A METRO April 11, 2017 Capital Metropolitan Transportation Authority 2910 East Fifth Street I Austin, Texas 78702 TEL 512.389. 7400 I FAX 512.369.6596 I capmetro.org Mr. Thomas Herrmann Director, Office of Techrtical Oversight Federal Railroad Administration 1200 New Jersey Avenue, SE Washington, DC 20590 RE: (a) Letter from T. Herrmann (FRA) to M. Clark (CMTA) dated Decemb er 20, 2016 (b) Letter from M. Clark (CMTA) to T. Herrmann dated March 30, 2017 Dear Mr. Herrmann: Capital Metropolitan Transportation Authority (CMTA) is requesting a second amendment to Docket Number FRA-2016-0126. In addition to the relief requested in the letter dated March 30, 2017, CMTA requests relief of compliance from the provisions listed below in Table 1 of Title 49 of the Code of Federal Regulations for Alternate Vehicle Technology Compliance Assessment for the four new G4 Railcars th at CMTA ha s purchased from Stadler Bussnang AG. Table 1: Alternate Vehicle Technology Compliance Assessment 49 CFR 238.203 Static End Strength 49 CFR 238.205 Anti-climbing Mechanism 49 CFR 238.207 Link between coupling mechanism and carbody 49 CFR 238.209 Forward end structure of locomotives, including cab cars and MU locomotives 49 CFR 238. 211 Collision Posts 49 CFR 238.213 Corner Posts 49 CFR 238.215 Rollov er strength 49 CFR 238.217 Si de Structure Integrity 49 CFR 238.219 Truck-to-carbody attachment 49 CFR 238.233 Interior fittings and surfaces Table 2, below, provides a list of Stadler documents that confirm that the Stadler G4 meets the ETF-1 requirements. Each Stadler Technical Report marked with the identifier (G2) is identica l to the report that was s ubmitted under the G2 process and addresses an aspect of the CMTA G4 vehicle that is identical to the OCTA G2 vehicle. Those teclmical reports marked with the id entifier (G4) were developed specifically for, and are unique to, the CMTA G4 vehicle. It was necessary to develop these new reports due to design Page 1of3
Transcript
A METRO
April 11, 2017
Capital Metropolitan Transportation Authority 2910 East Fifth Street I Austin, Texas 78702 TEL 512.389.7400 I FAX 512.369.6596 I capmetro.org
Mr. Thomas Herrmann Director, Office of Techrtical Oversight Federal Railroad Administration 1200 New Jersey Avenue, SE Washington, DC 20590
RE: (a) Letter from T. Herrmann (FRA) to M. Clark (CMTA) dated December 20, 2016 (b) Letter from M. Clark (CMTA) to T. Herrmann dated March 30, 2017
Dear Mr. Herrmann:
Capital Metropolitan Transportation Authority (CMTA) is requesting a second amendment to Docket Number FRA-2016-0126. In addition to the relief requested in the letter dated March 30, 2017, CMTA requests relief of compliance from the provisions listed below in Table 1 of Title 49 of the Code of Federal Regulations for Alternate Vehicle Technology Compliance Assessment for the four new G4 Railcars that CMTA has purchased from Stadler Bussnang AG.
49 CFR 238.203 Static End Strength 49 CFR 238.205 Anti-climbing Mechanism 49 CFR 238.207 Link between coupling mechanism and carbody 49 CFR 238.209 Forward end structure of locomotives, including cab cars and MU
Table 2, below, provides a list of Stadler documents that confirm that the Stadler G4 meets the ETF-1 requirements. Each Stadler Technical Report marked with the identifier (G2) is identical to the report that was submitted under the G2 process and addresses an aspect of the CMTA G4 vehicle that is identical to the OCTA G2 vehicle.
Those teclmical reports marked with the identifier (G4) were developed specifically for, and are unique to, the CMTA G4 vehicle. It was necessary to develop these new reports due to design
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modifications incorporated into the G4 design that were not incorporated into the G2 design, specifically the revisions to the C-car and the associated EPA Tier 4 enhancements.
