Railroad Rolling Stock Manufacturing (U.S.) — Industry Primer

NAICS 2022 code 336510. A Histometrics industry primer for public-market and private investors.

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1. Overview

Railroad rolling stock manufacturing is the business of building the equipment that runs on rails: freight cars (tank cars, covered hoppers, gondolas, boxcars, intermodal flatcars), locomotives, and passenger/transit cars, plus their major parts. "Rolling stock" is the industry term for anything with wheels that rides the track, as opposed to the track and signals themselves.

Why an investor cares: this is a deeply cyclical, capital-intensive manufacturing industry whose fortunes swing with freight volumes, commodity cycles, the age of the existing fleet, and interest rates. Orders can double or halve in a single year. The two largest U.S. builders have learned to smooth those swings by also owning and leasing the cars they make, which turns a lumpy build business into a steadier stream of lease income. That build-plus-lease model is the single most important thing to understand about how money is made here.

Ways in:

• Public markets — a handful of U.S.-listed pure-plays: The Greenbrier Companies (GBX), Trinity Industries (TRN), FreightCar America (RAIL), and the much larger locomotive-and-components maker Wabtec (WAB); plus railcar lessor GATX (GATX), which buys cars rather than builds them.
• Private markets — most of the supply chain is private: component giant Amsted Rail, locomotive builder Progress Rail (a Caterpillar company), tank-car lessor Union Tank Car (Berkshire Hathaway's Marmon), private-equity-owned fleets, and the U.S. plants of foreign passenger-train primes (Siemens, Alstom, Stadler, Hitachi Rail, Kawasaki).

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2. What it is and how it's structured

Scope (what NAICS 336510 covers). The U.S. Census definition includes establishments that (1) build or rebuild locomotives, frames and parts; (2) build railroad, street, and rapid-transit cars and car equipment for freight and passenger service; and (3) build track-maintenance machines such as rail layers, ballast distributors, and tampers.[1]

What it excludes (adjacent NAICS codes worth knowing):

• Mining rail cars → 333131 (Mining Machinery Manufacturing).[1]
• Railcar/locomotive repair, when done by railroads or transit agencies → 488210 (Support Activities for Rail Transportation); when done by independent shops → 811310 (Commercial & Industrial Machinery Repair).[1]
• Operating the railroads (moving freight and passengers) → 482 (Rail Transportation) — a separate, much larger industry.
• Railcar leasing → 532411 (Commercial Equipment Rental & Leasing). This matters: when Trinity or Greenbrier earns lease revenue on cars it built, that income is classified outside 336510, so the manufacturing statistics below understate what these companies actually earn.

Production model. Production is generally engineered-to-order batch or project manufacturing. A prime contractor designs to a railroad's, lessor's, or transit authority's specification; procures steel, wheels, axles, bearings, brakes, trucks, castings, electronics, and interiors; fabricates and welds the structure; applies coatings; installs systems; and completes testing, certification, and customer acceptance. Freight cars lend themselves to repeatable production lines, but plants must still switch among covered hoppers, gondolas, flats, boxcars, and pressure or non-pressure tank cars. Passenger vehicles are lower-volume and more customized, with long design, software-integration, and acceptance cycles.

Input economics. Inputs dominate freight-car economics. Trinity reports that externally purchased materials, parts, and coatings average more than 70% of the cost of most railcars, with the remainder largely direct labor and factory overhead.[2] Shortages or price moves in steel, wheels, brakes, side frames, bolsters, and bearings can disrupt output or compress margins.

Customer mix. Customers are not just railroads. Freight cars are frequently bought by leasing companies, banks, and other financial owners, or directly by chemical, agricultural, energy, and industrial shippers. FreightCar America reported that financial institutions represented 78% of its 2025 sales and shippers another 16%.[3] Passenger customers are principally government-controlled transit authorities, Amtrak, and state-supported intercity programs.

