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With a new administration in D.C., it's time to think outside of the box because passenger rail's survival just may depend on it

Saturday, April 30, 2011

Addendum: Cruise Trains clarification

After reviewing a past article that I did on rail service for cruise passengers, I realize that my proposal was completely different from the one that Jon Fostik proposedMine resembles the cruise version of Auto Train where passengers would be on a train from an actual train station to a port or would be transported by a cruise line sponsored vehicle to the port at a special stop designed for the cruise line. The trains would be divided into three versions: 1) full stop routes (all large cities currently served by Amtrak), 2) limited stop routes, 3) nonstop routes. Most trains would provide limited stop service. Fostik proposes trains that would operate out of ports to various tourist destinations as a part of a cruise's package.

A perfect example of the two versions would be in Florida. My Cruise Trains would stop along Florida's east coast to drop passengers off to their ports from other eastern states..Mr. Fostik's Cruise Fun Trains idea is to have trains from Miami that would serve West Palm Beach and Orlando while another Fun Train would serve St. Augustine out of Charleston. Jacksonville could also be served with the train stopping at historic Union Terminal as part of the same package or another package that could serve Orlando, Tampa/St. Petersburg, or the Panhandle.

There are certain areas that would be more in tune with Cruise Fun Trains rather than Cruise Trains because under Fostik's plan, the cruise companies would be in total control whereas a full-on passenger rail-to-cruise train route would be completely dependent on the host railroads and enough planning. If a train is delayed due to a derailment or to being behind other trains, passengers may miss their boats. Conversely, if a train is operated a day in advance, other travelers may be upset with having to spend the extra day traveling.

Should America Start Over?

A Brief Rundown

Tomorrow will mark 40 years since Congress officially relieved the private railroads from operating passenger trains. Yet as this anniversary approaches, there are fewer trains and train routes than in 1971. Current and recent Amtrak management have been very inattentive to the National System and recently as 1 ½ years ago put out very flawed studies on the feasibility of restoring old routes.


In the wake of the Passenger Rail Investment and Improvement Act of 2008, most people who care about the future of passenger rail in America have come to the realization that the status quo no longer works. The real problems are the people who are standing in the way and the ridiculously archaic rules for any challengers to Amtrak. The main purpose is to find out exactly what starting over would look like and what should it look like?


Problems

Amtrak only has plans to replace old equipment rather than add to its already shortened supply. This move will result in fewer available seats at peak times of the year and when gas prices are already approaching September 2008 levels. Others have pointed out that Via Rail Canada has done more with less—equipment, frequencies, and routes—in the last 21 years (when the Mulroney Cabinet crippled the Canadian agency) while Amtrak seems way too eager to ditch its old equipment. I’ll take it a step further by saying that the state of North Carolina has found a way to revamp a handful of Heritage equipment Amtrak didn’t want.


When the Rio Grande gave up passenger service on April 24, 1983 and the Georgia Railroad ended mixed train service five days later, Amtrak was a statutory monopoly. The Amtrak Reform and Accountability Act of 1997 made the company a de facto monopoly. States have been free to explore other operators for the last 13 ½ years. The problem is that practically each state already had a deal with Amtrak in place. Northern New England and Missouri were the only two areas that had the option of selecting a different operator. The Downeaster’s organizers voluntarily went with Amtrak in 2001 while Missouri nearly chose Herzog in 2003.


The competition aspect brings me to my next point: While foreign rail operators and transit agencies have expressed an interest in operating intercity routes, officials in Washington, D.C. and most rail advocates have been asleep at the switch! PRIIA mandates competition for both corridors and long distance routes.

Rifts within the Community

Over time, the rail community has more or less splintered into competing factions—True Believers and Business Oriented Pragmatists. The first group has been Amtrak’s biggest backers from Day 1 and contends that the carrier has never received sufficient funding. The latter group has more of a big picture view and is more than willing to challenge Amtrak on all issues, not just on service reductions.


I have found myself drifting from being in a peacemaker role to firmly siding with the BOPs because what True Believers have offered isn’t enough now that the tide has turned against air and auto travel due to rising gas prices. On the debate front, the extreme positions represented by True Believers (unlimited subsidies for Amtrak) and anti-transit libertarians (rail is 19th century technology) pollute the true issues on passenger rail’s future.



