# Amtrak’s Continued Ignorance

There was a congressional hearing about high-speed rail. Henry Miller in comments here took notes – thanks for this, much appreciated! The overall content was lacking; the politicians seemed like they were spinning their wheels, not because they themselves were bad (Reps. Tom Malinowski, Peter DeFazio, and Seth Moulton all raised interesting issues) but because they were getting ignorant advice from the witnesses, none of whom has any experience in successful high-speed rail networks. Among those, Amtrak deserves the most demerits, and its head, William Flynn, should lose his job purely over that testimony, if the reporting of what he said is accurate.

Flynn, based on both what Henry said in comments and on reporting in Politico Pro, said that Amtrak needs a trust fund on the model of that for American highways – and said that this is “the most important lesson we can learn” from countries with high-speed rail.

The rub is that countries with high-speed rail do not in fact have such trust funds. Financing models vary by country, but do not look like the American highway trust fund. For example, French LGVs are funded line-by-line, with the decision on each specific line taken at the highest level of government, with financing coming either purely from the public sector (as with the LGV Est) or from a higher-cost PPP (as with the LGV Sud-Europe-Atlantique).

To understand why, it’s important to understand the relationship between politics and the civil service in functioning, high-capacity states. Politicians make big decisions on spending priorities, and then the civil service implements those decisions. There is little political input on routing decisions, and the exceptions where there is tend to have the worst, highest-cost programs. So the planning is done by the civil service, which then presents a preliminary design for politicians. But the elected politicians have the final word on the yes-no decision whether to fund, and can also ask for high-level modifications (“reduce the budget,” “give the unions the wage increases they demand,” etc.).

The American highway trust fund inverts this principle. Going back to Thomas MacDonald, federal highway builders had internal sources of money without having to ask elected politicians for regular appropriations. In contrast, politicians exerted considerably petty power over routing. For example, in Twentieth-Century Sprawl, Owen Gutfreund points out that in the early planning for what became the Interstate highways, the FDR administration reduced the scope of roads to be built in Vermont from four planned routes to two in retaliation for its voting Republican in 1936. In The Big Roads, Earl Swift also notes that MacDonald himself did not think the Interstates could pay for themselves through tolls, but, due to pressure by politicians to write a positive report, the resulting report’s coauthor proposed toll-free motorways instead, hence the prohibition on tolling Interstates. MacDonald himself was fired by the Eisenhower administration for expressing concern that the roads were hollowing out the American rail network and proposing cars-and-trains investment instead of cars-only.

And here we have Amtrak’s CEO not only supporting that model, but also lying that this model is how high-speed rail has been built. In reality, no such trust funds exist anywhere with high-speed rail. I don’t know why Flynn says such a thing, which not only is verifiably wrong, but also has no reason to be believed in the first place – there is no grain of truth to it, no trust fund-like model for high-speed rail megaprojects.

As with most such fraud, he is probably lying to himself and not just to the people who pay his salary. Americans, as a collective, are wantonly ignorant of the rest of the world. The only time they interact with the rest of the world, especially countries that don’t speak English, is through intermediaries in international consulting, who get the skewed sample of world projects that invite in international consultants, omitting the bulk of public works built in states with in-house design capacity. Individual Americans can be knowledgeable, but their knowledge is not respected, even by people who profess their interest in state capacity. Thus, no matter how smart individual Americans can get, collectively America remains incurious.

This is the most acute in mainline rail. I suspect that this relates to the rail industry’s highway envy. For a railroader like Flynn, steeped in a culture that is technologically and institutionally reactionary and looks back to its heyday in the first half of the 20th century, the enemy, that is the Interstate system, is the obvious model for how to build. That this model produced severe cost overruns on the highways themselves does not matter; that treating rails institutionally like roads is inappropriate does not matter; that systems that get as much ridership in two days (cf. JR East) as Amtrak gets in an entire year and deliver a profit to their shareholders doing so work differently does not matter. The future, which is not in the United States in this field and hasn’t been in 60 years, is one in which people like Flynn do not even qualify for an internship.

