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 Post subject: Re: Delaware and Hudson Alco C628 in Mexico for possible sal
PostPosted: Fri Mar 01, 2019 10:40 am 

Joined: Tue Jul 05, 2011 1:18 am
Posts: 198
Scranton Yard wrote:

2. What if you then break down the prime mover into larger subassemblies and ship it as repair/replacement parts?


From my experiences within the automotive world, this is a bad idea. Federal import laws for vehicles dictate nothing under 25 years old can come into the country without having a proper EPA and Federal Safety Standard check. Regardless of this, people have tried everything from disassembling cars to titling them as other cars to circumvent these laws.

When the Federal government eventually (and they do eventually) catch up with these cars, the cars are destroyed. Now, I'm not saying that this will be the case with the Alco C628 if repatriated, but it is a possibility. Anybody up for the task needs to be aware that all of their i's must be dotted and it's must be crossed for this kind of operation.

Perhaps the groups that repatriated 2 Alco PA units can shed some more light on the process.


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 Post subject: Re: Delaware and Hudson Alco C628 in Mexico for possible sal
PostPosted: Fri Mar 01, 2019 8:38 pm 
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Joined: Sun Jun 27, 2010 12:24 am
Posts: 298
Location: H2O-town, CT
I think the way I'm understanding some of this is that if you wanted to import the locomotive it would be far easier to pull the prime mover out down there and LEAVE it there. Just import the loco as a shell with trucks, which isn't far from what it is already.


No way would I attempt to try to bring the prime mover back, it likely isn't worth it either by it's overall condition. Find a RTO one here.


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 Post subject: Re: Delaware and Hudson Alco C628 in Mexico for possible sal
PostPosted: Fri Mar 01, 2019 11:12 pm 

Joined: Wed Feb 02, 2011 9:40 pm
Posts: 841
cood101 wrote:
Scranton Yard wrote:

2. What if you then break down the prime mover into larger subassemblies and ship it as repair/replacement parts?


From my experiences within the automotive world, this is a bad idea. Federal import laws for vehicles dictate nothing under 25 years old can come into the country without having a proper EPA and Federal Safety Standard check. Regardless of this, people have tried everything from disassembling cars to titling them as other cars to circumvent these laws.

When the Federal government eventually (and they do eventually) catch up with these cars, the cars are destroyed. Now, I'm not saying that this will be the case with the Alco C628 if repatriated, but it is a possibility. Anybody up for the task needs to be aware that all of their i's must be dotted and it's must be crossed for this kind of operation.

Perhaps the groups that repatriated 2 Alco PA units can shed some more light on the process.


The one McCormack got did not have a prime mover in it. Nor a generator, trucks, traction motors, wiring, cabling, radiators, etc.


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 Post subject: Re: Delaware and Hudson Alco C628 in Mexico for possible sal
PostPosted: Sat Mar 02, 2019 12:52 am 

Joined: Mon Aug 18, 2008 11:48 pm
Posts: 126
Location: Watchung, NJ
Good evening all,

In response to those who asked questions above, I wanted to give everyone a little more information regarding the issue.

The main EPA regulations which deal with locomotive emission regulations are found in 40 C.F.R. § 1033 and 40 C.F.R. § 1068 respectively.

The critical Federal regulation everyone needs to be aware of is 40 C.F.R. § 1033.601

While I could have simply provided a link to the regulation cited above, I want to discuss this particular regulation with everyone, so I am reproducing the entire regulation below verbatim. I have added the bold highlighting so as to bring your attention to these important sections of the regulation.
_________________________________________________________

40 CFR § 1033.601 states:

Locomotive manufacturer/remanufacturers, as well as owners and operators of locomotives subject to the requirements of this part, and all other persons, must observe the provisions of this part, the requirements and prohibitions in 40 CFR part 1068, and the provisions of the Clean Air Act. The provisions of 40 CFR part 1068 apply for locomotives as specified in that part, except as otherwise specified in this section.

(a) Meaning of terms. When used in 40 CFR part 1068, apply meanings for specific terms as follows:

(1) “Manufacturer” means manufacturer and/or remanufacturer.

(2) “Date of manufacture” means date of original manufacture for freshly manufactured locomotives and the date on which a remanufacture is completed for remanufactured engines.

(b) Engine rebuilding. The provisions of 40 CFR 1068.120 do not apply when remanufacturing locomotives under a certificate of conformity issued under this part.

(c) Exemptions. (1) The exemption provisions of 40 CFR 1068.240 (i.e., exemptions for replacement engines) do not apply for domestic or imported locomotives. (Note: You may introduce into commerce freshly manufactured replacement engines under this part, provided the locomotives into which they are installed are covered by a certificate of conformity.)