I see divisions within the rail community to be more generational than ideological or philosophical. Many True Believers went through the dark days where the Class Is cut routes and let their equipment deteriorate. I was born between the Carter Administration cuts and the passage of Staggers and most BOPs are in the 25-45 age range. This is more or less the demographic that is the most entrepreneurial and, therefore, more willing to envision a world that has multiple operators. We aren’t willing to have a perpetual pledge drive mentality. Instead, we want to evaluate areas where Amtrak has failed to utilize because most people in the rail community fail to realize that passenger service is a business first.


Proposed Solutions

Recent solutions have ranged from privatizing Amtrak to breaking it up into a few pieces to handing all rail service back to the Class I railroads. There was an article in the March issue of Progressive Railroading that highlighted competition in the transit sector. The writer pointed out that only Amtrak and Herzog used to win contracts all the time but other companies have now stepped up to bid for commuter rail, light rail and streetcar services.

In addition to the five that I proposed last summer, here are several other options that others have proposed:

Nationalize all the railroads to split up infrastructure and operations. Rail infrastructure would stay in public hands but there’d be brand new private Class I railroads who would pay track fees and run the trains. A bidding process would be in place and would include Amtrak
• Use the German model of controlled competition and let the states use other operators for certain intrastate/intraregional routes (usually less than 250 miles long) while Amtrak holds on to Regional HSR (250-750 miles long) corridors. The states would be financially protected for the short-distance routes
• Have separate operators based on regions or states
• Make Amtrak a private nonprofit (the Korean Model) or a for profit organization (failed effort by the Bush 43 Administration)
• Break up Amtrak into several regions
• Separate Amtrak’s long-distance operations from its corridors (Note: All breakup options were opposed by the rail unions in 2002 and still are today)


Regional and shortline railroads across the country are either operating passenger trains or in the process of launching passenger service. It may seem impossible for the major railroads to relaunch passenger service or tolerate non-Amtrak operators on their lines but it isn’t. All that’s needed is a better set of liability enforcement guidelines, which in their current state, will be a bigger obstacle than Tea Partiers.


Companies like Herzog, Veolia and Keolis have mostly limited their interest to municipal transit for now, but how long will it be before these agencies decide to expand into the world of intercity rail? Given the recent news, I’d say such a move has already started. Veolia was one of eight teams that sought to operate the doomed Florida High Speed Rail project. Also, a new group representing these operators has formed. There is the potential for Congress to step up to the plate and enforce PRIIA guidelines on competition.


My Personal Plan

What I’d like to see is a combination of several of the aforementioned options. First, separating infrastructure and operations like the British would be in the best interest of the railroads because they would no longer have to pay for track improvements, only fees to access the tracks. Instead, a track maintenance organization operated by either the FRA or the USDOT will oversee the conditions of tracks and bridges and take appropriate action if something is out of the ordinary.

Second, I would like to see the federal government give the seven major railroads a subsidy or grant to operate passenger service. Out of all of the alternatives to the status quo, returning all passenger services to the Class Is--while not the worst thing--would prove to be the most problematic. As a result, they will be forced to get back into the game whether that means the feds start enforcing PRIIA guidelines or if the smaller railroads shame them into doing so. In giving these railroads financial guarantees and obligating them to operate passenger routes means that the private sector would once again be involved at all three levels. These moves automatically eliminate the Association of American Railroads’ Amtrak-only stance, which is a major roadblock to non-Amtrak passenger service.

Once we have a track maintenance organization, the government would set guidelines. The big railroads would operate the overnight routes and would have a consortium to handle routes that are on multiple railroads so passengers don’t have to change trains despite staying on the same route. Can anyone say Orbitz for train travel or a railroad version of HotWire? This kind of streamlining will make it very easy for train travelers to use multiple operators. Long-distance routes must have at least three trains each way so riders can plan accordingly while more popular routes should have at least four roundtrips. More long-haul routes or even enhanced passenger service will complement and relieve saturation on the other routes. On setting guidelines, the current liability requirements will have to be scrapped in favor of something that is much more sensible. This means that it’ll be essential that the railroads aren’t paying costs for track maintenance. The historic Ski Train was killed off in 2009 when new owner Iowa Pacific Holdings balked at paying Amtrak $200 million in liability insurance because the latter claimed that the 56-mile route between Denver and Winter Park resembled a commuter operation rather than an excursion. Amtrak has also used the liability issue to either delay agreements with commuter rail projects or pass on bidding for such routes altogether.


