metric) tons, Width is in meters, Pow is maximum short-term power in megawatts, P/W is power-to-weight in kilowatts per ton, Ld is average load per axle in tons, and Wt/Lng is weight in tons per meter of train length.

Train Lng Wt Width Pow P/W Ld Wt/lng
E231 series Green Car 20 36 2.95 0 0 9 1.79
215 Series 200 368.5* 2.9 1.92 5.2 9.2 1.84
TGV Duplex 200 380 2.9 8.8 23.2 14.6 1.9
Bom. BiLevel Coach 26 50 3 0 0 12.5 1.91
KISS, Regional 150 297 2.8 6 20.2 12.4 1.97
KISS, Interregio 100 212 2.8 6 28.3 13.3 2.11
E4 Series 201 428 3.38 6.72 15.7 13.4 2.13
NS DD-AR (w/ mDDM) 100 221 2.8 2.4 10.86 13.8 2.21
GO Transit MPI hauling 12 Bom. BiLevel Coaches 332 734 3.24 3 4.1 14.1 2.21
Metra Highliner 26 59 3.2? ? ? 14.8 2.28
Caltrain Coradia 213 517 3.2? ? ? 16.2 2.43
X40 (Coradia, Sweden) 81.5 205 2.96 2.4 11.7 17.1 2.52
Caltrain MPI hauling 5 Bom. BiLevel Coaches 150.5 384 3.24 3 7.8 16 2.55
CityRail A-sets 78 201 3.04 ? ? 12.6 2.57
MI 2N 112 288 2.9 4.5 15.6 14.4 2.57
Colorado Railcar, bilevel 26 74 3.2? 0.96 13 18.5 2.86

*Caltrain claims the same weight – see pages 36 (which partially confuses the train with a heavier Shinkansen) and 45 of its document about bilevel EMUs. Japanese Wikipedia claims a much lower weight, coming from substituting 2 for the leading 3. Given everything else, the higher figure seems more likely (with thanks to Miles Bader for pointing the above link out).

The observation here is that FRA compliance no longer neatly separates trains. Part of it comes from the very heavy low-speed trains in France, of which the MI 2N is an example. I do not know whether this is caused by special regulations – on the one hand, the TGV reportedly has 500 tons of buff strength, but on the other hand, Sweden’s X40 is also quite heavy.

The reason for this is that while high buff strength adds weight, its effect is much larger on lightweight frames than on heavyweight frames. A train that is already heavy will become heavier if it is required to be FRA-compliant, but typically only by a few tons. New Jersey Transit’s ALP-46 locomotive is 7 tons heavier than the European locomotive it is based on, of which 4.5 come from FRA regulations. This applies equally well to low-power bilevels. Even lightweight, high-power products such as the KISS would be considered middleweight by single-level standards.

Observe, however, that to achieve acceptable average weight, FRA-compliant products have to sacrifice power (as is done in Toronto or on Caltrain) and also to have a heavy locomotive drag many relatively light coaches, raising axle load. For fast service, one must use a product like the Colorado Railcar, which is the heaviest train per unit of weight on both this table and the single-level table, and which also awkwardly is a high-level train with much greater height than permitted by any European loading gauge, avoiding the low-floor weight penalty.

FRA Rules Are Not Just Buff Strength

The FRA waiver approach, adopted by Caltrain, appears to be a relatively simple way for agencies to get out of the buff strength rule. Caltrain applied for and got a waiver from a number of regulations that increase train weight, including buff strength but also several others. The comments written in Caltrain’s application, as well as the experience from SMART, suggest that there are problems with the FRA bigger than just the one regulation that’s most glaringly unnecessary.

First, the regulations that Caltrain asked out of are not just buff strength, but also less sexy rules: corner posts, collision posts, anti-climb mechanism, and so on. All of these are extra work for trains, and Caltrain indicates that it’s impossible to modify European EMUs to meet these rules for a small order. It would result in “no bids,” the application said, based on feedback from the largest vendors.