Ownership mix. Predominantly private-sector for-profit manufacturing. Three segments behave very differently:

• Freight cars — a domestic, cyclical, near-duopoly (Trinity + Greenbrier) plus smaller builders.
• Locomotives — concentrated in Wabtec (which absorbed GE's locomotive business in 2019) and Progress Rail/EMD (Caterpillar); a replacement-and-modernization business more than a growth one.
• Passenger/transit cars — dominated by the U.S. assembly plants of foreign primes (Siemens Mobility, Alstom, Stadler, Hitachi Rail, Kawasaki), driven by government transit funding and "Buy America" rules. Alstom describes its Hornell, New York facility as the country's largest passenger-rail manufacturing site.[4]

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3. How big it is

Our federal ground-truth figures for NAICS 336510:

Concentration (Economic Census 2022): the top 4 firms make 54.9% of revenue, top 8 72.5%, top 20 89%, top 50 96.8%; the Herfindahl-Hirschman Index (HHI, a standard concentration gauge where higher = more concentrated) is 1,017.[5]

Reading the concentration numbers carefully. An HHI near 1,000 looks only "moderately concentrated" — but that is because 336510 lumps together freight cars, locomotives, transit cars, track machines, and parts. The establishment count substantially overstates the number of prime manufacturers: in its freight-car rulemaking, FRA stated that only six manufacturers produced newly built freight railcars, with three qualifying as small entities — versus 220 establishments classified in the broad NAICS. FRA explicitly concluded that the NAICS establishment distribution was not a reliable description of new-car manufacturers.[8] Within the freight-car sub-segment specifically, the market is far tighter: Trinity and Greenbrier together are estimated to build roughly 80% of new North American freight cars, with Greenbrier alone around 40% share.[9][10]

Undercount / measurement caveats. This is a well-measured private manufacturing industry — it is not undercounted the way government-dominated or micro-operator industries are. But two facts distort the U.S. federal picture:

1. Much production happens in Mexico. Both Greenbrier and Trinity operate large Mexican assembly plants, so U.S. Census establishment and shipment counts capture only their U.S.-located work and understate the true footprint of U.S.-headquartered builders.
2. Leasing income is invisible here. The ~$12.0 billion in receipts counts new-equipment sales; the recurring lease revenue these same firms earn on owned fleets is booked under a different NAICS code (see Section 2). The economics of the industry are bigger and steadier than the manufacturing line alone suggests.

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4. The investable universe

Publicly traded pure-plays are few — this is a small, concentrated field.

Note on Wabtec: it is the biggest U.S.-listed name in rail equipment, but most of its revenue is locomotives, aftermarket parts and services, and transit systems — only part of it is "rolling stock manufacturing" in the narrow sense. Roughly 58% of its Freight-segment sales are recurring aftermarket (parts, overhauls, modernizations), which the company says is generally higher-margin and less cyclical than original equipment because maintenance remains necessary in a downturn.[14]

Major private and foreign owners (not investable as U.S. stocks):

• Progress Rail (Caterpillar) — locomotives; steward of the EMD (Electro-Motive Diesel) brand.
• Amsted Rail — private; dominant maker of wheels, bearings, couplers, and truck (bogie) castings — the components inside almost every North American freight car.
• Union Tank Car — tank-car builder/lessor owned by Berkshire Hathaway's Marmon Holdings.
• National Steel Car — Canadian private freight-car manufacturer.
• Siemens Mobility (Sacramento, CA), Alstom (Hornell, NY), Stadler (Salt Lake City, UT), Hitachi Rail, Kawasaki — passenger/transit assembly for Amtrak and transit agencies.[4][16]
• CRRC — Chinese state-owned giant, effectively locked out of new U.S. federal-funded transit orders (see Section 7).
• Private-equity / infrastructure capital — owns much of the leasing and components base (e.g., Brookfield's rail-leasing joint venture with GATX; ITE Management's ownership of former American Railcar assets).

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5. How the money works

Owners make money three ways, and the mix determines how cyclical the returns are.

