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.
Pedestrian Observations 
There’s no legitimate reason, but this isn’t just an FRA problem. Part of the reason that American cars are so overweight is that it’s illegal to import many European cars, by which I mean cars that are sold in that market, rather than cars made in Europe or by European companies, and the headache of jumping through all the hoops to get them approved and make the necessary modifications has been too big. Even if Ford wants to sell a car that it builds in the US and sells in Europe, there’s still mandatory bureaucracy and possible modifications involved. The FDA and drug approval is the same: the US doesn’t have reciprocal agreements about drug safety, so drug companies have to prove that drugs are safe in the rest of the world, and then separately also that they’re safe in the US. And getting that approval is a pretty huge burden.
To be fair, importing US cars to Europe is just as bad; both sides have stupid rules on autos. And an import into Japan will have yet another set of rules, as will an import into Australia, as will….
On the other hand, with trains and drugs it’s one set of rules for the US, one set of rules for *practically everyone else*; the European rules in each case are good enough for most of the rest of the world and the US rules aren’t. It didn’t used to be this way; it used to be that US rules were world standard. Our regulators have fallen behind. Way behind.
Japanese and European train rules are also quite different. Japan has lower buff strength limits – it seriously believes in prevention over mitigation, which is why it has very few accidents but the ones that do happen are often catastrophic, whereas European rules include a variety of mitigation measures, the difference with the FRA being that the European measures work. The signaling systems are also completely incompatible. That’s why I push for Richard’s idea of lifting one set of rules as a second best solution, the best being developing rules that accommodate both existing European and Japanese stock.
The O-Train is so cost effective, I’m really surprised its success hasn’t spurred the construction of similar systems elsewhere (even in Gatineau, for example). The costs of the original equipment order and infrastructure were $21 million for three trainsets, four stations, and eight km of track: that’s a cost of $2.6 million per km, and ~$1500 per weekday rider. The lessons: one-person operation, proof-of-payment, lightweight DMUs, clockface schedules, etc. are necessary for effective and cheap operation seem to be completely lost on the rest of North America.
It’s certainly possible to replicate the operations of the O-Train, and indeed lightweight DMUs, clockface schedules, and proof of payment have been implemented in a few places, including the River Line. But part of what makes the O-Train so cost effective is its very high ridership, for a line of that length. And nobody’s managed to replicate that, whether because they haven’t learned its planning lesson (just build a short line where there’s the best potential for strong ridership thanks to connections to existing transit and things like universities) or because there just aren’t very many opportunities as good for building ridership as the one they had in Ottawa, first with the busways and then with the O-Train.
M8s weigh more than M7s because M8s carry around a transformer, more inverter, pantographs and sundry other equipment allowing them to run on AC along with everything they need to run on third rail. Part of the reason North American passenger cars weigh more than European cars is that they are wider and longer. In the Northeast, passenger cars are going to be 10’6″ and 85 feet long for the next few centuries if not forever. Unless you want to tear out Penn Station, Grand Central and all the suburban stops they serve. 30th Street Philadelphia, Suburban, Market East and all the suburban stops they serves….Jamaica, Newark, Baltimore, Trenton, Stamford, New Haven… I suspect that 10’6″ wide, 85 feet long and 48 inch high platforms is going to be the standard East of the Rockies. Probably going to be 14’6″ high so they can go through the North River Tunnels even though they never go anywhere near the North RIver tunnels.
NYC subway cars have a lot in common between divisions. If IRT cars are an analog for European cars and IND/BMT cars are an analog for North American cars.. IRT cars weigh a lot less. They are shorter and narrower. Go stand at the PATH turnstiles on Track 1 or 2 in Newark some time. Which cars weigh more? The NJTransit and Amtrak cars or the PATH cars?
Gotta do tonne or kilograms per passenger for cars and tonne per kilowatt for locomotives. They aren’t all that far apart.
The M-7s are pretty heavy even per unit of length. (So are NYCT trains, by the way.) Meter for meter, they’re a third heavier than FLIRTs. The M-8s and Silverliner Vs are almost two-thirds heavier.
Alon, that’s because low-floor trains like FLIRT have an inherent structural weight penalty.
Oh. Never mind …
American Know How can overcome that!
Do you know what the inherent low-floor weight penalty is, if there is one? I tried comparing the Class 423 with the Class 424 in Germany, but apparently the Class 423 is uniquely lightweight, and the Class 425 is high-floor and weighs the same as the Class 424.