Now, SMART’s experience is very high capital costs for rolling stock: $6.7 million per two-car DMU. Those are compliant DMUs; there were four other bids, some compliant and some not, all more expensive. However, even the noncompliant bids were not off-the-shelf. They were not even noncompliant in general – they needed to comply with all rules except buff strength. Off-the-shelf DMUs run on mainline tracks in North America with time separation. One positive example is the O-Train, which has spent $34 million on six three-car sets for a service expansion, using completely off-the-shelf Alstom Coradia trains for the new order; the initial order not only used off-the-shelf Bombardier Talents, but also piggybacked on a large Deutsche Bahn order.

Although the performance under a partial FRA regime can be comparable to that under a European regime, the cost of modifying small orders can be very large, as Caltrain discovered. As a result, commuter rail agencies make do with inferior products such as the Colorado Railcar (which loses 42 seconds accelerating to 60 mph, vs. about 30 for a Stadler GTW) and pay $4-5 million per car.

For large orders, the problem is less acute, and indeed, Northeastern commuter rail EMUs are fine, if not great. The M-7s are a little heavier than comparable European EMUs, and the Silverliner Vs and the M-8s are much heavier, but the cost per car is only about $2.5 million, the performance is fairly good, and the reliability is very high. Spread over more than a thousand M-7s, the modifications required to build a compliant EMU are not too expensive. The FRA or other branches of the government could theoretically try to get uniform designs for other cars to spread modification costs over multiple orders, but instead, the next-generation trains proposed for Amtrak orders are overweight and low-performance, and explicit geared toward the needs of local manufacturers rather than those of transit agencies.

Another issue is the reliance on large vendors in drafting regulations and waivers. That’s a first line of cost increase, since it could shut out smaller vendors, which can’t adapt to the unique regulations so easily. Auckland had 11 bids for rolling stock for its electrification project; Caltrain designed its waiver in consultation with 4. On top of this, note again that Caltrain said about the buff strength rule that “to require compliance would result in no bids received.” If there could be bids but they are too high, then it’s harder if at all possible to get waivers. Many of the regulations are quite small and vehicles could be modified to meet them, for some additional cost – nothing huge by itself, but added together, it makes a DMU cost $3.3 million per car and not $2 million.

Finally, while the waiver regime allows new rolling stock to get in, it says nothing about maintenance regimes. Caltrain did not ask for waivers from maintenance requirements, even though the FRA discourages multiple-unit trains by treating them as locomotives for maintenance purposes. The Talents, Coradias, etc. have established maintenance requirements, and often agencies order not only the trains but also maintenance over their lifetime, from the manufacturers, who already know how to fix them. They do not explode from undermaintenance in Europe. Neither do their counterparts in Japan.

The alternative approach is to start from service needs, rather than from bureaucratic needs. This is what I mean when I talk about FRA revolutions. A train or a train concept with a history of success elsewhere should by default be legal on mainline tracks in the US and so should the established operating and maintenance practice, and it’s up to the FRA to show that it’s unsafe rather than up for the manufacturers to prove it once again. This is to a large extent the approach used with time-share waivers, which have put Talents and soon Coradias on mainline track in Canada and GTWs and Desiros in the US. If collisions with freight trains are prevented using other means (not that FRA compliance offers much protection to begin with!), and there is a track record of normal operation absent freight trains, there should not be problems with running those trains on shared mainline track. They do it in Europe and Japan, more safely than in the US. There’s no legitimate reason not to import that practice.

FRA Stonewalling

Stephen Smith interviewed the FRA last month asking questions about its regulations and the waiver process. The initial round of responses is included below, unmodified except very minor formatting, followed by my own commentary; there was also followup, which I’ll provide on request, but the responses generated were uninteresting. The three PDF files attached by the FRA in its email to Stephen are also included.

FRA’s role in regulating passenger rail safety

Ensuring the safety of America’s railways is job one.  FRA has jurisdiction over passenger operations of rails including current and planned high-speed intercity passenger rail service.  FRA enforces specific regulations governing passenger equipment crashworthiness, emergency systems, and emergency preparedness.  FRA does not exercise jurisdiction over insular rail systems (i.e. subway, light rail, narrow gauge, etc.). Visit for more information.

