Please clarify the proposed change to Section 213.3. The revision reads "Similarly, this exclusion does not apply to track over which a general system railroad operates, even if that track is located within a plant railroad." This appears to mean that any track inside a plant over which a general system carrier operates becomes part of the general system and, thus, subject to the TSS. If so, this is a major departure from the existing rule. Presently, industry track over which a general system railroad operates (to serve the customer) must be maintained to satisfy the safety concerns of the railroad (preferably to FRA Class 1 minimum), but does not fall under the TSS. Is it the proposed case that all industry track upon which a general system railroad operates will now be covered under the TSS, even simple side tracks? This would be a dramatic expansion of coverage. How can FRA expect industry track owners to comply with TSS requirements?
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This is comment on Proposed Rule
Track Safety Standards; Improving Rail Integrity
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