Comment: [49 CFR Part 229] UP does not believe there is a safety justification for FRA’s requirement that the letter “F” be displayed on each locomotive to identify the front end.
FRA response: FRA is currently engaged in a rulemaking proceeding dealing with the revision of the Locomotive Safety Standards. An NPRM in the matter was published on January 12, 2011, RIN 2130-AC16, 76 FR 2200. The subject of the letter “F” requirement was not raised by UP or any other RSAC participant during the development of the NPRM, but to the extent practicable, FRA will consider UP’s suggestion as a late comment to the NPRM in developing the final rule. The letter “F” requirement is related to safety, because it identifies not only the front end of the locomotive, but also identifies all of the locomotives equipment.
Good thing that locomotive has a letter “F” on it; otherwise, how is one to know it is a locomotive? And for those hoping PTC would mean the end of the infamous FRA weight-penalty, guess again:
Comment: [49 CFR Part 238 ] SRC believes that the crashworthiness standards in Part 238 are detrimental to the use and growth of passenger rail transportation. According to SRC, the regulation assumes wrecks to be commonplace, which has not been the case, acts to curtail the export of passenger rail equipment to other countries, and results in prohibitive capital costs for passenger rail expansion and startup in the U.S. SRC states that with the advent of PTC, perhaps the regulation could be revised to enable passenger rail equipment to compete more effectively with other modes of transportation.
FRA response: 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.
Chamber of Commerce types are already blasting the regulatory “reform” as underwhelming. As much as I hate to admit it, they may have a point.