The bidding process would resemble this:

• Host railroads contract specialty rail routes out to foreign operators, independent passenger operators and cruises/tourist destinations via a PPP
• Host railroads (solo and via a consortium) and Amtrak would be eligible to bid on long-distance routes
• Amtrak, foreign operators, and independent operators would be eligible for Express and Regional HSR routes
• For Emerging HSR routes, Amtrak and independent operators would be able to bid on routes that are between 250 and 749 miles long. Any route with a distance less than 250 miles long would go to independent operators while states would be given financial support for these routes from the FRA via subsidies
• Corridors would be divided into 10 regions—Northeast, Southeast, Florida, Gulf Coast/South Central, Texas, Southwest, California/Nevada, Northwest, Rockies, Midwest
• Outside of the Northeast, the number of assigned operators would range from two to seven and will change based on ridership and demand. Class II and III railroads would not count against a region’s given allotment because they enacted passenger service on their own. Neither would any private company like the Triangle Railroad Holding Company since it doesn’t want any government funding. The Northeast may remain an Amtrak-only zone in exchange for the carrier giving up several routes and corridors in other parts of the country

I would keep Amtrak in the mix because certain regions will want to keep it as their carrier, but there will be major tweaks in a future of multiple operators. My proposal involves Amtrak being the operator of a certain number of long-distance routes as a way of fulfilling its national requirement even as it becomes more of an NEC organization. This move would allow Amtrak to thrive, not just survive as it has since the dreary 1970s. The new roster would be composed of the Carolinian (because NC is paying for that route), the Cardinal (since it’s congressionally mandated), all Silver Service routes, the combined Texas Eagle/Sunset Limited route, the new San Antonio-New Orleans route, California Zephyr, and Coast Starlight. Amtrak would keep all of its current equipment and be given the opportunity to add service along existing routes (an example would be Silver Service routes being complemented with additional frequencies that run counter to the Silver Meteor and Star).


Some people would get upset if another railroad operates a route that is currently run by Amtrak and hires nonunion employees. My plan is simple and would primarily apply to areas that are historically hostile to unions: Allow union members to relocate to an area that is served by Amtrak or another unionized railroad if the route in question is selected by a nonunion organization.


Historic stations in major cities must play a role in the future of passenger rail. It has been two decades since Grand Central Terminal last saw intercity service. If things go to plan, Housatonic may serve the facility in five years. Special themed trains to Canada and the Midwest should complement the Class III railroad at GCT. Speaking of the Midwest, among several things that left me underwhelmed is that the MWHSR is relying too much on Union Station in Chicago. Last spring, I chastised a plan for a standalone HSR station just a few blocks away from Union Station because it would become just as overcrowded as the current Amtrak station. As a matter of fact, I am still disappointed that MWHSR has failed to take advantage of utilizing the city’s other three stations other than combining Ogilvie Transportation Center with Union Station. My guess is that the organization has likely written in Amtrak as the operator of every non-Express HSR route. Personally, Amtrak should keep all of its services at Union Station while other railroads should operate trains out of LaSalle Street Station, Millennium Station, and the OTC. Those three stations could also host themed rail travel. Long-distance routes operated by a host or in a partnership with the host and another operator would be the only non-Amtrak intercity routes handled out of Union Station.

Conclusion

The endgame is that just about everybody who cares about rail travel realizes one thing: The status quo is a failure! The current way of doing things cannot be allowed to continue because America will be harmed by falling further behind. Several problems must be worked out in order for train travel to move forward. Forcing certain elements of PRIIA to introduce competition, goading the Class I railroads back into the people-carrying business, and liability guidelines that won’t force other railroads to go bankrupt are the main three things that must happen. Many True Believers fail to realize that railroads are businesses first.


President Obama is right in the sense that China should not have some of the fastest trains in the world while America stagnates or worse. However, only five areas of the country have earned the right to build trains that are up to par with the Asians and Europeans or within striking distance. Before the entire nation turns on train travel, it is best to reevaluate the passenger rail policy of America. Doing so means that the daytime (formerly known as medium-distance routes) and overnight route network must be vastly improved from what it is today. Reopening shuttered markets will add ridership. Allowing special types of passenger services will provide the public with something other than just speed: options. If we are to build a national high speed network, we have to realize that it will come in bits and pieces like the Interstate Highway System and that it will be a few more presidents before something more presentable is fully embraced by Beltway politicians.