Alon, I recall (without reference) a number like 20% gross being thrown around some years ago. But I have no reference for that. As designs (and FEA) improve, the difference decreases, but will never be zero. Five minutes of searching found this (unreferenced) quip (HaJo 4May 2008):
As near as I can tell FLIRTs are narrow and have 2 by 2 seating. Silverliners, Arrows, M-whatevers have 2 by 3 seating. Or 25 percent more per row. How many tonnes per seat…
The Continental FLIRTs are 3.05 meters wide. The American cars are 3.2. The NYCT cars are 2.6 or 3.05 and still weigh more per unit of train length.
FLIRT for Finland: 3.2m wide, 232 seats (mostly 3+2: see the diagram); standing capacity 323; 132t; 72.2m
So Silverliner Vs, at 108 seated passengers, 26 meters and 66.5 tonnes are 615 kg per passenger. The Finnish FLIRT is 232 seated passengers and 132 tonnes or 569 kg per passenger. 92 percent of a Silverliner. Or a Silverliner is 108 percent of a Finnish FLIRT. How well does the air conditioning on the Finnish train cope with 40 degrees and 100 percent humidity? Does it get to 40 degrees in Helsinki? How much heavier is the 25Hz/60Hz transformer in the Silverliner versus the straight 50 Hz single voltage transformer in the FLIRT? How much do the traps and stairs in the FLIRT weigh. Hmmmmm …. nah it’s all because of those studly FRA required buffers and the grab irons.
The Finnish FLIRT has to cope with -40 degrees, and this required beefing up some systems. That’s why the Scandinavian FLIRTs are heavier than the Continental FLIRTs despite being hardly any wider. It’s for the same reason that the Velaro RUS is heavier per car than the Velaro CN and the Velaro E.
Also, one reason not to think in terms of weight per seat is that the FLIRT has wide doors to speed up boarding, ample vestibule space, and a car that has subway-style seating to provide more standing space. See diagram here. The Finns could’ve provided the same seating-to-standing space proportion as the Silverliner if they’d wanted.
OK, off topic, but something that shocked me was that the newest generations of NY subway cars are not only non-articulated (pretty much every new design is, to save weight) but don’t have any sort of inter-car walkways, let alone the wide, bright, safe, non-impeding and capacity-increasing passages that one expects on any new metro or urban mainline train anywhere.
Culture? Not Invented Here? Don’t Have a Clue? Don’t Give a Damn? 9/11? (answers all other questions, after all.)
Any informed ideas?
It’s a cultural and historical thing. NYCT got burned badly in the 1970s with the R44 and R46 purchases, both meant to be higher-performance in anticipation of Second Avenue Subway. It succeeded with the R62 by having very conservative specs; the conservative specs stuck, and as a result it’s not thinking about major changes. Narrow tech advances such as electronic information displays and regenerative braking it adopts, but anything that requires changing the train concept is out. (The flip side of this is that those trains are cheap.)
Conversely, one of the biggest arguments for articulated bodies, safety, isn’t that big a deal in New York. The subway police started cracking down in 1990, and by the mid-1990s subway crime was in rapid decline. In e.g. France, fears of suburban crime have led SNCF to get walk-through trains. Fear of crime in New York is lower (and possibly NYCT is also less amenable to this kind of thinking about safety and less likely to listen to passenger complaints), so there’s no pressure on NYCT to get articulated trains.
Update: I forgot another reason – in New York, they think safety means not having panhandlers, and associate moving between cars with panhandler behavior as well as with other illegal behavior. The view, at least at NYCT, is that keeping people from moving between cars and begging is more important for safety than letting passengers move away from cars they feel unsafe in or have better line of sight.
I’m a little confused by the use of terminology here—”articulated” means a particular train configuration, with one common truck for two cars, right? And that’s basically orthogonal to having easy inter-car transfer, which can be done well enough using diaphragms, etc., on non-articulated cars.
BTW, isn’t one of the best arguments for having good inter-car connections that passengers really like them…? (oh, I know, who cares about those jerks… 🙂
I agree that shared bogies and easy inter-car transfer are separate concepts.
Shared bogies reduce train weight (they’re a very significant percentage the total) and maintenance. There are disadvantages of (starting with higher higher per-axle loading) of course, or they’d be universal.
Then there’s the separate notion of “trains” as a unit (run as a unit, maintained as a unit, separated only in heavy overhaul) versus mostly-mix-and-match cars, which I know have a strong appeal here in the the land of retro. With mostly-mix-and-match it’s still possible to have OK-but-not-great connections.
