Re: Age of Steam Era Freightcars
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As a current transportation regulator, although for aviation, I can state that the non-emergency regulations are required to have a public comment period and those comments must be resolved by the regulator and the comment and resolution placed in the public record. That record is easier to find for today's rules with the internet, but the basics of administrative law applied during this list's period of interest. So yes, industry is very likely to have commented on and shaped the FRA rules.
ATSF North Bay Lines
Golden Gates & Fast Freights
PO Box 44736
Washington, DC 20026-4736
From: "destorzek@... [STMFC]"
Sent: Tuesday, April 11, 2017 5:24 PM
Subject: [STMFC] Age of Steam Era Freightcars
In the recent "ORER thread", the statement was made that USRA cars began to disappear "because they were forty years old." That led several of us to object that the age limit on freightcars is a child of the FRA, and therefore far in the future to the interests on this list. Someone then asked if the AAR interchange rules had an age based prohibition on car in interchange, and I said no. I am now finding how hard it is to prove a negative, but no one has cited an actual rule to that effect, either.
It did lead me to dig out a Soo Line railroad document I have titled OFFICE OF CHIEF MECHANICAL OFFICER - FREIGHT CARS OWNED - AS OF JANUARY 1, 1962. You'll have to forgive that it is one year past our 1960 cut-off, but I feel the data is applicable to our era of interest. The Soo Line was one of the smaller of the class one railroads, and is likely typical of the industry as a whole. It had an easy to understand medium size car fleet (15,000 cars at this time) and rarely renumbered anything.
The document has the feel of a periodic report; likely yearly. It lists each and every group of cars, their dimensions, built date, and two columns for "RECOMMENDATIONS" headed "FOR RETIREMENT" and "NOT FOR RETIREMENT" Here are the pertinent details I gleaned, by car type:
AUTOMIBILE, For Retirement:
11 cars (all remaining) built 1915, 47 years of age
1 car (all remaining) built 1917, 45 years of age.
40 cars built 1924, 38 years of age, 58 NFR (Not for retirement)
BOXCARS, For Retirement:
5 cars (all) built 1913, 49 years of age
3 cars (all) built 1916, 46 years of age
1 car (ALL) built 1917, 45 years of age
4 cars (all) built 1919, 43 years of age
13 cars (all) built 1920, 42 years ! of age
7 cars (all) built 1921, 41 years of age
11 cars (all) built 1923, 39 years of age
60 cars built 1926, 36 years of age, but 386 NFR
40 cars built 1928, 34 years of age, but 326 NFR
FLATCARS, For Retirement:
23 cars (all) built 1912, 50 years of age
21 cars (all) built 1913, 49 years of age
40 cars built 1921, 41 years of age, but 64 NFR.
GONDOLA, for retirement:
6 cars (all), built 1916, 46 years of age
40 cars built 1921, 41 years of age, but 296 NFR
60 cars built 1923, 39 years of age, but 112 NFR
40 cars built 1927, 35 years of age, but 156 NFR
HOPPER, For Retirement:
9 cars (all) built 1913-16, 46-49 years of age
Oldest cars NFR built 1926, 36 years of age
ORE, For Retirement: (these are interesting)
50 cars built 1906-07, 55-56 years of age, but 73 NFR
Those fifty six year old ore cars are former DSS&A on the Marquette Range, there are an additional 138 cars built in 1910 that are not being retired. This traffic was totally captive to the Soo (DSS&A) and many of these cars still rode on archbar trucks, into the sixties. It was obvious that the mines the South Shore served were playing out ( the last ore was shipped over the DSS&A dock in 1966 or 67, IIRC) and the railroad was simply not going to invest in new equipment.
The Soo had much the same situation on the Gogebic Range on the former Wisconsin Central, although, since this was joint service with the C&NW, the cars had been brought up to interchange standards.However, the oldest of those cars also dated to 1910, and none were newer than 1919. The joint service with the NP on the Cyuna Range got the newer (1925 and 1930) 70 ton cars.
What does this all mean? Well, one thing I take away is that the general service cars (box, flat, and gons) seem to be dying of obsolescence, rather than age, an an age right around forty years. The ca! rs are too small, and two little capacity (40 and 50 ton) for current needs. Even as they were clearing the last of the pre-WWI boxcars off the roster, they had been buying and building new 50' boxcars in their own shops, and were just two years away from launching into a fifteen year program of building modern 50', 70 ton cars with ten foot doors. The little 40 ton, 40' x 8' IH grain boxes from an earlier era were simply no longer useful.
I also wonder about the FRA age limit of 1974. Knowing that these regulations are normally open for comment and negotiated with the industry being regulated, it appears the numbers chosen (50 years in 1974, decreasing to 40 years in 1983) were chosen specifically because they would cause the railroad industry little pain; they were essentially already in compliance, with few exceptions.
But, of course, that's all in the future.