| First Name | Marty |
|---|---|
| Last Name | Westland |
| Email Address | martywestland@att.net |
| Affiliation | Carson and Colorado Railway |
| Subject | Proposed In-Use Locomotive Regulation /Clarifications |
| 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 |
| Attachment | |
| Original File Name | |
| Date and Time Comment Was Submitted | 2023-03-16 11:41:03 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.