1. Building and selling cars (the cyclical core). New-build gross margins are thin and steel-driven. A freight car is mostly fabricated steel and purchased castings (externally purchased materials, parts, and coatings average more than 70% of cost),[2] so profitability hinges on plant capacity utilization (keeping lines full), steel and component input costs, and disciplined pricing. Watch two operating metrics:

• Deliveries (units shipped) — drives revenue.
• Backlog (firm orders not yet built) — the industry's clearest forward indicator. A big backlog means factories are loaded for quarters or years; a shrinking one signals a downturn ahead. Backlog swings hard: Railway Supply Institute data show North American freight-car backlog contracted from 34,273 cars at the start of 2025 to 23,431 at year-end 2025.[17]

Reported margins demonstrate why a single "industry margin" is misleading. Trinity's Rail Products Group earned a 5.2% operating margin in 2025, when deliveries fell sharply and weighted manufacturing capacity utilization was about 50%.[2] Greenbrier's fiscal-2025 Manufacturing segment generated $2.99 billion of revenue with a 14.5% segment margin and 10.9% operating margin while delivering 20,400 railcars; management attributed improvement despite lower deliveries to operating efficiencies.[11] FreightCar America reported 2025 revenue of $501 million with a gross margin of approximately 14.6%.[3] Profitability improves when manufacturers enter a recovery with lean capacity, secured steel and component supply, escalation protection, and a favorable mix.

2. Leasing the cars they build (the stabilizer). Trinity and Greenbrier retain a share of production on their own balance sheets and lease it out. This converts a one-time sale into years of contracted rent and adds a portfolio of appreciating (or depreciating) hard assets. The key metrics here are fleet utilization (share of owned cars on lease and earning — Trinity's runs near 97%),[12] lease rates (often tracked via a Lease Price Index, LPI), and renewal success. Leasing income is higher-margin and far steadier than building, and it is why the two leaders trade partly like finance companies — though leasing introduces interest-rate, leverage, residual-value, and utilization risk. GATX is the pure expression of this model — it owns cars and lives entirely off lease economics and residual values.

3. Parts, service, and modernization (the recurring annuity). The North American fleet is huge and long-lived, so aftermarket parts, repairs, retrofits, and locomotive modernizations throw off steady, higher-margin revenue. Wabtec is the prime example — its Freight segment had nearly 24,600 locomotives in its installed base, with 58% of segment sales from aftermarket work in 2025.[14]

The cycle itself. New-car demand is fundamentally replacement demand plus a thin layer of growth. The North American revenue-earning freight-car fleet totaled about 1.63 million cars at the end of 2025, with an average age of 20.4 years. Approximately 69,000 new cars entered the fleet over the preceding two years, with 90% of equipment added in 2025 carrying the higher 286,000-pound gross rail load rating.[18] Because cars last 30–50 years, replacement need is lumpy: it depends on scrappage economics (scrap-steel prices vs. the cost of a new car), regulatory retirements, and which commodity segments are growing. That lumpiness is the source of the industry's famous boom-bust order pattern. RSI data show North American orders falling from 60,734 cars in 2022 to 20,361 in 2025; deliveries of 31,205 in 2025 exceeded orders, drawing down backlog.[17]

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6. What drives demand

• Freight volumes / carloadings. More goods on rail eventually means more (and newer) cars needed; a freight recession stalls orders. Traffic growth does not translate mechanically into new orders — better car utilization, longer trains, conversions, and the return of stored equipment can satisfy additional volume before customers buy new assets.
• Fleet age and the replacement cycle. With average age ~20 years and a large cohort of aging boxcars and hoppers, replacement is the baseline demand engine.[18]
• Commodity mix. Segments move independently: coal-car demand is in secular decline; tank and covered-hopper demand tracks energy, chemicals, plastics pellets, grain, and sand. A single commodity's cycle can swing a builder's mix. USDA reported that the six Class I railroads originated 1.3 million grain carloads in 2024, 8% more than in 2023 but 1% below the prior three-year average.[19]
• Regulation-driven retrofits. Safety rules can force fleet-wide upgrades — the DOT-117 tank-car standard (Section 7) created a multi-year wave of new-builds and retrofits.
• Interest rates. Leasing is a spread business (cost of capital vs. lease rate), and railroads/lessors finance car purchases — so rates shape both demand and lessor profitability.
• Steel and scrap prices. High steel raises new-car prices (dampening orders) but high scrap prices accelerate retirements of old cars (spurring replacement). The two pull in opposite directions.
• Passenger/transit funding. Federal money — the Infrastructure Investment and Jobs Act (IIJA), Federal Transit Administration (FTA) grants, and Amtrak fleet renewal — drives transit-car and passenger-locomotive orders, largely independent of the freight cycle. IIJA established $300 million annually for competitive rail-vehicle replacement in fiscal years 2022 through 2026, alongside much larger State of Good Repair formula funding.[20] In February 2024, FTA announced $631 million for 300 replacement railcars in Chicago, Baltimore, and Philadelphia.[21]