And if Flynn wouldn’t qualify for an internship, why is he allowed to be the CEO? He should lose his job. The people who briefed him should lose their jobs. It is likely that full replacement of Amtrak’s planning staff and possibly the line workers too would be a big win for riders. Even total liquidation could well be a net positive relative to status quo: most Amtrak routes have no social value, and the one route that does, the Northeast Corridor, could well produce a more competent institution from among the ashes.

Without liquidation, it is still advisable to sideline Amtrak until it can be put out of its delayed customers’ misery. The best way forward institutionally is to set up an agency responsible for all Northeastern passenger rail operations, to subsume and replace Amtrak and the commuter rail operators. It will be run by people who can speak to the difference between French, German, and Japanese high-speed rail operating models, and who know how to implement integrated timed transfer networks and intermodal fare integration. It will buy imported equipment if there is no domestic equivalent for a similar price, and use standard European or East Asian methods for track geometry machines, signaling (ACSES is thankfully an Americanized variant of the European standard, ETCS), safety systems, timetabling, and so on. The United States has no shortage of dedicated people who speak Spanish, and secondarily Japanese, Korean, Chinese, Italian, German, or French.

Moreover, since in many cases the knowledge does exist among Americans but isn’t valued, it is important to let American civil servants interview for such an agency. I expect that most would come from an urban transit background, where in my experience the people are more curious than in mainline rail. But American railroaders too could join if they demonstrate sufficient knowledge of advanced-world operations.

That said, under no circumstances should the organizational culture be allowed to turn into anything like present-day American railroading. Current workers who do not qualify for this agency are to be laid off, perhaps with a pro-rated pension for partial service, and told to seek private-sector work. Flynn himself has no role to play in any successful rail agency. He must go, and it’s almost certain that the rest of Amtrak’s management should as well. Every day he stays in his job is a day American railroading plans based on assumptions that can be easily verified to be fraudulent.

# The United States Needs to Learn How to Learn

I just saw an announcement from November of 2020 in which the Federal Transit Administration proposes to study international best practices… in on-demand public transit.

It goes without saying that the international best practice in on-demand micromobility is “don’t.” The strongest urban public transport networks that I know of range from not making any use of it to only doing so peripherally, like Berlin. In fact, both France and Germany have rules on taxis that forbid Uber from pricing itself below the regulated rates; Japan, too, banned Uber from operating after it tried to engage in the usual adversarial games with the state that it is so familiar with from the US.

And yet, here we see an FTA program attempting to learn from other countries not how to write a rail timetable, or how to modernize regional rail, or how to design a coordinated infrastructure plan, or how to integrate fares, or how to do intermodal service planning, or how to build subways affordably. It’s perhaps not even aware of those and other concepts that make the difference between the 40% modal split of so many big and medium-size European cities and the 10-15% modal splits that non-New York American cities top at.

Instead, the FTA is asking about a peripheral technology that markets itself very aggressively to shareholders and VCs so that it can ask for more money to fund its losses.

Earlier today I saw a new announcement of congressional hearings about high-speed rail. There are 12 witnesses on the list, of whom none has any experience with actual high-speed rail. They’re American politicians plus people who either run low-speed trains (Amtrak, Brightline) or promise new vaporware technology (Hyperloop*2, Northeast Maglev). American politicians and their staffers are not that stupid, and know that there are strong HSR programs in various European and Asian countries, and yet, in the age of Zoom, they did not think to bring in executives from JR East, DB, SNCF, SBB, etc., or historians of these systems, to discuss their challenges and recommendations.

I bring up these two different examples from the FTA and Congress because the US has trouble with learning from other places. It’s not just that it barely recognizes it needs to do so; it’s that, having not done so in the past, it does not know how to. It does not know how to form an exchange program, or what questions to ask, or what implementation details to focus on. Hearing of a problem with a public agency, its first instinct is to privatize the state to a consultancy staffed by the agency’s retirees, who have the same groupthink of the current publicly-employed managers but collect a higher paycheck for worse advice.