FRA’s approach to safety regulation
The U.S. approach to safety regulation uses crashworthiness principles and standards.  Rail rolling stock in the U.S. is generally larger in terms of size, weight, and mass.  There are no freight trains (with the length of 125 cars) operating in Europe, nor 286,000lbs freight cars.  In contrast to the European rail network, traffic on the U.S. rail system is dominated by privately-owned freight railroads.  The mix of freight and passenger train traffic creates a complex operating environment, which pose distinct hazards.  In the U.S., intercity and commuter trains commonly share the same tracks with freight trains weighing 15,000 tons or more, requiring morestringent safety regulations instituted by FRA.

There are more than 250,000 highway-rail grade crossings in the United States, and commercial trucks are much heavier than typical European trucks (with freight tonnage substantially higher), so the risk of a crossing collision involving large commercial vehicles and passenger trains, is greater in the U. S.  As a result, FRA has actively sought to establish robust passenger rail equipment safety standards to mitigate the hazards that exist.

FRA and International Peer Review/Best Practices
FRA has studied the design and operation of European and Asian passenger rail systems, and other nations have – for decades – looked to the FRA for guidance and expertise in designing robust safety assurance systems.  Rigorous testing and applied research have helped in the development of standards for U.S. passenger rail service.

Passenger rail regulatory initiatives
There are several initiatives underway regarding alternatively-designed passenger equipment.  The key is use of alternative performance standards which may allow foreign designs to meet U.S. crashworthiness standards.  FRA expects these requirements will be formally incorporated into future regulations.  The work of the Engineering Task Force (ETF), which was created before RSIA, is an outgrowth of FRA’s Railroad Safety Advisory Committee (RSAC)—a group comprised of rail industry stakeholders – is developing Tier III (latest generation) passenger equipment safety standards.  FRA has a comprehensive system safety approach to ensure that infrastructure, equipment, and operations are rigorously designed, engineered and tested.  In the passenger rail arena, this means attention is paid both to accident avoidance, and accident mitigation (i.e. occupant survivability).

Rail equipment procurement costs
With the infusion of unprecedented federal investment thanks to the Obama Administration, a renewed market for passenger rail equipment is emerging, and the stringent Buy American requirements set forth by the Administration’s high-speed intercity passenger rail program will provide a much-needed boost to U.S. manufacturing.  The Sec. 305 Next Generation Corridor Equipment Committee (comprised of the states, FRA and the rail industry) is working to develop equipment standards that balance the necessity of ensuring safety, while taking into consideration the costs and prospective benefits of regulation, as required by law.

Standards harmonization
Current guidelines are intended to allow alternatively-designed rolling stock that meets UIC standards, to be modified for use in the U.S.  See the attached draft report of the Railroad Safety Advisory Committee, Technical Criteria and Procedures for Evaluating the Crashworthiness and Occupant Protection Performance of Alternatively-Designed Passenger Rail Equipment for Use in Tier 1 Service.

Waiver requests
There are several operators seeking waivers to use lighter passenger equipment.  FRA intends to revise existing regulations to incorporate a process that ensures operators seeking to utilize non-compliant equipment, can obtain approval to do so under the existing waiver process, while maintaining the level of safety.

The section about the FRA’s approach to safety regulation is full of false claims. Let’s start from the easiest: it is completely false that American trucks are heavier than European trucks. It may be true on average, but the maximum gross weight of an American truck is 40 short tons, or 36 metric tons; individual states may impose higher limits, going up to about 60 metric tons, but the Interstate system and other national roads are designed to the federal limit. In contrast, the EU limit is 40 metric tons, and some EU member states have waivers and have higher limits, including Britain (44) and Sweden (60). Japan’s limit is 36 tons. I do not know what the gross load limit is at individual level crossings, but assuming it is not different from the national limit, in both Sweden and Japan there are many crossings carrying EMUs that are lighter than the heaviest permitted trucks. While Europe has less truck traffic than the US per capita (see e.g. ton-km numbers here), the difference isn’t so large that it justifies an entirely different policy.