This brings back to the question raised in this post’s title: Should America start over? I say no because what’s really needed is a genuine reform of a system that is run by the feds and needs more than one operator. The 40 year experiment has lived its purpose. What we need today is federal funding for infrastructure and services for certain routes but private operators running most of the trains. This doesn’t mean that Amtrak should be abolished. Far from it, I just want the company to focus on its strengths while following the rules per the 1971 mandate to be a national system rather than a system of disjointed corridors while paying lip service to the overnights.

Monday, April 25, 2011

Tackling the Headlines 10

May Railfan & Railroad article on the Amtrak holdouts
The latest issue of the magazine looked at three of the four major railroads that did not hand their trains over to Amtrak on April 1, 1971. Southern, the Rio Grande, and Georgia were all discussed (the only one that wasn't discussed happened to be the one railroad that was going broke [Rock Island]). The thing that interested me the most was that the Georgia Railroad was the last carrier to operate mixed trains (Southern eventually gave up on its mixed trains in Virginia later on in the '70s).


The magazine is definitely worth a read given that this week marks 28 years after both the Rio Grande and the GARR gave up carrying people. It's just a shame that the Class Is' speaking head shot down the possibility of mixed trains being revived on the Diane Rehm Show earlier this year when a caller brought it up (go to 10:33:48 and 10:34:24 of the transcript). If the big boy railroads aren't even willing to consider mixed trains, then it will be up to their regional and shortline counterparts to lead the way and show just how much of a successful business model carrying people can potentially be.



Iowa Pacific looks east
I just stumbled upon this after reading a Railfan & Railroad article on the issue at hand and I'm astonished at how this group of tiny railroads can continue adding service so methodically. The company has spent much of its 10 years providing freight and passenger service out west. The trains will run between Saratoga Springs and North Creek in New York and connections to Amtrak will be possible at Saratoga Springs for regular passenger service. The new Class III owner also plans to add excursion runs to Gore Mountain in the form of a ski train. Amazing, just amazing!

What's that going on in Connecticut?
New London's mayor wants to reinstate train service between the city and Brattleboro, VT by upgrading the tracks. Ever since the overnight Montrealer was replaced by the daytime Vermonter in the spring of 1995, that area has not had any train service. Instead, the Washington-St. Albans route branches off the Northeast Corridor route 51 miles to the west in New Haven and stops in Springfield, MA instead of Norwich. Regional leaders have been trying to shush him up.

Mayor Martin Olsen wants to boost tourism in southeastern CT and sees a bright future in rail given that his proposal would also serve Storrs, home to the University of Connecticut. I say, good for him because it only takes one renegade to get a good idea going. The article brought up the possibility of either track owner New England Central Railroad or another operator running the Central Corridor Rail Line. NECR and its owner Rail America are open to the idea as the possibility of additional passenger service from upgrades would also improve NECR's freight business. Both of the proposals in NY and CT would actually complement--not compete with--Amtrak, which is something that will make certain railfans relax.

Big things happening in Virginia
While President Obama is having trouble finding support for a $53 billion Infrastructure Bank, down the road in Richmond, Governor Bob McDonnell just signed a bill that will provide $4 billion to fund roads, rail and transit in the next three years.

Perhaps, the way to get an infrastructure bank going is at the state level. Once enough states have protection for various projects, Washington can step in and help the states with anything enormous like the nationwide high speed rail system that so many want.

Wednesday, April 20, 2011

Tackling the Headlines 9

The GOP just won't stop with its anti-rail stance
Just when I though it was safe came this news from here in NC and this one from MO. First, the NC House decided that since it couldn't block the federal stimulus funds to upgrade the Piedmont route and implement SEHSR service it wants to have veto power to stop the state from spending more than $5 million annually on operating and maintenance costs in the future.

Second, a committee in the Missouri legislature decided not to honor Governor Jay Nixon's vision to receive $1 billion in federal money to not only upgrade the existing St. Louis-Kansas City line but to build an entirely new line for Express service. The move would mean that the state wouldn't spend the money if the Obama Administration gave it part of Florida's grant.