Worse, this is a nationwide problem. Amtrak can and should fully replace its senior management with people who know how to run a modern intercity railroads, who are not Americans. But then middle management will still think it knows better and refuse to learn what a tropical algebra is or how it is significant for rail schedule planning. They do not know how to learn, and they do not recognize that it’s a problem. This percolates down to planners and line workers, and I don’t think Americans are ready for a conversation about full workforce replacement at underperforming agencies.

This will not improve as long as the United States does not reduce its level of pride to that typical of Southern Europe or Turkey. When you’re this far behind, you cannot be proud. It’s hard with American wages being this high – the useless managers even in the public sector earn more than their Northern European counterparts and therefore will not naturally find Northern Europe to have any soft power over them. Wearing sackcloth and ashes comes more naturally with Italian or Spanish wages. But it’s necessary given how far behind the US is, and bringing in people who are an American’s ideal of what a manager ought to be rather than people who know how to run a high-speed passenger railroad is a step backward.

# Streaming the Biden Infrastructure Plan

I streamed my thoughts about the Biden infrastructure plan, and unlike previous streams, I uploaded this to YouTube. I go into more details (and more tangents) on video, but, some key points:

• Out of the nearly $600 billion in the current proposal that is to be spent on transportation, public transportation is only$190 billion: $80 billion for intercity rail,$85 billion for (other) public transit, $25 billion for zero-emissions buses. This 2:1 split between cars and transit is a change from the typical American 4:1, but in Germany it’s 55:42 and that’s with right-wing ministers of transport. • Some of the spending on the car bucket is about electric vehicles, including$100 billion in consumer subsidies, but that’s still car spending. People who don’t drive don’t qualify for these subsidies. It’s an attempt to create political consensus by still spending on roads and not just public transit while saying that it’s green, but encouraging people to buy more cars is not particularly green, and there’s no alternative to sticks like fuel taxes in addition to carrots.
• The $25 billion for zero-emissions buses is likely to go to battery-electric buses, which are still in growing pains and don’t function well in winter. In California, in fact, trolleybuses are funded from the fixed infrastructure bucket alongside light rail and subways and are ineligible for the bucket of funding for zero-emissions buses. It is unknown whether in-motion charging qualifies for this bucket; it should, as superior technology that functions well even in places with harsh winters. • The$85 billion for public transit splits as $55 billion for state of good repair (SOGR) and only$30 billion for expansion (including $5 billion for accessibility). This is a terrible idea: SOGR is carte blanche for agencies that aim to avoid public embarrassment rather than provide useful service to spend money without having to promise anything to show for it, and Amtrak in particular cycles between deferring maintenance and then crying poverty when money becomes available. Federal money should go to expansion alone; a state or local agency that doesn’t set aside money for maintenance now isn’t going to do so in the future, and periodic infusions of SOGR money create moral hazard by encouraging maintenance deferral in good times. • The Amtrak money is a total waste; in particular, Amtrak wants$39 billion for the Northeast Corridor while having very little to show for it, preferring SOGR, climate resilience, and agency turf battles over the Gateway project over noticeable improvements in trip times, reliability, or capacity.