Unsurprisingly, lighter weight is not a problem at level crossings: Caltrain’s waiver study, which the FRA is familiar with because it granted the waiver, found that UIC-compliant trains are at least as safe as FRA-compliant trains in grade crossing accidents.

The claim about freight train weight in the US and Europe is true in broad outline, but misleading. First, Australia has the same freight train length and weight as the US, but has British-style regional passenger trains, i.e. narrow and light. Second, from the point of view of a 500-ton passenger train, it does not matter whether it hits a 4,000-ton Swiss intermodal train or a 15,000-ton American coal train; both are like hitting a solid wall. For deformability purposes, the weight of a single car or locomotive matters more.

Although the weight of a single freight car is higher in the US than in Europe and Japan, the difference between American cars and some locomotives running in Europe and Japan is small. American locos weigh about 130 metric tons, and the heaviest cars are 155 short tons, or 141 metric. The RENFE Class 333 locomotive weighs 120 metric tons, and the Vossloh Euro locomotive has versions weighing 123 metric tons running in Spain and Sweden. Most European locomotives are lighter, but the UIC system is fully capable of dealing with heavier locos, with better safety than in the US. Japanese freight locos can be even heavier, up to 134 tons for JR Freight’s Class EH500, and passenger service in Japan is far safer than in Europe, to say nothing of the US.

Missing from the FRA’s safety regime entirely is any mention of stopping distances or derailment protection. With positive train control, the only collision risk comes from a derailed train, and derailments are common enough that freight railroads demand some track separation from passenger tracks, to reduce liability. FRA buff strength is nearly worthless in such a scenario: according to the Caltrain waiver report again or page 15 of the waiver request PDF, Tier I strength offers protection up to a relative speed of about 40 km/h; since Tier I is applicable up to an average speed of 200 km/h, we obtain that Tier I strength cuts 4% from the stopping distance. The practice in other countries with mixed legacy track is to limit the stopping distance instead – for example, Germany had to develop an entirely new signaling system to allow stopping distances longer than a kilometer.

The other sections basically say “Trust us, we know what we are doing, and at any rate we will do better in the future.” Sometimes, the FRA is even contradicting earlier statements it made, for example that its regulations do not increase passenger train weight; however, the biggest zinger, the claim about truck weight in the US vs. in other developed countries, is a consistent line.

Whether the FRA’s upcoming Tier III regulations will actually be an improvement remains to be seen, but is doubtful. The documents supplied by the FRA are ambiguous as to whether the FRA will even permit high-speed EMUs, a configuration used since the Shinkansen in the 1960s. The FRA says on page 23 of the first PDF it attached:

FRA realizes that some of the more modern HSR train sets used overseas eliminate the conventional power car and use an electrical multiple‐unit configuration that includes passenger seating in the cab car. However, there are no simple answers to the question of whether passenger seating in cab cars is appropriate. The answer will require careful research and full consideration of the operating environment where the trainset operates. Protection for the operator and passengers will remain a key factor.

Readers with some knowledge of HSR history will know that the Shinkansen has had no passenger fatalities. But in fact more is true: the ICE has only had one fatal accident and that came from the bridge falling on a derailed train, killing people in car three and behind while sparing the first two cars; the Pendolino EMUs running at 200-250 km/h all over Europe have not had passenger fatalities; and the recent Wenzhou accident involved one train falling from the bridge, killing people in multiple cars. Finally, at Zoufftgen the passenger train was an EMU, and the low fatality count (6 including the crew of the freight train) was attributed to the presence of crumple zones and a survivable space.

This is stonewalling at its finest: insist that the people in charge know what they’re doing and handwave all concerns by appealing to special circumstances, which are usually not all that special. As we’ve seen before with the FRA’s self-justifying approach to waivers, the agency exists mainly in order to keep existing. Finer examples of Decide-Announce-Defend exist in environmental policy, but this is a very good one in transportation policy.

Amtrak’s Role in Regulatory Reform

In my previous post, I focused on the FRA’s self-justifying bureaucratic approach to regulation. However, the other main institute of intercity rail in America, Amtrak, too doesn’t come out of the comments looking very well. Unlike the FRA, Amtrak is not actively malevolent, and on the narrow issues it raised, it’s in the right. However, its choice of what to comment on betrays a warped sense of priorities.