My off-topic query was: why no connections at all NYC? (I’d bet $100 on “culture”. That’s Not How We Do Things so Why Should Anybody Want Such a Foreign Thing.)
As I said, I think the lack of connections comes from conservatism about rolling stock as well as association of moving between cars with panhandlers. The latter issue is a cultural misfeature of city planners, but the former has its benefits. You will not see New York spend $4 million per car or buy from Boeing or AnsaldoBreda.
For what it’s worth, the trains in Singapore are walk-through, but have standard bogies. The train pics I’ve seen from Tokyo look like BART trains: not fully walk-through, but relatively okay for inter-car connections. (The cars are permanently coupled, despite having standard bogies.)
The Transport Politic asked staff at both the Washington Metro and NY-MTA why they don’t use articulated trains. Basically, they gave the standard “we like our trains the way they are, thank-you-very-much” answer.
I’ve also had discussions with BART staff about this, and they have the same attitude.
For what it’s worth, just about all NYCT subway cars are in permanently linked sets, with some of the older cars in pairs and most of the newer cars in permanently linked sets of 4 or 5. They’re linked by a drawbar, so uncoupling them requires a trip to the shops, and even then, cars in a set are pretty much always kept together barring some kind of accident that renders some of the cars unusable.
As far as comparisons to foreign rolling stock go, I think the Finnish version of the FLIRT is probably a fair baseline for comparison, as it’s the right size and seating configuration. I do wonder whether it or, say, the M-8 has more usable length as a proportion of the train length, as low-floor trains lose some space to internal stairs, and the fancy rounded cab at either end, but articulated trains gain some space between cars.
Back in the day, people used to ride between cars and do dangerous things there. I remember when young and having drunk too much going between cars to throw up on the tracks. Probably a safety engineer’s nightmare: a drunk guy with one foot on one car’s end, the other on the other, leaning over the connecting chains.
Adding jim’s comment to the comment about panhandlers, I think it is a cultural issue, but more of an “our passengers suck and we can’t let them walk between cars because they suck” issue rather than anything else.
To be fair, evidence is that they’re right. You don’t get the kind of crazy intercar behavior in London that you used to get in NY.
Well, in New York walking between cars is dangerous and noisy, so quote-unquote normal people don’t do it. In five years of riding, I think there was one time I’d have moved between cars if it were legal. Of course if it were legal and also the cars would walk-through I’d have done it often.
People used to walk between the cars all the time. Buried deep in the bowels of the MTA are statistics on how many people were injured or killed each year – it happened.
..but a subway ride was different back then. The windows opened, because the cars weren’t air conditioned, so opening the doors didn’t make it much noisier during the warmer months. The transit police were a bit more aggressive about panhandlers.
There was much discussion when it was first implemented. The official reason was that it’s dangerous to pass between cars. The unofficial reason is that it cramps the style of the panhandlers.
NYC had articulated cars for 40 years
http://nycsubway.org/cars/bmt-d.html
I’d hazard a guess that it’s loading gauge/curves. The three car BMT Triplexes were 137 feet long. BMT/IND cars are 60 feet long. So four sets of Triplexes were roughly the same lenght as ten conventional cars. IRT cars have been 51 feet long forever and ever. There’s gotta be a good reason why the IRT didn’t go to 60 foot cars or both divisions haven’t gone to 70 or 80 foot long cars.
Lexington Ave Local train using the City Hall Station as a loop track.
Downtown local at Union Square.
The correct fix is to not hire US transportation engineering “professionals”, but instead to hire technical translators.
Pick a set of known-working regulations, translate, implement. Done.
I disagree with this idea of automatically allowing any legal European trainset to be used in the other side of the Atlantic, unless some reciprocal agreement for unified certification were in place. Only small countries, or poor ones, piggyback-of-sorts on regulators from bigger countries when it comes to safety issues of industrial systems.
So, before EU-wide norms were in place, countries like Luxembourg or to an extent Belgium and Denmark accepted foreign certifications, no-questions-asked. Now they have a uniform body.
But US has a GDP roughly equal to that of UK, and 70% of its population and 90% of its size. No reason, whatsoever, for US to abdicate the possibility of imposing its own regulations, no matter how “desperate” some people might be to see European off-shelf trains running in American railways. It is just non-sense for one of the biggest/most populated/richest countries in the World to take as valid a CE-certification for which no American input was considered.
That is not to say FTA is perfect or even that it has a good record, but reforming FTA doesn’t mean outsourcing safety regulations to Europe.