Hayden then chimes in, talking about FRA regulations, saying that they’re different from American ones, so European and Asian prices differ from American ones, seemingly indifferent to the fact that he just threw Andreski under the bus – Andreski said that multiple-units do not cost $2.5 million per car and if a public contract says they do then it’s omitting some extra costs. The only problem is, FRA regulations were recently revised to be in line with European ones, with specific eye toward permitting European trains to run on American tracks with minimal modifications, measured in tens of thousands of dollars of extra cost per car. In a followup conversation off-video, Hayden reiterated that position to longtime reader Roger Senserrich – he had no idea FRA regulations had been revised. Hayden’s response also includes accessibility requirements. Those, too, are an excuse, albeit a slightly defensible one: European intercity trains, which are what American tourists are most likely to have experience with, are generally inaccessible without the aid of conductors and manual boarding plates. However, regional trains are increasingly fully accessible, at a variety of floor heights, and it’s always easier to raise the floor height to match the high platforms of the Northeast Corridor than to lower it to match those of low-platform networks like Switzerland’s. 1:45: asked about why Metro-North does not run EMUs on the wired Shore Line East, a third official passes the buck to Amtrak, saying that Amtrak is demanding additional tests and the line is Amtrak’s rather than Metro-North’s property. This is puzzling, as 1990s’ Amtrak planned around electrification of commuter rail service east of New Haven, to the point of constructing its substations with room for expansion if the MBTA were ever interested in running electric service on the Providence Line. It’s possible that Amtrak today is stalling for the sake of stalling, never mind that commuter rail electrification would reduce the speed difference with its intercity trains and thus make them easier to schedule and thus more reliable. But it’s equally possible that CDOT is being unreasonable; at this point I would not trust either side of any Amtrak-commuter rail dispute. # Amtrak is Blocking MBTA Electrification Ten years ago, Amtrak began putting out its outrageously expensive proposals for high-speed rail on the Northeast Corridor. Already then, when it asked for$10 billion to barely speed up trains, there was a glaring problem with coordination: Amtrak wanted hundreds of millions of dollars to three-track the Providence Line so that its trains could overtake the MBTA’s commuter trains between Providence and Boston, even though the same benefit could be obtained for cheaper by building strategic overtakes and electrifying the MBTA so that its trains would run faster. Unfortunately, Amtrak has not only displayed no interest in coordinating better service with the MBTA this way, but has just actively blocked the MBTA.

The issue at hand is MBTA electrification: the MBTA runs an exclusively diesel fleet. These trains are slow, polluting, and unreliable. Lately they have had breakdowns every few thousand kilometers, whereas electric trains routinely last multiple hundreds of thousands of kilometers between breakdowns. The current scheduled trip time between Boston and Providence is about 1:10 on the MBTA with a total of nine stops, whereas Amtrak’s southbound trains do the same trip in 35 minutes with three stops, leading to a large schedule difference between the trains, requiring overtaking. Fortunately, modern electric multiple units, or EMUs, could make the same stops as the MBTA in about 45 minutes, close enough to Amtrak that Amtrak could speed up its trains without conflict.

The MBTA would benefit from electrification without any reference to Amtrak. Connecting Boston and Providence in 45 minutes rather than 70 has large benefits for suburban and regional travelers, and the improved reliability means trains can follow the schedule with fewer unexpected surprises. The line is already wired thanks to Amtrak’s investment in the 1990s, and all that is required is wiring a few siding and yard tracks that Amtrak did not electrify as it does not itself use them. With the diesel locomotives falling apart, the MBTA has begun to seriously consider electrifying.