On pages 35-36 of the document detailing the comments to transportation regulatory changes and the agency responses, Amtrak effectively asks the FRA to permit it to operate trains at up to 160 mph, rather than 150 mph as is the limit today. Says Amtrak,

The National Railroad Passenger Corporation (Amtrak) states that regulations governing high-speed track are duplicative and overlapping.  Amtrak notes that one set of regulations for track Class 8 governs speeds from 125 mph up to 160 mph, and yet another provision in this section states that operations at speeds above 150 mph are currently authorized by FRA only in conjunction with a rule of particular applicability (RPA) that addresses the overall safety of the operation as a system.  Amtrak believes that the speed threshold for an RPA should be 160 mph, to be consistent with the class track speeds.

This is a sensible request, within the boundaries set by accepting the rule of particular applicability in principle. The FRA is wrong to brush it off. However, Amtrak’s decision to make this its stand about speed while neglecting to ask for a waiver from the static buff strength rule shows it’s more interested in pizzazz than in performance.

Amtrak trumpets its 24-mile catenary upgrade, permitting trains to plow the tracks between New Brunswick and Trenton at 160 mph, up from 135 mph today. The time saving from this move is 1:40 minutes, minus a few seconds for acceleration; the time saving from going at 160 mph rather than 150 as the FRA currently permits is 36 seconds, again minus a few seconds for acceleration. The sole purpose of this is to let Amtrak brag about top speed, as it already does. The literally hours that could be saved by higher cant deficiency and higher acceleration are not on Amtrak’s radar, for they do not by themselves let Amtrak write press releases about its top speed.

Although the FRA is unwilling to repeal its regulations preventing unmodified European or Japanese trains from running on US track, it also practically begged agencies to request waivers. The process is sure to be onerous and frankly masochistic, but if Amtrak is willing to make a comment to try to cut the Acela’s travel time by 36 seconds, it ought to be willing to go through the motions of submitting a waiver request to cut it by 2 hours.

The FRA Doesn’t Need Reform – It Needs A Revolution

Via Systemic Failure, I’ve learned that the federal government is implementing regulatory reform, including some cosmetic changes to railroad regulations; for details, go to this file and see pages 30-41, 54-61, 105-106, 108-109, 112-113, and 115-127.

Drunk Engineer already rightly excoriates the FRA for sticking to its static buff strength regulations even in the face of positive train control, but the full quote given by the FRA to the SRC, which raised the issue, showcases Kafkaesque malevolence. On pages 39-40, the FRA says:

FRA’s regulatory approach to passenger equipment safety is balanced and does incorporate both crash avoidance and crashworthiness measures.  FRA necessarily considers the safety of the rail system as a whole, beginning with ways first to avoid an accident, such as through adherence to standards for railroad signal and operating systems (to avoid a collision) and railroad track (to avoid a derailment).  Yet, FRA is indeed concerned about mitigating the consequences of an accident, should one occur, and crashworthiness features are an essential complement to crash avoidance measures in providing for the overall safety of the rail system.

FRA has tailored the application of its crashworthiness standards.  See 49 CFR 238 Subpart C, and § 229.141.  SRC itself notes that, as a tourist railroad, it is exempt from the crashworthiness standards.  Similarly, FRA has established a policy to issue waivers under appropriate circumstances to help limit the impact of these standards on light rail equipment that shares use of trackage or rights-of-way with conventional rail equipment (see appendix A to 49 CFR part 211).  FRA has also continued to explore means of making its standards more performance-based.  FRA has developed guidelines through the RSAC process for waiver approval to use alternative, performance-based crashworthiness standards for passenger equipment operating at speeds up to 125 mph.  FRA is pursuing a similar approach through the RSAC process to develop standards for passenger rail equipment operating at speeds up to 220 mph.