AT LEAST, FTA should form a co-joint body with Brussels do deliver uniform trans-Atlantic rules (that could also include Canadians).
The problem is that the amount of expertise about modern passenger rail practices in North America really is at the same level of small or poor countries. The safety level I want to say is actually worse, but I’m only confident enough that the media reports I’m cribbing my safety numbers from are comprehensive about developed countries. That’s why the biggest mainline rail success comes from piggybacking. (And abroad, countries have been copycatting ETCS, sometimes with minor modifications, e.g. CTCS.)
The EU and Japan get away with having different rulesets for passenger trains and not talking to each other because there’s no international train travel between them and both markets are huge. It’s a shame that Paris and Berlin can’t purchase standard-gauge versions of the E231 Series for the RER/S-Bahn, but Bombardier, Siemens, Alstom, CAF, and the rest make good products and can make comparable trains – and the same is true in the other direction, with using Talents in Japan. The difference with the US is that the Europeans and Japanese generally know what they’re doing, and the FRA doesn’t.
In that case, the correct course of action is to have more competent people on FTA, not to ignore home regulations and unilaterally accept CE certifications.
It’s a lot harder to reform an agency like this than to let trains with a track record of running safely run on US tracks. The US doesn’t have to have regulations for the sake of having regulations. They’re supposed to have a purpose, like “passenger safety” or “passenger comfort.”
Institutional culture. It’s a hard problem.
You think the FRA or FTA are bad? Try to reform the Department of Defense. Nobody has succeeded, and it still has a 1940s culture. (Before that, the US dissolved the military between wars, which helps.)
The Department of Homeland Security, established under the corrupt Bush, has developed an even worse institutional culture — one of abusing citizens and covering up crimes (like, you know, rapes — there are multiple real examples of this). It’s not going to be fixable and it needs to be shut down entirely.
In the corporate world, KBR (Kellogg Brown Root) is the poster boy for toxic institutional culture, to the point where it contaminates any company which buys *it*.
Compared to these examples, the FRA and FTA, with really might be reformable; their institutional cultures came from an idealistic background originally, which helps compared to DoD or DoHS or KBR, whose cultures came from a background fundamentally hostile to people.
More to the point, the US has a pretty large rail network, comparable in size to Europe, and quite a lot of freight rail traffic. Given that the network already exists, and already has certain standards, it might not work to just import European standards: they’d have to be adapted a bit to the things that already exist on the American network, like a much bigger loading gauge and automatic couplers on trains (rather than screw couplings and buffers). Incidentally, the Finnish rail network has both of these things, inherited from its common heritage with Russia. The latter might also be a good source for technical standards given the similar size and freight orientation of the rail network, but unfortunately not really a good source of rolling stock. Still, there’s a Russian version of the Velaro, and Belarus bought a few FLIRTs for regional service. If even the former USSR can do it, given all their regulations and standards and totally non-ETCS-like PTC systems, then there’s no reason for the US not to do it either.
I’s not just the odd Velaro or FLIRT. Siemens is also developing the Desiro RUS EMU, and Alstom is designing a new EMU family for Russia in a joint venture with Russian group Transmashholding..The Alstom/Transmashholding joint venture is also developing freight and passenger electric locomotives.
Elektriraudtee in Estonia is buying Stadler FLIRTs too.
“Only small countries, or poor ones, piggyback-of-sorts on regulators from bigger countries when it comes to safety issues of industrial systems.”
The US is a third world country when it comes to safety issues of industrial systems. If we adopted European health and safety rules, it would be a *vast improvement* — we’d eliminate all manner of pervasive toxins in our food, clothing, furniture, air, water, etc.
So yeah, we are like a “small” or “poor” country in this regard.
The FRA Regulations, while definitely imperfect, play a critical role in preventing rolling stock that is not fit for the North American rail network from being put into service. It is hard to regulate robustness, the end strength requirements that Bombardier lobbied for so that it could win the Acela contract are a good start, but as had been seen they can lead to poor overweight designs. However that does not mean that every kind of European econo-box train should just be imported wholesale because they can accelerate faster or are “off the shelf”. What is needed are designs no worse than the Amfleets and other Budd stainless steel rolling stock that has stood up so well over the last 50-60 years in both regular service and various types of collisions.