Unfortunately, the MBTA has made some questionable decisions, chief of which is its attempt to procure electric locomotives rather than self-propelled EMUs. The MBTA’s reasoning is that EMUs require high platforms, which cost about $10 million per station, which is a small but nonzero amount of money on the Providence Line. As a result, it neglected any solution involving buying new EMUs or even leasing them from other railroads for a pilot project. It’s only looking at electric locomotives, whose travel time benefits are about half as large as those of EMUs. And yet, Amtrak is blocking even the half-measures. The MBTA sought to lease electric locomotives from Amtrak, which uses them on its own trains; Amtrak quoted an unreasonably high monthly price designed to get the MBTA to lose interest. As of last week, the MBTA put the plan to lease electric locomotives for its electrification pilot on hold. No plans for purchase of rolling stock are currently active, as the MBTA is worried about lead time (read: having to actually write down and execute a contract) and does not know how to buy lightly-modified European products on the open market. As far as Amtrak is concerned, speeding up the MBTA is not really relevant. Yes, such a speedup would improve Amtrak’s own scheduling, removing a few minutes from the Northeast Corridor’s travel time that would otherwise cost hundreds of millions of dollars. But Amtrak has time and time again displayed little interest in running fast trains. All it wants is money, and if it can ask for money without having to show anything for it, then all the better. Coordinating schedules with other railroads is hard, and only improves the experience of the passengers and not Amtrak’s managers. The MBTA’s decisionmaking is understandable, in contrast, but still questionable. It was worth asking; the MBTA is no worse for having received an unreasonable offer. However, it is imperative that the MBTA understand that it must be more proactive and less hesitant. It must electrify, and commit a real budget to it rather than a pilot. This means immediately raising the platforms on the stations of the Providence Line that do not yet have level boarding and buying (not leasing) modern EMUs, capable of running fast schedules. Even with some infill, there are only seven low-platform stations on the mainline and two on the branch to Stoughton, none in a constrained location where construction is difficult. This is at most a$100 million project, excluding the trains themselves. The MBTA could operate the Providence Line with seven to eight trainsets providing service every 15 minutes and the Stoughton Line with another four providing the same. Procuring trains for such service would cost another $250 million or so, but the MBTA needs to buy new rolling stock anyway as its diesel locomotives are past the end of their useful lives, and buying EMUs would pay for itself through higher ridership and lower operating expenses coming from much faster trips. The MBTA is fortunately salvageable. It has a serious problem in that the state leadership is indecisive and noncommittal and prefers a solution that can be aborted cheaply to one that provides the best long-term financial and social return on investment. However, it is seriously looking in the right direction, consisting of better equipment providing higher-quality service to all passengers. Amtrak is unfortunately not salvageable. An intercity railroad whose reaction to a commuter railroad’s attempt to improve service for both systems is to overcharge it on rolling stock proves that it is ignorant of, indifferent to, and incurious about modern rail operations. A chain of managers from the person who made the decision to offer the MBTA bad lease terms upward must be removed from their positions if there is any hope for improved intercity rail in the Northeastern United States. # Amtrak Uses Climate Adaptation as an Excuse to Waste More Money When the Gateway tunnel project began at the start of this decade, it was justified on the same grounds as the older ARC project: more capacity for trains across the Hudson. This justification continued even after the existing tunnels suffered damage in Hurricane Sandy. As costs mounted and it became clear there was no political will to round up$25 billion of federal and state money for capacity, the arguments changed. An engineering report softly recommended long-term tunnel closure for maintenance, without comparing the cost of new tunnels to that of continuing to close the tunnels one tube at a time on weekends, and subsequently both the funding requests and the press releases shifted in tone to “we must close the tunnels or else they’ll collapse.” Unfortunately, this racket is now spreading to other parts of the American mainline rail network – namely, Amtrak and its high-speed rail program.

Case in point: in an internal report, leaked to the press via a belated public records request, Amtrak fearmongers about the impact of rising sea levels on its infrastructure. Bloomberg helpfully includes maps of rising sea levels inundating part of the Northeast Corridor’s infrastructure in low-lying parts of Connecticut, Delaware, and Maryland.

What Bloomberg does not say is that the Northeast Corridor is slightly elevated over the parts shown as inundated, due to river crossings. There’s even an attached photo of the station in Wilmington, clearly showing the train running above ground on a viaduct, at what looks like about five meters above sea level. There are no photos from other areas along the corridor, but regular riders as well as people looking closely at satellite photos will know that through the flood-prone parts of Secaucus, the Northeast Corridor is already on a berm, crossing over intersecting roads, and the same is true in most of Connecticut. On Google Earth, the lowest-lying parts of the route, passing through southeastern Connecticut and parts of Maryland, are 3-4 meters above sea level.

