Six and a half years ago, the Federal Railroad Administration announced that it was going to revise its passenger train regulations. The old regulations required trains to be unusually heavy, wrecking the performance of nearly every piece of passenger rolling stock running in the United States. Even Canada was affected, as Transport Canada’s regulations mirrored those south of the border. The revision process came about for two reasons: first, the attempt to apply the old rules to the Acela trains created trains widely acknowledged to be lemons and hangar queens (only 16 out of 20 can operate at any given time; on the TGV the maximum uptime is 98%), and second, Caltrain commissioned studies that got it an FRA waiver, which showed that FRA regulations had practically no justification in terms of safety.
The new rules were supposed to be out in 2015, then 2016, then 2017. Then they got stuck in presidential administration turnover, in which, according to multiple second-hand sources, the incoming Republican administration did not know what to do with a new set of regulations that was judged to have negative cost to the industry as it would allow more and lower-cost equipment to run on US tracks. After this limbo, the new rules have finally been published.
What’s in the new regulations?
The document spells out the main point on pp. 13-20. The new rules are similar to the relevant Euronorm. There are still small changes to the seats, glazing, and emergency lighting, but not to the structure of the equipment. This means that unmodified European products will remain illegal on American tracks, unlike the situation in Canada, where the O-Train runs unmodified German trains using strict time separation from freight. However, trains manufactured for the needs of the American market using the same construction techniques already employed at the factories in France, Germany, Switzerland, and Sweden should not be a problem.
In contrast, the new rules are ignoring Japan. The FRA’s excuse is that high-speed trains in Japan run on completely dedicated tracks, without sharing them with slower trains. This is not completely true – the Mini-Shinkansen trains are built to the same standards as the Shinkansen, just slightly narrower to comply with the narrower clearances on the legacy lines, and then run through to legacy lines at lower speed. Moreover, the mainline legacy network in Japan is extremely safe, more so than the Western European mainline network.
On pp. 33-35, the document describes a commenter who most likely has read either my writings on FRA regulations or those of other people who made the same points in 2011-2, who asked for rules making it possible to import off-the-shelf equipment. The FRA response – that there is no true off-the-shelf equipment because trains are always made for a specific buyer – worries me. The response is strictly speaking true: with a handful of exceptions for piggybacks, including the O-Train, orders are always tailored to the buyer. However, in reality, this tailoring involves changes within certain parameters, such as train width, that differ greatly within Europe. Changes to parts that are uniform within Europe, such as the roofing, may lead to unforeseen complications. I don’t think the cost will be significant, but I can’t rule it out either, and I think the FRA should have been warier about this possibility.
The final worry is that the FRA states the cost of a high-speed train is $50 million, in the context of modification costs; these are stated to be $300,000 for a $50 million European high-speed trainset and $4.7 million for a Japanese one. The problem: European high-speed trainsets do not cost $50 million. They cost about $40 million. Japanese sets cost around $50 million, but that’s for a 16-car 400-meter trainsets, whereas European high-speed trainsets are almost always about 200 meters long, no matter how many cars they’re divided into. If the FRA is baking in cost premiums due to protectionism or bespoke orders, this is going to swamp the benefits of Euronorm-like regulations.
But cost concerns aside, the changes in the buff strength rules are an unmitigated good. The old rules require trainsets to resist 360-945 metric tons of force without deformation (360 for trains going up to 200 km/h, 945 beyond 200 km/h), which raises their mass by several tons per cars – and lightweight frames require even more extra mass. The new ones are based on crumple zones using a system called crash energy management (CEM), in which the train is allowed to deform as long as the deformation does not compromise the driver’s cab or the passenger-occupied interior, and this should not require extra train mass.
How does it affect procurement?
So far, the new rules, though telegraphed years in advance, have not affected procurement. With the exception of Caltrain, commuter railroads all over the country have kept ordering rolling stock compliant with the old rules. Even reformers have not paid much attention. In correspondence with Boston-area North-South Rail Link advocates I’ve had to keep insisting that schedules for an electrified MBTA must be done with modern single-level EMUs in mind rather than with Metro-North’s existing fleet, which weighs about 65 metric tons per car, more than 50% more than a FLIRT per unit of train length.
It’s too late for the LIRR to redo the M9, demanding it be as lightweight as it can be. However, New Jersey Transit’s MultiLevel III is still in the early stages, and the railroad should scrap everything and require alternate compliance in order to keep train mass (and procurement cost) under control.
Moreover, the MBTA needs new trains. If electrification happens, it will be because the existing fleet is so unreliable that it becomes attractive to buy a few EMUs to cover the Providence Line so that at least the worst-performing diesels can be retired. Under no circumstance should these trains be anything like Metro-North’s behemoths. The trains must be high-performance and as close as possible to unmodified 160 km/h single-level regional rail rolling stock, such as the DBAG Class 423, the Coradia Continental, the Talent II, or, yes, the FLIRT.
Metra is already finding itself in a bind. It enjoys its antediluvian gallery cars, splitting the difference between one and two decks in a way that combines the worst of both worlds; first-world manufacturers have moved on, and now Metra reportedly has difficulty finding anyone that will make new gallery cars. Instead, it too should aim at buying lightly modified European trains. These should be single-level and not bilevel, because bilevels take longer to unload, and Chicago’s CBD-dominant system is such that nearly all passengers would get off at one station, Millennium Station at the eastern edge of the Loop, where there are seven terminating tracks and (I believe) four approach tracks.
Ultimately, on electrified lines, the new rules permit trains that are around two thirds as heavy as the existing EMUs and have about the same power output. Substantial improvements in train speed are possible just from getting new equipment, even without taking into account procurement costs, maintenance costs, and electricity consumption. Despite its flaws, the new FRA regulation is positive for the industry and it’s imperative that passenger railroads adapt and buy better rolling stock.