How is the North American rail system so much different? First it is freight oriented instead of passenger oriented and that means any passenger rolling stock is going to be playing on a highway full of big rigs, not small Fiats like is seen in Europe. Even if we decided to blow large sums of money on advanced signaling systems to prevent collisions, North American freight train derail all the time for their own reasons and if you are on an adjacent track when that happens you’d better be in a position to take the impact.
Second our rail network is littered with grade crossings with tens of thousands that are probably just plain unsafe. Europe has far fewer crossings and where they do have them they are monitored by CCTV, hooked into the signaling system and use various kinds of advanced barrier systems to protect the integrity of the right of way. That’s all well and good, but in North America we simply have too many level crossings to protect. In the UK there are 1600 total road-rail level crossings…TOTAL. In just the United States there are over 200,000. The fact is that in North America trains are going to hit road vehicles and road vehicles include dump trucks, fuel trucks, logging trucks and low boy trailers with heavy equipment on them like armoured fighting vehicles.
Third the rail network in Europe is maintained to much higher standards than is possible in the United States. In the US we have to assume that the trains will be riding on track suffering from low or deferred maintenance. Heavier trains with robust American style suspension is better able to absorb the bumps and provide a ride that passengers will still find acceptable. Furthermore rail vehicles that aren’t designed for US conditions will simply begin to fall apart, especially all that lack of maintenance applies to the vehicles themselves. It’s happened time and time again. The DeGlen Atlantic tried by the PRR basically fell apart. The power train of the Krauss-Maffei ML 4000 C’C”s were no match for the heavy duty cycles imposed on them. The most successful European import, the AEM-7 family, was heavily ruggedized by EMD and had body shells supplied by Budd. If you don’t do something like that you are basically buying a shop queen that will get retired after only 10 or 20 years in service.
FRA Regulations aren’t a golden bullet, but they prevent things like those ICE train that turn into confetti when they derail from getting foisted on a gullible transit agency that thinks it knows better than nearly 200 years of North American railroad tradition.
“Econo-box.”
Nice. Very very nice.
Another fine American econo-box tradition saw off those “Japs” with their Subarus and Hondas and Toyotas who just didn’t understand Rugged American Freedom back in the 1970s either.
“200 years of North American railroad tradition.” Highball on the green!
Mike, the FRA regulations are not the optimal ones you’d place if the worry was derailments. To protect against derailments, the most important thing is to stop the train quickly. As a result, various countries’ safety laws mandate a maximum stopping distance, which also helps keep (fixed) signal blocks short. In Germany the maximum was 1 km until LZB; in Japan, the maximum on the legacy network is 600 meters. Present-day rolling stock in the US is actually very bad at this, because locomotives pulling unpowered cars do not brake as fast as EMUs. Tier 1 regulations are only effective up to about 40 km/h; since on a braking curve the relationship between speed and distance is roughly quadratic, and the regulations are intended to be used at speeds up to 200, all they do is shave 4% from the necessary stopping distance. A modern lightweight European or Japanese train, built for very fast braking, would get to a complete stop long before the Amfleets would get down to safe collision speed.
Second, there are tons of grade crossings in Europe and Japan – fewer than in the US per km of track, but not per train-km. The Chuo Rapid Line had 13 of them between Mitaka and Tachikawa, a segment that sees 28 tph peak traffic. It still has some west of Tachikawa. The lead cars are lighter than the maximum allowable weight for trucks. The number of passenger fatalities in the last few decades: zero. (Japan outperforms the US, by a factor of 15.)
And third, the US is not the only country without a lot of track maintenance. In Japan what they’ve discovered on rural branch lines is the opposite: the lighter the car is, the better it will ride on less than perfect trackbed. Tellingly, noncompliant DMUs that run on North American tracks with a waiver do not have big comfort problems beyond the general comfort issues of DMUs. Ottawans are just fine riding off-the-shelf, piggybacked-on-a-DB-order Talents.
Mike, your point is undermined by the fact that the FRA itself agrees that its regulations are unsafe and unfit for passengers. Paul has it on his blog:
http://reasonrail.blogspot.com/2011/11/value-of-crash-energy-management.html
“200 years of North American railroad tradition” … Honestly, this makes you sound ridiculous to anyone who knows that we’ve sorely neglected passenger rail in the past half century or so. Operating a railroad like it’s the 19th century is cute for heritage lines, but irresponsible for a serious passenger transportation agency (or company) in the 21st century. Most other countries on Earth get this, and do a lot better job than we do, in effectiveness as well as safety. You should be asking “what can we learn from them?” instead of retreating into a defensive “ARRRR! NOT INVENTED HERE” stance.