| Comment | Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
Re.Sec. 2478.2 Exemptions, I would suggest the following language:
"Locomotives that meet the following requirements are exempt from
this Locomotive Regulation and all its reporting requirements.
(a) Locomotives propelled by engines with a total continuous
rated power of less than 1,006 horsepower(hp). For
locomotives..."(continue as proposed).
Explanation: When I read this proposal, it was not clear that
these exemptions released the Operator from all aspects of this
Regulation, including registration and recordkeeping. Inclusion of
the term "continuous" rated power will eliminate some confusion in
the assessment of steam locomotives which typically are not rated
in horsepower, but in tractive effort.
Re.Sec. 2478.11 Reporting and Recordkeeping Requirements. par.(g)
Historic Railroad Report. I think the authors mistakenly omitted
"No later than July 1 of each Calendar Year..." Without that
language the paragraph does not define when and how often the
operator "...shall submit..."
Re.Sec. 2478.13 (a)(2) I would suggest increasing the maximum fuel
usage allowed. I propose "...does not use more than 20,000 gallons
of fuel collectively..."
Explanation: Some historic steam locomotives will require more
than 10,000 gallons of fuel for just a few days of operation.
Given the small number of steam locomotives in the state, their
limited days of operation, and practical absence of NOx emissions,
I would appeal to the Board's generosity to grant more latitude
for operation of museum/educational steam locomotives. Can an
exemption be made for steam vs. diesel-electric locomotives?
Thank you for your consideration.
Sincerely,
Marty Westland, Director
Carson and Colorado Railway,
Independence, California
|
|---|