Yesterday, the Federal Register published FRA’s revised rules for enhanced strength of front-end cab and MU cars:
This final rule is intended to further the safety of passenger train occupants by amending existing regulations to enhance requirements for the structural strength of the front end of cab cars and multiple-unit (MU) locomotives. These enhancements include the addition of requirements concerning structural deformation and energy absorption by collision posts and corner posts at the forward end of this equipment. The requirements are based on standards specified by the American Public Transportation Association (APTA). FRA is also making clarifying amendments to existing regulations for the structural strength of passenger equipment and is clarifying its views on the preemptive effect of this part.
The new regulation, which goes into effect March 9, 2010, will increase the “weight-penalty” of FRA -compliant passenger trains. Even worse, the regulation will complicate attempts by transit agencies to procure world-class trainsets from foreign manufacturers. Rather than promote safety, the FRA regulations serve to carve out a protected niche in the US market. US transit agencies have no choice but to run Amtrak-style “museum” trains, or even try to custom-design trains from scratch.
In the published rule, some of the comments from the public reflect growing concern that FRA regulations needlessly bulk-up the weight of trains:
6. Whether the Requirements Affect Vehicle Weight
AWA commented that, while it stands firmly for rail safety, it was concerned with any policies or institutions that have the effect of limiting the development and operation of passenger trains and pushing existing or potential rail passengers onto already crowded highways and putting more people at greater risk. As stated in its comments, AWA believed the NPRM to be the latest in a series of FRA rules that attempt to enforce safety by adding yet more heavy metal to already massive passenger trains.
AWA raised concern with increasing the weight of America’s “uniquely bulky” passenger rail fleet compared with the “extremely safe, lighter” trains of Switzerland, Germany, Sweden, or Japan, and how the added monetary costs of such heavier trains in terms of purchase and greater energy consumption may discourage or inhibit passenger rail carriers from acquiring rail cars or running passenger trains.
AWA recommended FRA reconsider its action and consider the impacts of mandating even heavier and costlier “steel-wheeled Hummers.” AWA recommended that FRA look to harmonize passenger rail car construction and safety standards with the widely-accepted standards of the International Union of Railways (UIC), a worldwide organization for the promotion of rail transport and cooperation, so that rail agencies and operators can afford to provide more people with passenger rail service.
Similarly, a private citizen principally commented that rather than increasing crashworthiness requirements and the weight of cab cars, FRA should first investigate whether existing UIC standards for end strength and buff strength would provide equal or better safety than the current FRA standards. The commenter believed that increasing the weight of passenger equipment should be a major concern from both an economic and an environmental point of view, causing greater wear on the track, increased energy consumption, and decreased operational performance. The commenter believed that reducing car weight and enabling use of European designs can reduce costs, and that there is a definite environmental and economic impact from having collision standards that differ from those in Europe or Asia.
In response to this criticism, FRA report offers this defense:
As noted earlier, FRA wishes to dispel the belief that there is a meaningful correlation between an increase in a vehicle’s crashworthiness and its weight. As FRA has stated, crashworthiness features from clean-sheet designs can occupy the same space as other material and not weigh in excess of the structure(s) being replaced. There is considerable leeway in designing such systems so that no additional weight is required, and the car body structure itself typically accounts for only between 25 to 35 percent of the final car weight.
Claims that FRA-compliant vehicles are no heavier than comparable European equipment does not pass the laugh test. Compare a “clean-sheet” Acela to a TGV, or a “clean-sheet” Colorado Railcar DMU to European DMU, etc, etc. The weight differences are incredible.
(And let’s not even bring up light-weight Japanese designs….)
The FRA regulation goes on to rehash the tired “Europe is different” argument:
Nonetheless, as FRA has previously stated, the rail operating environment in the United States generally requires passenger equipment to operate commingled with very heavy and long freight trains, often over track with frequent highway-rail grade-crossings used by heavy highway equipment. European and Asian passenger operations, on the other hand, are generally intermingled with freight equipment of lesser weight, and in many cases highway-rail grade-crossings also pose lesser hazards to passenger trains in Europe and Asia due to lower highway vehicle weight. FRA is necessarily concerned with the level of safety provided by passenger equipment designed to European and other international standards when such equipment is intended to be operated in the United States and must ensure that the designs are appropriate
for the nation’s operating environment. FRA does believe that these new requirements for collision posts and corner posts will significantly enhance the performance of the posts in protecting occupants of cab cars and MU locomotives, while having little if any effect on total vehicle weight.
If there is any difference at all in US and European rail environments, it is that European rail safety efforts focus on more cost-effective signal improvements, and other ways to avoid accidents from occurring in the first place. The FRA takes the SUV-driving soccer-mom approach. Assume collisions are inevitable, so design trains like tanks.