FRA’s intent has been to develop a set of standards in the alternative to FRA’s structural and occupant protection requirements for railroad passenger equipment operating at speeds up to 125 mph that would provide the same level of safety and yet be more performance based and more technology and design neutral.  Consequently, FRA does anticipate that the alternative standards will provide a benefit to the industry to the extent regulated entities take advantage of the additional flexibility.

Observe that, after saying its regulations are important for the safety of the entire system, the FRA basically admits they’re bad for modern passenger rail, and proposes that railroads that want to do better seek waivers. At this stage, I doubt even the FRA believes that its trains are safer for occupants in crashes with freight trains than UIC-compliant EMUs with crumple zones. The FRA is simply justifying its own existence here, giving itself more jurisdiction than it really needs. Demanding that railroads paint an F on the front end of every locomotive (p. 40-41) is a joke; making agencies jump through hoops to obtain trains that don’t telescope in crashes is a danger to public safety.

If the FRA truly believed its rules were necessary for freight compatibility – or if it were simply captive to freight interests – it would promulgate a streamlined process by which passenger-primary lines can switch to UIC or Japanese rules. New operations could convert lines to those rules by consent of the host freight railroad; it would be a bonanza for the freight rail industry and a ripoff for passenger rail, but it would only impose costs on the public that the public could pay. It would not require a new waiver application from each operator, which costs more than what smaller operators can pay.

Note also that Amtrak, far from following the FRA’s request for waiver applications, only asked for one major change: it asked for performance-based track inspection regimes (p. 124), rather than ones based only on top speed as determined by track class. The FRA brushed it off, saying that maintenance requirements and derailment risk depend on speed. An agency that really thinks this, and doesn’t think axle load or center of gravity matters, should not be in charge of developing alternative standards.

The FRA is beyond hope. Its direct boss, Secretary of Transportation Ray LaHood, should submit a list of about 10-20 existing regional and high-speed trains, from both Europe and Japan, and tell the FRA that it has until the end of the year to write rules under which all listed trains can run on US tracks unmodified except for such modular changes as loading gauge, or else it’ll be dissolved. Freight rail could regulate itself; the AAR won’t do a worse job than the FRA is currently doing. Passenger rail should just pick either the UIC or Japan and follow its rules consistently. Without this gun to the FRA’s proverbial head, nothing will change. It needs revolution, not gradual reform.

Followup on the FRA and Amtrak

My posts about the FRA and American railroad incompetence are getting a lot of traction nowadays, thanks to links from Aaron Renn and Stephen Smith, of which the latter has been relinked by Matt Yglesias. The comments to those posts have often brought up the question of why I believe that come 2015, the buff strength requirement will be gone. They also sometimes propose that FRA regulations are useful in the unique circumstances of American railroads. Let me address both concerns right now.

In 2009, Amtrak published its first document proposing higher-speed trains in the Northeast. In this document Amtrak states that,

Subsequent analysis by Amtrak suggests achieving 2 hour and 15 minute service between New York and Washington in the long-term by 2030 will require modifications to existing equipment, or deployment of next generation rolling stock, to allow required speeds through curves, as well as expansion of capacity into and through Manhattan, NY. Table 2 includes estimates of costs required to replace Amtrak’s existing NEC fleet with next generation equipment. As discussed above, this next generation of equipment has the potential to be lighter, and thus faster, than the current generation. However, performance specifications for such equipment will need to be developed and will depend in part on emerging standards for positive train control (PTC) and crash avoidance systems.

My reading of this is that the Amtrak believes the FRA will indeed waive buff strength requirements once PTC comes online; this is buttressed by the fact that Caltrain got a waiver, based in part on a requirement that it install PTC first. The PTC discussed doesn’t seem to be heading anywhere good – note the discussion of developing performance specifications rather than using the emerging worldwide standard that is ERTMS – but it does indicate that Amtrak’s new premium-cost locomotives could be much lighter.

As an aside, this document is what first clued me in to Amtrak’s incompetence. For example, immediately below the paragraph quoted above, Amtrak proposes to raise cant deficiency (“underbalance”) on Metro-North territory from 3″ to 5″; the Acela trainsets can do 7″, and Pendolino trainsets close to 11″. Based on this rather low standard, Amtrak claims “an additional five minutes of trip time reductions are potentially available with the deployment of modified or new equipment.” (Try half an hour.)