The moves are sheer madness and really sets the Republicans to be the party of highways and oil. In NC's case, the GOP can now take its talking points from an anti-transit, pro-highway think tank called the John Locke Foundation. This now means that people who actually take trains will have to tell these unenlightened lawmakers the benefits of rail.

2011: A bad year for high speed rail
The year is not even half over and one can easily sum up 2011 to be a horrible year for high speed rail. Even before the year began, two governors-in-waiting had already declared their intent to return stimulus money to the feds in favor of roads. Then, Rick Scott used an anti-rail think tank's study to kill the high speed project in Florida two months ago. Now, we find out that in order to avoid a government shutdown, the Senate and President Obama allowed the House to eliminate HSR funding for the rest of this fiscal year, which ends on June 30.

Who's to say that future funding won't be next? If the White House is willing to sacrifice HSR instead of following up on its pledge that it's something essential for America's future, then the country as a whole must reexamine how relevant 150-200 mph trains are when there has been no expansion in "slow" overnight trains in decades even though people have been using Amtrak in the last few years. My opinion is that HSR should be frozen--that is, fast train service should be limited to five regions--while the long-distance network has to be rebuilt, with or without Amtrak.

Rick Scott's caught fibbing
Speaking of the Florida governor, Scott admitted last week that he misquoted the amount the state had spent on its now scuttled HSR project.

Of course, it's of no comfort now to people who had anticipated the fast train. Even though the governor blames the error on miscommunication with the state's DOT, one can only hope he is not as intellectually dishonest with SunRail as Ohio's John Kasich who repeated the 39 mph lie when in truth the 3C train was really going to travel at 79 mph.

Tuesday, April 12, 2011

Tackling the Headlines 8

Bad rail bill derailed in NC
On Friday, a bill that would have prohibited North Carolina from receiving $422 million in stimulus funds was withdrawn. The bill was horrible from the beginning and deserved to die.

More info on Norfolk Southern-FRA negotiations
I may have jumped the gun on singing the Class I's praises because at the last minute it wanted the NCDOT not to penalize it for future delays to passenger trains. The state and feds responded by stating that NS would lose funding for planning its Crescent Corridor between Alabama and Pennsylvania. On that front, the railroad got what it deserved because NC is one of the few places that has actually planned its rail service in advance and stands to reap rewards soon.

High speed mischief in China
These days, fast train advocates are astounded over how the world's most populous nation is producing HSR at an ultra rapid pace while America continues to be stuck in neutral. However, they'd be wise to cool their jets a bit because of recent setbacks. Two months ago, the government fired its rail minister after it was discovered that he was taking money while he was handing out HSR contracts. Also, several rail lines were discovered to have been constructed poorly. Now, this article pretty much points out that the fast trains have a dark side--class division. The writer saw well-off Chinese traveling on the white bullet trains while their poorer counterparts travel on green trains that were cramped, extremely slow, and hadn't been updated in ages. My take is that while China's scenario is extreme, Florida would have easily resembled it had that state's Supreme Court not killed the FLHSR project because as long as it was a Tampa-Orlando project, only the well-to-do and tourists would have ridden the 84-mile train line. It would have been the glamour of the fast train versus Floridians taking an Amtrak train with aging Amfleet and Heritage components that may or not be late--a point the media would have picked up on to bash any train service that does not resemble the European definition of high speed rail.

CSX chief comes out swinging against HSR
In New York, CSX CEO Michael Ward said that he can't be part of Obama's HSR plan because his company "can't make money hauling passengers." The focus is on a dispute the railroad has with the state of New York over how fast trains will be between Albany and Buffalo. The state wants trains to go up 110 mph, upgrading Empire Service to Regional status but the freight carrier wants a 90 mph cap, claiming that faster Amtrak trains will force CSX trains to slow down. A second or third track should be built, but at the same time, the state should try to buy passenger-only ROW where it'd be possible to develop a parallel route for faster trains.

HSR funding and government shutdowns
Congress decided to reduce funding for high speed rail as part of the budget battle that almost resulted in a government shutdown.. If the president isn't committed to HSR as he stated two months ago, then, it's time to scrap European style rail (Express HSR) and focus on improving conventional rail (Regional and Emerging HSR) by adding more frequencies on popular lines that already exist and reviving other routes that haven't seen service in years or decades.