The rub is that a sea level rise of 3-4 meters is globally catastrophic to an extent that doesn’t make Amtrak any of the top thousand priorities. Cities would be flooded, as helpfully shown by photos and images depicting the railroad running above street level. Entire countries would be wiped off the map, like the Maldives. Low-lying coastal floodplains, so crucial for high-intensity agriculture, would disappear. In Bangladesh alone, a sea level rise of a single meter would flood 17.5% of the country, which with today’s demographics would displace about 25 million people; the sea level rise required to threaten the Northeast Corridor is likely to produce a nine-figure global refugee crisis.

To Amtrak’s credit, it’s somewhat pushing back against the apocalyptic language – for now. The Bloomberg article tries to demagogue about how unconcerned Amtrak is with climate change-related flooding, but at least the quotes given in the piece suggest Amtrak views this as a concern, just not one it’s going to talk about while the president openly says climate change is a Chinese conspiracy. Once the political winds will shift, Amtrak as portrayed by a close reading of the article will presumably shift its rhetoric.

However, the credit Amtrak gets for not pushing this line right now is limited. Sarah Feinberg, a former FRA administrator who was also on the panel for Governor Cuomo’s MTA genius grant competition, is described as saying talking about climate change won’t fly in Congress. In other words, in Feinberg and Amtrak’s view, “we need money to flood-proof the Northeast Corridor” is not a preposterous proposition, but a demand to be reserved until the Democrats are in charge of the federal government.

In the 2000s, Amtrak fired David Gunn from his position as CEO, since he wouldn’t succumb to political pressure to skimp on maintenance in order to achieve on-paper profitability so that Amtrak could be privatized. In his stead, the Amtrak board installed the more pliable Joe Boardman. Then Obama replaced Bush and economic stimulus replaced domestic spending cuts, and suddenly Amtrak discovered a backlog of maintenance, demanding billions of dollars that could have built 350 km/h high-speed rail between Boston and Washington already for state of good repair instead. The backlog has increased ever since, as it became clear Amtrak could just ask for more money without having to show any work for it as long as it was couched in language about maintenance.

The same mentality is still in place today. The required response of the American transportation complex to climate change: an immediate end to any public spending on roads and airports and massive spending on public transportation, intercity rail, and electric car charging stations, in that order. Amtrak has a role to play in advocating for more rail use as mitigation of transportation emissions, which are currently the largest single source of greenhouse gas emissions in the United States.

However, responding this way would require Amtrak to run better service. It would require it to stop playing agency turf games with other railroad agencies – after all, the planet does not care who owns which piece of track on the Northeast Corridor. It would require it to show visible improvements in speed, capacity, coverage, and reliability. It is not capable of producing these improvements and neither do other federal organs dealing with passenger rail, such as the FRA-led NEC Future effort. Thus, it is preparing the way to argue for a massive increase in spending that is explicitly not designed to produce any tangible benefit.

There is a way forward, but not with any of the people in charge today. They are incapable of managing large projects or even smoothly running a railroad in regular service, and should be replaced by people who have the required experience. Feinberg is a political operative who before her appointment as FRA head in 2015 had no background in transportation; evidently, together with the other judges of the genius grant she greenlit manifestly impossible projects.

Evidently, when New York City Transit hired a chair with a strong transportation background, namely Andy Byford, suddenly plans became more than just the state of good repair black hole plus court-mandated accessibility retrofits. Byford insists on specific positive improvements, which lay riders can judge in the coming decade as they see more elevator access and higher train frequency, provided his plan’s very high cost is funded.

With Amtrak, in contrast, there is only a black hole. There is an extremely expensive high-speed rail plan out there, but the first segment Amtrak wants to build, Gateway, wouldn’t provide any tangible benefit in speed or even capacity (the current state of Gateway is a $11 billion tunnel without additional surface tracks, so the two-track bottleneck would remain). A project that was once a critical capacity increase has since been downgraded into the state of good repair black hole, in which many tens of billions of dollars can disappear without showing anything. As the NEC Future process evolves, any calls for high-speed rail in the Northeast are likely to evolve in the same direction: no improvement, just endless money poured on the same service quality as today, justified in terms of adaptation or resilience. # FRA Reform is Here! 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.