As for the second concern, usually the arguments in favor of FRA regulations hinge upon exaggerated claims that the US railroad system is unique. One commenter claims that railroaders call cab cars coffin cars because of the possibility of grade crossing accidents. In reality, lightweight trains safely cross roads at-grade abroad, to say nothing of light rail networks in the US.

There are still plenty of old-time railroaders who believe that in crashes, FRA compliance offers extra protection. It does not. Please read Caltrain’s structural report and compliance assessment for the FRA waiver, which include a technical explanation of the mechanisms for accident survivability used in Europe. Caltrain’s simulations show that high buff strength is only relevant at relative speeds between 15 and 25 mph, and that European EMUs and compliant cars are equally safe in grade crossing accidents. The FRA seems convinced of the safety of European EMUs; it is reportedly harassing Japanese manufacturers about compliance with European survivability regulations (for example, in collisions with a 6-kg steel ball) rather than American ones. Finally, high weight is a liability as much as it is an asset: at Chatsworth, the loss of life came from the fact that the first passenger car telescoped into the heavy locomotive.

Update: the Business Alliance for Northeast Mobility, an organization supporting Amtrak’s NEC Master Plan, published an article claiming Amtrak made the right choice to buy the aforementioned locomotives, claiming that Amtrak is underfunded. Recall that the Master Plan is the document that came out of the report referenced above, complete with the same laconic assumptions on train performance, as well as false claims about capacity constraints. The Business Alliance’s article’s greatest sin is the claim at the end that,

Smith also ignores the question of funding when he suggests that Amtrak should purchase Electric Multiple Units (EMUs) for the NEC. Unlike locomotives and non-motorized passenger cars, currently in use on the NEC, EMUs have smaller engines on each passenger car. The debate between investing in EMUs vs. locomotives + cars is beyond the scope of this post. Still, what’s clear is that EMUs would need a significantly higher up-front investment and require an even larger amount of government support, which is highly unlikely at this time.

In reality, a new unpowered Amtrak coach costs $2.2 million, about the same as a decent FRA-compliant EMU on the LIRR and Metro-North. And the three European EMU orders in Railway Gazette’s April 2011 compilation cost between $1.3 and $2 million per car.

Bad FRA Regulations

Since many people are linking to my previous post identifying the FRA as the primary obstacle to an American railroad revival, I’m hoisting a comment I wrote on the Infrastructurist detailing some of the FRA regulations that are the most destructive.

The original references for this are from Zierke’s website and the East Bay Bicycle Coalition, but those are a few years out of date, and recently the FRA has made noises about reforming the first two rules, which are the most destructive to intercity rail. Unfortunately, those reforms are not good enough, chiefly because they are designed to preserve the FRA’s bureaucracy, piling more obstacles on any attempt to modernize US trains.

1. 945 tons buff strength for locomotives and end cars and 360 for coaches (link); the maximum that’s even partly defensible is Europe’s 200, and Japan’s 100 is perfectly safe. This is by far the most important: as a result of this rule, the Acela power cars weigh 90 metric tons, vs. 68 for the TGV power cars they’re derived from. Zierke notes that the lighter the train, the higher the FRA weight penalty is.

2. 4″ maximum cant deficiency for non-tilting trains, except 5″ on track connected to 110+ mph rail (derisively called the magic HSR waiver by railfans). The Acela is limited to 7″ despite tilting. Non-tilting TGVs do 180 mm in France (about the same as the Acela) and tilting trains do 250-300 mm in Japan and a bunch of European countries, no special testing required except on actual track. In addition, superelevation is limited by regulation to 7″ minus a safety margin; high-speed lines around the world have 180 mm actual superelevation, and the Tokaido Shinkansen, which has tighter curves, has 200 mm.

Those two regulations are already being somewhat modified. Amtrak seems to believe that the nationwide mandate for positive train control (PTC), passed in 2008 in response to the Chatsworth crash, will allow it to run lighter trains; the FRA has granted Caltrain a waiver from the FRA buff strength rule provisioned upon PTC installation. As for cant deficiency, the FRA has already decided on a revision allowing tilting trains up to 225 mm cant deficiency, and non-tilting trains up to 150 mm by testing.