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7. Regulation

Rolling stock is one of the more regulated manufactured products in the U.S., across three overlapping regimes:

• Federal Railroad Administration (FRA). Sets and enforces safety standards for locomotives, cars, and equipment; passenger equipment must be FRA-certified to operate.[16] In December 2024, FRA adopted freight-car rules restricting sensitive technology and certain components from countries of concern and state-owned enterprises.[22]
• Pipeline and Hazardous Materials Safety Administration (PHMSA). Governs tank cars that carry hazardous materials. After the 2013 Lac-Mégantic oil-train disaster, PHMSA finalized the DOT-117 standard (thicker shells, head shields, thermal jackets, better valves) for high-hazard flammable trains; new tank cars built after Oct. 1, 2015 must meet it, and older DOT-111/CPC-1232 cars had to be retrofitted or retired on a schedule.[23][24] This rule was, in effect, an industry-wide demand event for builders and retrofitters.
• Environmental Protection Agency (EPA). Tier 4 standards apply to newly manufactured locomotives from 2015 onward and also regulate emissions-related remanufacturing, supporting engineering and modernization work.[25]
• Association of American Railroads (AAR) — industry self-regulation. The AAR writes the interchange rules that let any car run on any railroad, and its Tank Car Committee sets safety-critical specs (PHMSA has delegated certain tank-car authority to it).[26] Builders must also meet AAR M-1003 quality certification and register cars in the Umler equipment database. In practice, an uncertified car simply cannot enter interchange service — a powerful non-governmental gate.

Trade and procurement rules shape the passenger/transit side:

• "Buy America" (FTA/FRA) requires domestic content (generally more than 70% of component cost) and U.S. final assembly for federally funded transit and passenger equipment; procurements also require pre-award and post-delivery audits — the reason Siemens, Alstom, Stadler, Hitachi Rail, and Kawasaki built U.S. plants.[16][27]
• NDAA Section 7613 (FY2020) bars federal transit funds from buying rolling stock made by Chinese state-owned enterprises, effectively shutting China's CRRC out of new U.S. transit orders after it had won subway/commuter contracts in Boston, Chicago, Los Angeles, and Philadelphia.[28][29]
• Steel tariffs and cross-border (Mexico) trade policy matter directly, given steel-intensive cars and heavy U.S. reliance on Mexican assembly.

The National Transportation Safety Board (NTSB) investigates accidents and its recommendations frequently seed the next round of FRA/PHMSA equipment rules.

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8. Competitive dynamics and consolidation

Freight cars — a duopoly. Trinity and Greenbrier together build roughly 80% of new North American freight cars, with FreightCar America a distant third, National Steel Car (Canada), and a few private builders (Progress Rail, Union Tank Car) filling niches.[9][10] Competition turns on price, plant utilization, lease-financing muscle, and the ability to offer a full "build-and-lease" package. Scale and a captive leasing arm are the moats; FreightCar America's historical weakness has been the lack of a large leasing portfolio.[9]

Locomotives — concentrated and mature. Wabtec (post-GE) and Progress Rail/EMD dominate; demand is largely replacement, rebuilds, and modernizations rather than growth, so recurring services revenue is the prize.

Components — a hidden concentration. Amsted Rail (private) supplies wheels, bearings, couplers, and truck castings across nearly the whole fleet — a critical, under-appreciated chokepoint.