(2) The exemption provisions of 40 CFR 1068.250 and 1068.255 (i.e., exemptions for hardship relief) do not apply for domestic or imported locomotives. See §1033.620 for provisions related to hardship relief.

(3) The exemption provisions of 40 CFR 1068.261 (i.e., exemptions for delegated assembly) do not apply for domestic or imported locomotives, except as specified in §1033.630.

(4) The provisions for importing engines and equipment under the identical configuration exemption of 40 CFR 1068.315(i) do not apply for locomotives.

(5) The provisions for importing engines and equipment under the ancient engine exemption of 40 CFR 1068.315(j) do not apply for locomotives.

(d) SEAs, defect reporting, and recall. The provisions of 40 CFR part 1068, subpart E (i.e., SEA provisions) do not apply for locomotives. Except as noted in this paragraph (d), the provisions of 40 CFR part 1068, subpart F, apply to certificate holders for locomotives as specified for manufacturers in that part.

(1) When there are multiple persons meeting the definition of manufacturer or remanufacturer, each person meeting the definition of manufacturer or remanufacturer must comply with the requirements of 40 CFR part 1068, subpart F, as needed so that the certificate holder can fulfill its obligations under those subparts.

(2) The defect investigation requirements of 40 CFR 1068.501(a)(5), (b)(1) and (b)(2) do not apply for locomotives. Instead, use good engineering judgment to investigate emission-related defects consistent with normal locomotive industry practice for investigating defects. You are not required to track parts shipments as indicators of possible defects.

(e) Introduction into commerce. The placement of a new locomotive or new locomotive engine back into service following remanufacturing is a violation of 40 CFR 1068.101(a)(1), unless it has a valid certificate of conformity for its model year and the required label.

(f) Multi-fuel locomotives. Subpart C of this part describes how to test and certify dual-fuel and flexible-fuel locomotives. Some multi-fuel locomotives may not fit either of those defined terms. For such locomotives, we will determine whether it is most appropriate to treat them as single-fuel locomotives, dual-fuel locomotives, or flexible-fuel locomotives based on the range of possible and expected fuel mixtures. For example, a locomotive might burn natural gas but initiate combustion with a pilot injection of diesel fuel. If the locomotive is designed to operate with a single fueling algorithm (i.e., fueling rates are fixed at a given engine speed and load condition), we would generally treat it as a single-fuel locomotive, In this context, the combination of diesel fuel and natural gas would be its own fuel type. If the locomotive is designed to also operate on diesel fuel alone, we would generally treat it as a dual-fuel locomotive. If the locomotive is designed to operate on varying mixtures of the two fuels, we would generally treat it as a flexible-fuel locomotive. To the extent that requirements vary for the different fuels or fuel mixtures, we may apply the more stringent requirements.

___________________________________________________________

The reason the above quoted regulation is so critical to know, and important to comprehend, is that the language contained within this regulation effectively wipes out regulations which might otherwise seem reasonable relief for importing an older prime mover back into the United States. All the "reasonable" exemptions for non conforming engines are simply not permitted for locomotives.

The end result of this quirky regulation is that any diesel engine contained within an imported locomotive will be essentially held to the same standard as a "new" prime mover under the current regulations.

In working with Mr. Jahn, and consulting many others experts around the country, we have reached the conclusion that the Obama Administration purposefully inserted language into the regulation which insures that any imported diesel engine contained in locomotives must meet the current (stringent) EPA standards. (The current regulations were updated in 2008, 2011, and 2016.) It should be noted that the EPA currently considers any imported engine to be "new" when it first arrives in the United States. They do not care if the engine was actually built in the US previously - 5, 20, or more - years ago.

If it is an imported engine, it is "new" as of the date it arrives - Period.

For two years now a group of engine experts, regulatory practitioners, attorneys and (yes) Congressmen have been looking at this issue. While there has been some progress made to resolving this moronic issue, the politics behind granting a single exemption for a number of US-built prime movers has kept my own project tied up in regulatory red tape for two plus years now. 4 historic locomotives that could have been saved recently went to scrap as a direct result of this impasse.

It should be noted that these regulatory changes are relatively recent events. If someone imported a locomotive into the United States prior to Dec of 2008, they did not face these unique challenges.

If any wants more information, feel free to ask away! I'll try to answer your questions the best I can.

