A&SV RR has announced that when filing FRA paperwork they discovered that they have an extra year of service left on Santa Fe 4-6-2 3415. It was originally believed that their 15 years had expired, but they will now be operating in 2023.

My question is how does this happen? Was something in Part 230 misinterpreted to make them start the count at the wrong point in time? Is this a discovery that could affect other steam operators? It seems inconceivable that an engine could accidentally be withdrawn early with another good year available but it apparently almost happened here.

My understanding after reading about it on another forum is that good record keeping of their not in service days gave them the extra time.

I read that too, but honestly it doesn't make sense to me. There are no credits for not in service days under part 230, only service days. You get 1472 service days or 15 years, whichever comes first. They only run a couple times a month for about half a year so there is no way they should have been up against the 1472 service days.

Is it possible that someone accidentally started counting the 15 years from when the first flue/tube was installed and did not take into account the one year grace period that is intended to give the owner/restorer sufficient time to complete the restoration in a manner that does not impact the fifteen year window for operation?

That crossed my mind as well and it’s been debated multiple times. Maybe A&SV now has the definitive answer? Whatever the case, I’m sure there is a lesson in this that can benefit others.

Yet another reason why Fear of Regulator Inspectors is not a good idea.

Every regulation inspector I've ever dealt with were absolutely happy to find you asking them for advice ------ as long as you were honest with them. They all were happy to help you thread the needle.

Brian Helfrich

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Didn't the FRA grant an extra year for Operators who did not operate their locomotive in 2020? I swear I thought I remember reading that the Heritage Rail Alliance had worked with the FRA to get that extension done as part of a COVID relief activity. I searched their website, RYPN, and Google but did not come up with that information - Perhaps I dreamed it. Anyway, if that is true and ASV didn't operate 3415 in 2020, then that could be another explanation of where the extra year came from.

I know nothing of this example. But I do believe you can "REQUEST" an extension of your flu time and that may be based on few service days? I know of a few locomotives that the request was made to FRA and am thinking it was a one year extension? This was in recent times.

Also believe that the old ICC used to allow for extensions on flue time and possibly scheduled boiler work. You were not guaranteed the "ok to proceed". But it was a thing. Always had a love affair with the AT&N #401/Woodward Iron Co #41 {now at AOS} and had heard she was scheduled for firebox work when donated to MC back in mid or early 1960s. There supposedly was a rear flue sheet all formed and ready to go in but was left behind. Someone here looked up the records and found she had already been granted an extension and the ICC denied putting off the work any longer. I often get my 2nd hand stories confused but this is how I remember it. Not to be confused with the truth. Regards, John.

Whatever the exact reason for our good fortune, this is good news and I thank BM765 for posting it here. You all might remember the last thread on this line ended with a couple of us predicting that they would be back in steam before too long --- this is one time I'm happy to say told ya so....

As a former FRA inspector, this is sometimes confusing as the regulation is sometimes misunderstood. From my understanding, all service days were counted and accurately reported. A small operation like this accrues only a minimal number of service days in 15 years. The confusion was the start of the 15 year clock. They were just off by a year, thinking the clock started when the tubes were installed, and didn’t realize it. Their ongoing communication with local FRA and others in the business helped them realize their misunderstanding of the regulation. If they had started the 15 year/1472 inspection, it would have not have been any kind of a safety issue or FRA non-compliance, just performing an inspection before it is required, that is all. This now allows them some more operating time to showcase the locomotive and raise money for the 15 year/1472 when it is due.

There are no longer any "out of service" days or "flue extensions" referenced in the regulations. Time runs out after 1472 service days or 15 years, whichever comes first. In some unusual cases, a owner/operator may petition FRA for a waiver to operate a little longer for specific locomotives under certain circumstances.

MD Ramsey - FRA Passenger Specialist, Steam Inspector (Ret).