Consolidation trend. The industry has steadily consolidated: Wabtec absorbed GE Transportation in 2019; and in leasing, GATX and Brookfield's joint venture acquired Wells Fargo Rail (closed Jan. 2026), lifting GATX's share of the lessor-owned fleet from roughly 13% to about 25%.[15] Expect continued consolidation, because scale lowers capital costs and steadies the cycle.

Passenger/transit — foreign primes, local plants. Siemens, Alstom, Stadler, Hitachi Rail, and Kawasaki compete for transit-agency and Amtrak orders from U.S. factories built to satisfy Buy America; CRRC's exclusion removed the low-price disruptor.[16][28]

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9. Risks

• Severe cyclicality. Orders and backlog can swing dramatically year-over-year (orders fell from 60,734 cars in 2022 to 20,361 in 2025).[17] Earnings for pure builders are volatile and hard to forecast.
• Commodity and energy-transition exposure. Coal-car demand is in structural decline; a builder over-indexed to any one commodity can be whipsawed.
• Thin new-build margins and input-cost inflation. Steel and casting costs can quickly erode already-slim building margins. Tariffs, steel-price volatility, castings capacity, bearing or brake shortages, energy costs, and cross-border disruption can all affect delivery and margin.
• Interest-rate sensitivity. Rising rates raise financing costs for buyers and squeeze lessor spreads; falling rates do the reverse.
• Long asset life = lumpy replacement. Cars lasting 30–50 years mean demand arrives in unpredictable waves rather than a smooth annuity.[18]
• Trade and tariff risk. Heavy reliance on Mexican assembly and imported/domestic steel makes the industry acutely exposed to tariff and cross-border policy shifts. Mexican production creates USMCA, tariff, currency, and border risks.
• Customer concentration. A small number of Class I railroads and large lessors buy most cars; losing a major program hurts.
• Labor risk. Experienced welders, electricians, engineers, inspectors, and production supervisors are critical. Downcycles encourage layoffs; the next ramp can then produce shortages, overtime, temporary-worker expense, and quality problems.
• Regulatory whipsaw. Retrofit mandates create demand but also impose costs and can strand older equipment. New rules restricting components from countries of concern may protect qualified North American supply but can reduce sourcing flexibility and raise compliance expense.[22]
• Substitution. Trucks compete for shorter-haul and time-sensitive freight, pipelines for liquids, and barges for bulk commodities. Customers can rebuild, rebody, or convert existing cars instead of ordering new ones.

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10. How to invest and the outlook

Public-market routes.

• Builders: Greenbrier (GBX) and Trinity (TRN) are the two liquid ways to own the freight-car cycle plus a leasing kicker; both pay dividends but carry cyclical earnings. FreightCar America (RAIL) is a smaller, higher-beta turnaround play with greater dependence on its Mexican facility and a smaller backlog.
• Diversified/defensive: Wabtec (WAB) offers rail exposure with a large recurring aftermarket and transit business — less cyclical, more of a compounder.
• The lessor angle: GATX (GATX) is the cleanest way to own the fleet economics (lease rates, utilization, residual values) without factory risk — it behaves partly like a specialty-finance company.

Because earnings are cyclical, valuation is best judged across a full cycle (through-cycle margins, backlog trend, lease-fleet utilization, and net asset value of owned fleets) rather than on a single year's multiple.

Private-market routes. Most of the value chain is private: railcar leasing fleets (attractive to infrastructure and private-equity capital for their contracted, inflation-linked cash flows and hard-asset backing — see Brookfield/GATX), component makers like Amsted Rail, tank-car specialists (Union Tank Car under Berkshire/Marmon), and the U.S. operations of foreign passenger-train primes. The critical diligence differs by asset type: lease portfolios require car-level age, type, lessee credit, maintenance liability, utilization, and residual-value analysis; suppliers require qualification status and customer concentration; manufacturers require cycle-normalized capacity utilization, backlog quality, price-adjustment protection, and warranty history.

Near-term drivers to watch (forward-looking).