_________________
Eric S. Strohmeyer
CNJ Rail Corporation


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 Post subject: Re: Delaware and Hudson Alco C628 in Mexico for possible sal
PostPosted: Sat Mar 02, 2019 1:46 am 

Joined: Mon Mar 20, 2017 5:26 pm
Posts: 632
Location: Pure Michigan
MEC_557 wrote:
I think the way I'm understanding some of this is that if you wanted to import the locomotive it would be far easier to pull the prime mover out down there and LEAVE it there. Just import the loco as a shell with trucks, which isn't far from what it is already..


I have PM'd the Yucatan museum on Facebook, but I am still awaiting a response.

Here is their phone number (I think): 52 55 1531 0816
I am not familiar with calling Mexico.


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 Post subject: Re: Delaware and Hudson Alco C628 in Mexico for possible sal
PostPosted: Sun Mar 03, 2019 12:06 pm 

Joined: Thu Jun 17, 2010 9:31 am
Posts: 728
I get the appeal, but with so many worthy projects in the US in dire need of funding it seems like a bridge too far...


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 Post subject: Re: Delaware and Hudson Alco C628 in Mexico for possible sal
PostPosted: Sun Mar 03, 2019 2:23 pm 

Joined: Tue May 26, 2009 12:42 am
Posts: 113
You might want to get some advice on what is involved in bringing a locomotive here from Mexico from the guys in Oregon who brought back the PAs


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 Post subject: Re: Delaware and Hudson Alco C628 in Mexico for possible sal
PostPosted: Sun Mar 03, 2019 9:33 pm 

Joined: Sun Aug 22, 2004 1:51 pm
Posts: 12150
Location: Somewhere east of Prescott, AZ along the old Santa Fe "Prescott & Eastern"
Whoever tries to get this doesn't (yet, at least) have the credibility and diplomacy of the Smithsonian Institution behind them, as did the PA project.


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 Post subject: Re: Delaware and Hudson Alco C628 in Mexico for possible sal
PostPosted: Mon Mar 04, 2019 12:40 am 

Joined: Tue Feb 05, 2019 3:48 pm
Posts: 5
NS 3322 wrote:
diningcartim wrote:
Delaware Lackawanna?


Someone on Facebook said that the current CMO does not want a C628. But that could be wrong.

Doesn't want them ,because he doesn't like that particular model. Something about the control system and the particular model of generator it's matched to. (Saw it on FB quite recently)


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 Post subject: Re: Delaware and Hudson Alco C628 in Mexico for possible sal
PostPosted: Mon Mar 04, 2019 9:47 am 

Joined: Sun Aug 22, 2004 11:26 am
Posts: 4773
Location: Maine
The C628 was not a particularly popular locomotive on any railroad. Most were phased out as soon as economically feasible. Apparently, they did not track well and lurched a great deal. I always liked their extreme length, ALCO Century design, and seeing them operate on the LV, D&H, and in helper service on Horseshoe Curve.
With only two remaining in existence, bringing one home with a place to ensure it is protected (under cover) still seems like a noble effort. Having one shipped off to become catfood cans would be a loss.

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"It's only impossible until it's done." -Nelson Mandela


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 Post subject: Re: Delaware and Hudson Alco C628 in Mexico for possible sal
PostPosted: Mon Mar 04, 2019 10:09 am 

Joined: Mon Mar 20, 2017 5:26 pm
Posts: 632
Location: Pure Michigan
I am not sure of the logistics (weight restrictions, shipping rates, customs process, etc) but there is a railroad car ferry (CG Railway) that runs between Coatzacoalcos, Veracruz and Mobile, Alabama. However, going "that route" would still require moving it a couple hundred miles by rail...

Image
Photo by Genesee & Wyoming


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 Post subject: Re: Delaware and Hudson Alco C628 in Mexico for possible sal
PostPosted: Mon Mar 04, 2019 12:34 pm 

Joined: Thu Jun 17, 2010 9:31 am
Posts: 728
I'd love to see the shell saved and retrofitted for something like the GE Hybrid.


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 Post subject: Re: Delaware and Hudson Alco C628 in Mexico for possible sal
PostPosted: Tue Mar 05, 2019 2:45 pm 

Joined: Wed Sep 02, 2015 11:34 pm
Posts: 270
The first step toward any repatriation effort would be to set up a non-profit with a talented group of individuals. You will need people who not only understand the language but understand legalities in both countries when approaching this transaction. Before any of that can be done however I would ask if anyone has had the opportunity to travel to Merida and see the #610 in person. It is crucial we know her exact condition which may or may not impact her ability to move on her own wheels. Likewise I do hope this project succeeds.

Cameron


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