Saturday, April 2, 2011

A Rational Passenger Rail Policy Before a National HSR Network

Intro
“…[R]ailfans could contribute much expert knowledge, based on the maxim ‘What man has done, man can do.’ But first their goals have to be realistic. Universal high speed rail is not one of them.”



I remember retired Metro North engineer Olaf Olsen uttering the above quote in 1999 regarding a realistic rail policy. Back then, he praised advocates in Northern New England for reviving Boston-Maine service but he was miffed at the idea of high speed rail in small towns with limited transportation options, being tourist trains, and serving shacks disguised as stations.

Let's Have a Little Logic Here
As the years have gone by, I just shake my head every time a region with infrequent rail service jumps on the fast train bandwagon. The more I think about it, the more I tend to agree with him. It’s laughable for Colorado to talk about HSR when the state sees a total of four trains daily. The state’s leaders should be trying to provide more roundtrips between Denver and Salt Lake City as well as a conventional speed Denver-Albuquerque route via Pueblo and Trinidad. And don’t even get me started on the Gulf Coast Corridor. When the Sunset Limited is upgraded to daily status and it has a complementary route, then talk to me about Gulf Coast HSR.

Some railfans have also made the push for a nationwide HSR system. It’s the wrong approach that is the result of the Asians and Europeans running laps around America with bullet trains while Amtrak operates with antiquated equipment that it can’t wait to get rid of. Now, I’m not opposed to a nationwide network of high speed rail per se, but we in the rail community have to look before we leap. In order to have a national network of fast trains, we must improve the skeletal rail system Amtrak has now. William Lind has a point about the negative effect the push for nationwide HSR has had on conventional rail travel.

In order to have a productive rail system, we need more long-distance routes. If a heavily traveled segment of an overnight route has the ridership, then corridor service will result. Overnight trains should have at least one or two other roundtrips along its route (the URPA plan is an example of this), and corridors will relieve overcrowding and serve more local destinations. Once the latter has been implemented, then high speed service planning should take place, leading to true high speed service. The corridors would remain in place as regional trains since the fast trains would make even fewer stops within the given region than the long-distance trains.

Last year, I proposed an interstate passenger rail system. This would mean that heavily traveled routes and any intercity segments that Amtrak shuttered will be preserved as America’s Rail Highways. This means that some routes would follow Gil Carmichael’s Interstate II vision where passenger trains would operate on double and triple tracked rights of way while other routes would run on dedicated passenger-only ROWs. This post from the Midwest HSR blog is an idea of what a rail highway could look like.

In an era where there will be multiple operators, stations need to be upgraded, so get rid of the Amshacks! Seriously, there is no excuse in this day and age for a train station to look like a city bus shelter or worse.

Who Really Deserves HSR?

The only areas that can logically support HSR are the Northeast, Southeast (D.C to Hampton Roads/Charlotte only), Midwest, California and the Northwest. A caveat is that funding for the Empire and Keystone routes would be given special consideration in Amtrak’s budget. Every other region not listed would start out at the 79 mph level and then build up.

I’d rather have a limited number of regions with true HSR instead of the scramble currently going on where everybody is demanding 150 mph service or bust while true connections to corridors remain scarce. JR Central is free to develop an Express route between Houston and Dallas while the private Triangle Railroad Holding Company can plan the Texas Triangle, but if Texas DOT officials get in the rail game, they would have to plan their service as Emerging HSR routes.

Onward to the Future...At Last
Once enough corridors have been upgraded to Regional status, then a national HSR network will be developed. Since passenger trains will be on their own tracks along the busiest routes, the transition will be relatively easy. These operators will then build special tracks for Express HSR routes. For corridors that share tracks with freights, the operating entity will build its own tracks to keep up.

When it comes to ownership, either the FRA or the USDOT would own the tracks of the passenger-only rail highways. Federal ownership would serve two purposes. First, it would guarantee that someone will maintain the tracks at all times. So, when there is an infrastructure issue, the governing body would fix the problem rather than a company only pays lip service to faulty materials due to Wall Street peer pressure or another company that may find repairing tracks and bridges prohibitively expensive. Second, as long as there are multiple operators using these rail highways, compatibility and ownership issues will arise. Putting the feds in charge means that no operator will have an unfair advantage on the tracks.