Jeffrey Scott Moore - Comments

I highly recommend redfining what railroad means in part 239. Although some passenger railroads also operate trollies, buses and other means of transportation, they also transferse larger entities such as Amtrak and should be treated the same. They travel through multiple states and large stretchs of remote areas. They travel the same rails as Amtrak at the same speeds and dispatched throught the same rules. Rather that base their definition on the items currnetly listed in the definiton below as to whether they are a commuter railroad, or not, passenger denisty should be the driving force for meeting the definition of a passenger railroad. I strongly recommend that commuter or short haul passenger service be removed. They all should meet the same standard right down to the first aid kits.