• Replacement demand from an aging (~20-year-average) fleet is the structural floor under orders.[18]
• Freight-volume recovery and the order/backlog trend — the leading indicator of the next up-leg after 2024–25 softness.[17]
• Interest rates and steel prices — the two swing factors for both new-build margins and leasing spreads.
• Passenger/transit tailwind from IIJA funding and Amtrak fleet renewal, largely decoupled from the freight cycle.[20][21]
• Tariff and Mexico policy — a genuine wild card given the industry's cross-border manufacturing base.
• Further consolidation, especially in leasing, as scale players chase lower capital costs.[15]
• Alternative propulsion. Battery, hybrid, and hydrogen locomotives are investable development areas, but adoption rates remain uncertain; it would be premature to model rapid displacement of the diesel freight fleet.

The reasonable base case is a mature, consolidating, cyclical industry: modest secular growth anchored by replacement demand and a growing, steadier leasing/aftermarket layer, punctuated by sharp order cycles that reward investors who buy the down-leg and respect the volatility.

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Sources

1. U.S. Census Bureau, "NAICS 336510 — Railroad Rolling Stock Manufacturing (definition and exclusions)," North American Industry Classification System 2022. https://www.census.gov/naics/?details=336510&input=336510&year=2022
2. Trinity Industries, Inc., Form 10-K (FY2025: input cost mix; Rail Products segment operating margin and utilization), U.S. SEC, 2026. https://www.sec.gov/Archives/edgar/data/99780/000009978026000014/trn-20251231.htm
3. FreightCar America, Inc., Form 10-K (FY2025: revenue $501M; customer mix; deliveries 4,125; backlog 1,926 cars at $137M), U.S. SEC, 2026. https://www.sec.gov/Archives/edgar/data/1320854/000119312526098668/rail-20251231.htm
4. Alstom, "Alstom in the United States" (Hornell, NY facility), 2025. https://www.alstom.com/alstom-united-states
5. U.S. Census Bureau, 2022 Economic Census, Concentration ratios and receipts, NAICS 336510, 2022. https://data.census.gov/
6. U.S. Census Bureau, County Business Patterns (CBP), NAICS 336510: establishments, employment, payroll, 2023. https://www.census.gov/programs-surveys/cbp.html
7. U.S. Small Business Administration, "Table of Size Standards," NAICS 336510 (1,500 employees), 2023. https://www.sba.gov/document/support-table-size-standards
8. Federal Railroad Administration, "Freight Car Safety Standards — Regulatory Impact Analysis" (six new-build manufacturers vs. 220+ NAICS establishments), 2023. https://downloads.regulations.gov/FRA-2023-0021-0001/content.pdf
9. Brightpath Associates, "A Deep Dive into Leading Railroad Equipment Manufacturers in the US" (freight-car duopoly; FreightCar America positioning), 2025. https://brightpathassociates.com/backbone-of-rail-a-deep-dive-into-leading-railroad-equipment-manufacturers-in-the-us/
10. FinancialContent / Finterra, "Tracking the Tracks: A Deep Dive into The Greenbrier Companies (GBX)" (~40% share), 2026. https://markets.financialcontent.com/stocks/article/finterra-2026-4-7-tracking-the-tracks-a-deep-dive-into-the-greenbrier-companies-gbx
11. The Greenbrier Companies, Inc., Form 10-K (FY2025: Manufacturing segment $2.99B revenue, 14.5% segment margin, 10.9% operating margin, 20,400 deliveries), U.S. SEC, 2025. https://www.sec.gov/Archives/edgar/data/923120/000119312525253612/gbx-20250831.htm
12. Technavio / PR Newswire, "Rolling Stock Market in North America" (Trinity lease-fleet utilization ~97%), 2024. https://www.prnewswire.com/news-releases/rolling-stock-market-in-north-america-in-railroads-industrymarket-impact-and-analysistechnavio-301336590.html