Unfortunately, those two reforms only look good at first glance. The Caltrain waiver application from the buff strength rule was devised in consultation with the biggest rolling stock manufacturers – Bombardier, Kawasaki, Alstom, and Siemens – which indicates which rules they could comply with and which they could not. This may well lock out smaller vendors, such as Stadler and CAF. Stadler’s FLIRT is the fastest-accelerating, highest-powered regional train on the market; it is also very light, and may well not comply even with regulations Caltrain did not ask out of.

In addition, since such waivers depend on PTC, if the freight railroads succeed in their attempt to delay or water down PTC implementation, which they consider too expensive, then future rolling stock purchases will remain heavy. Indeed, Amtrak’s purchase of new electric locomotives, due to enter service in 2013, is FRA-compliant and more expensive than purchases of similar locomotives in Europe; this despite the fact that they are intended to run on the Northeast Corridor, which has a PTC system.

As for the cant deficiency waiver, it was obtained by testing existing outdated technology in the US, such as Amtrak locomotives and the EMUs used on commuter rail in the Northeast. No attempt was made to use high-cant deficiency European technology, a point also made by Drunk Engineer. Such trains would have to be tested to the FRA’s satisfaction, and not be allowed to run at the same speeds as they do in Europe. In fact the FRA’s proposed rule revision includes a language about higher track standards for cant deficiency higher than 5″, never mind that TGVs run on less than perfect legacy track at 7″ cant deficiency.

In addition, for high-cant deficiency operation, it’s important to regulate both cant deficiency and the rate at which it changes. The muscles can adjust to lateral acceleration, given enough time; thus the jerk, or the rate of change of acceleration, must also be prescribed. With a proper superelevation ramp and change in cant deficiency based on the abilities of existing trains, high speeds and high cant deficiencies can combine well, as found in a Swedish study about the feasibility of very high-speed trains on legacy track.

Additional FRA regulations, which hamper regional rail more than intercity rail, seem to be here to stay. These include the following:

3. Two employees per train; regional trains should have one. But, bear in mind, many regional operators have multiple conductors, and the limit to lower staffing is antiquated trains or managerial incompetence rather than the FRA. For example, the MBTA believes it needs one conductor per two cars.

4. Brake tests at every turnaround. Intercity trains can enter a stub-end station and back away in 3-4 minutes, and do every day in Germany; regional trains turn around in 3-4 minutes in Japan. However, Amtrak makes Keystone trains dwell 10 minutes at Philadelphia.

5. Four-quadrant gates required for quiet zones; these make quiet zones expensive, and as a result trains have to blare loud horns at grade crossings, alienating neighbors and creating NIMBYism.

6. No regulations encouraging high-performance lightweight cars and good signaling. The FRA should mandate a modern system, preferably ETCS, which permits a throughput of up to 37 trains per hour at standard speeds. This is 12 tph more than currently can run between New Jersey and New York, and would be about $13 billion cheaper than Amtrak’s Gateway tunnel proposal, which would add 21 tph.

The multitude of bad regulations is why I think FRA reform has to be intensive, without any half-measures. The new rail regulations in the US should as much as possible be based on UIC (predominantly European) and Japanese regulations, with the present status quo ignored.

The only role of American regulators should be to devise a coherent system to allow European and Japanese trains to interact with each other. In some places, such as PTC and jerk, it requires greater regulation, based on best industry practices in the rest of the developed world. But in most other areas, the rule should as far as possible be that everything that’s legal in Europe or Japan is legal in the US.

I’ll repeat my exhortation in my post on Mica’s privatization plan: please contact the relevant Congressional representatives and let them know that any real reform must include extensive FRA reform. Organization and electronics should come before concrete, and such deregulation of rolling stock could jive well with the conservative mood in Congress that Mica is channeling. And if it does not, then never mind – the Democrats could seize FRA reform, too, as a good-government issue. It’s more important than whether future railroads are run publicly or privately.