Table 2: Stadler Technical Reports
ETF-1 Requirements Documentation Submittal
1. Collision with Stadler Technical Report AL_2173030: Collision with conventional equipment Conventional Equipment (G4)
2. OVI Stadler Technical Report AL_1287430: Occupant Volume Integrity (G2)
Model Validation Stadler Technical Report AL_1307346: Validation Report for Finite Element Modeling (G2) Stadler Technical Report AL_2199970a: GTW CMTA Mass
Mass Comparison Deviation -Influence on the Structural Analyses of the Cab Bodies
The Request for Waiver, Docket FRA-2016-0126, only pertains to the four new G4 vehicles CMTA has purchased, and does not affect any prior waivers issued to CMTA by the FRA.
If you have any questions or require additional information, please contact Brian Allan at 512-852-7258 or [email protected].
Sincerely,
Melvin Clark Vice President for Rail Operations
CC: Nathan Wallace, FRA
John Manutes, FRA
Gary Fairbanks, FRA
Attachments: (a) Letter from T. Herrmatm (FRA) to M. Clark (CMTA) dated December 20, 2016 (b) Letter from M. Clark (CMTA) to T. Herrmann dated March 30, 2017
BA:EO:BB:MC
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U.S. Department of Transportation
Federal Railroad Administration
DEC 2 0 2016 Mr. Melvin Clark Vice President Rail Operations Capital Metropolitan Transportation Authority 2910 East Fifth Street Austin, Texas 78702
Re: Docket Number FRA-2016-0126
Dear Mr. Clark:
1200 New Jersey Avenue, SE Washington, DC 20590
This reply shall serve as acknowledgement of the receipt of your request dated December 19 2016, received December 20, 2016. In this letter, the Capital Metropolitan Transportation Authority requested that the Federal Railroad Adminisn·ation (FRA) grant a waiver of compliance from certain provisions of 49 CFR Prut 229,231,238, request for waiver for foW' new vehicles CMTY has ordered.
FRA has created an electronic mailbox, FRA [email protected], to receive petitions for waivers and exemptions from railroad safety rules and regulations, applications to modify or discontinue railroad signal systems (block signal applications), and ce1tain special approvals. Please submit all railroad safety waiver and exemption requests, as well as block signal applications and special approval applications, to either FRA [email protected] or to FRA's Docket Clerk, in accordance with the existing requirements in Title 49 Code of Federal Regulations Part 211, Rules of Practice.
Your request has been assigned Docket Number FRA-2016-0126. All information contained in this and other dockets is available at www.regulations.gov.
Sincerely,
Thomas He1Tmann Director, Office of Technical Oversight
AME R Capital MetropoLitan Transportation Authority 2910 Eas t Fifth Stree t I Aus tin, Texas 78702 TEL 512.389.7400 I FAX 512.369.6596 I capmetro.org
March 30, 2017
Mr. Thomas Hermaim DiTector, Office of Teclrnical Oversight Federal Railroad Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590
Docket Nmnber FRA-2016-0126
Subject: Request for Relief and Alternate Vehicle Compliance Designation for Stadler GTW G4 Railcars 201, 202, 203 and 204
Reference: (a) Letter from M. Clark (CMTA) to R. Lauby (FRA) dated December 19, 2016 (b) Technical Criteria and Procedures for Evaluating the Crashworthiness and
Occupant Protection Performance of Alternatively Design Passenger Rail Equipment for Use jn Tier 1 Service Final Report dated October, 2011
Dear Mr. Hermann:
This letter supersedes the reference (a) letter.
The Capital Metropolitan Transportation Authority (CMTA) is petitioning the FRA to provide CMTA relief from certain portions of 49 CFR (200-299) in order to operate four new GTW G4 Railcai·s, 201, 201, 203 and 204 that CMTA has purchased from Stadler Bussnang AG. With the exception of the following ntles listed in Table 1: Base Waiver Compliance Assessment, the Stadler GTW G4 Railcars 201, 202, 203 and 204 are in compliance with the applicable parts of 49 CFR (200-299).
Table 1: Base Waiver Complian ce Assessment
49 CFR 229.47 ai1d 238.305 Emergency Brake Valve
49 CFR 229.71 Clearance Above Top of Rail 49 CPR 229.135(b)(4)(xvili) and (xix) Event Recorders 49 CFR 231.14(a)(2), (b)-(d), (f), (g), 238.229, and 238.230( d) Safety Appliances