13. RailMarket, "FreightCar America produces 4,125 wagons in 2025," 2026. https://railmarket.com/news/rolling-stock/51851-freightcar-america-delivers-4-125-wagons-in-2025
14. Wabtec Corporation, Form 10-K (FY2025: Freight segment $8.04B, 19.5% operating margin, ~24,600 locomotives installed base, 58% aftermarket), U.S. SEC, 2026. https://www.sec.gov/Archives/edgar/data/943452/000162828026008067/wab-20251231.htm
15. OpenPR, "Railcar Leasing Market" (GATX/Brookfield acquisition of Wells Fargo Rail; lessor-fleet share ~13%→~25%, closed Jan. 2026), 2026. https://www.openpr.com/news/3539650/railcar-leasing-market-size-gaining-off-to-a-good-start
16. CNBC, "How Siemens and Alstom are preparing for a passenger rail boom in the U.S." (FRA certification, Buy America, U.S. plants, Amtrak orders), 2023. https://www.cnbc.com/2023/07/11/siemens-and-alstom-anticipate-passenger-rail-boom-in-the-us.html
17. Railway Supply Institute, "ARCI Summary — Fourth Quarter 2025" (orders 20,361; deliveries 31,205; backlog 23,431), 2026. https://www.rsiweb.org/wp-content/uploads/2026/01/ARCI-Summary-4th-Quarter-2025-1.pdf
18. Railway Age, "Tanks Up, Hoppers Down" (Railinc: revenue-earning fleet ~1.63M cars end-2025; avg age 20.4 years; 69,000 new cars added over prior two years; 90% at 286K lb rating), 2026. https://www.railwayage.com/mechanical/freight-cars/tanks-up-hoppers-down/
19. U.S. Department of Agriculture, "Grain Transportation Report" (Class I railroads originated 1.3M grain carloads in 2024), Jan. 2025. https://www.ams.usda.gov/sites/default/files/media/GTR01232025.pdf
20. Federal Transit Administration, "State of Good Repair and Rail Vehicle Replacement Program — Fact Sheet" ($300M annually FY2022–2026), 2022. https://www.transit.dot.gov/funding/grants/fact-sheet-state-good-repair-and-rail-vehicle-replacement-program
21. Federal Transit Administration, "Biden-Harris Administration Announces Nearly $631 Million in Grants" (300 replacement railcars for Chicago, Baltimore, Philadelphia), Feb. 2024. https://www.transit.dot.gov/about/news/biden-harris-administration-announces-nearly-631-million-grants-help-transit-agencies
22. Federal Railroad Administration, "FRA Issues Final Rule to Strengthen Freight Car Safety Standards" (Dec. 2024 rule restricting technology from countries of concern), 2024. https://railroads.fra.dot.gov/about-fra/communications/newsroom/press-releases/fra-issues-final-rule-strengthen-freight-car-0
23. Wikipedia, "DOT-117 tank car" (specifications; Lac-Mégantic origin; retrofit timeline), 2025. https://en.wikipedia.org/wiki/DOT-117_tank_car
24. U.S. Department of Transportation, "Rule Summary: Enhanced Tank Car Standards and Operational Controls for High-Hazard Flammable Trains," 2015. https://www.transportation.gov/mission/safety/rail-rule-summary
25. U.S. Environmental Protection Agency, "Emission Standards for Locomotives and Locomotive Engines — Fact Sheet" (Tier 4), 2008. https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100500B.pdf
26. Association of American Railroads, "Hazmat Tank Car Regulations" (AAR Tank Car Committee; delegated authority; CPC-1232), 2025. https://www.aar.org/issue/hazmat-tank-car-regulations/
27. Federal Transit Administration, "Buy America Requirements," 2025. https://www.transit.dot.gov/buyamerica
28. The Eno Center for Transportation, "Final Defense Bill Bans New Purchases of Mass Transit Vehicles from Chinese Companies" (NDAA FY2020 Section 7613), 2019. https://enotrans.org/article/final-defense-bill-bans-new-purchases-of-mass-transit-vehicles-from-chinese-companies-after-2-year-delay/
29. Railway Age, "RSI: No Federal Funds for Chinese-Sourced Railcars" (Railway Supply Institute on Section 7613; CRRC U.S. transit awards), 2019. https://www.railwayage.com/regulatory/rsi-no-federal-funds-for-chinese-sourced-railcars/