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                              May 27, 2020

       Christopher J. Eppel
       Chief Financial Officer
       FreightCar America, Inc.
       125 S. Wacker Drive, Suite 1500
       Chicago, Illinois 60606

                                                        Re: FreightCar America,
Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2019
                                                            Filed March 4,
2020, and as Amended April 6, 2020
                                                            Form 10-Q for the
Quarterly Period Ended March 31, 2020
                                                            Filed May 12, 2020
                                                            File No. 000-51237

       Dear Mr. Eppel:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments. In some of our comments, we
may ask you to
       provide us with information so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-Q for the Quarterly Period Ended March 31, 2020

       Item 2. Management's Discussion and Analysis of Financial Condition and
Results of Operations
       Results of Operations, page 20

   1.                                                   We note that your
revenue significantly declined by $65 million, or 92%, from $71
                                                        million for the three
months ended March 31, 2019 to $5 million for the three months
                                                        ended March 31, 2020.
You indicate this was due to the decrease in the number of
                                                        railcars delivered (11
versus 641 units) due to lower industry demand, which was partially
                                                        offset by a higher
average selling price for new railcars in 2020. We also note from your
                                                        earnings call that the
lower demand was due to the combination of timing and weakness in
                                                        the backlog, line
changeovers, and a loss of 8 production days at the end of the first
                                                        quarter related to the
Coronavirus. Revise your results of operations to provide qualitative
                                                        reasons as to why
demand was lower. To the extent possible, quantify how the differing
 Christopher J. Eppel
FreightCar America, Inc.
May 27, 2020
Page 2
         factors impacted the overall change in your results of operations.
Additionally, quantify
         how your expected deliveries are expected to ramp up through the year
to the extent
         possible to provide further insight into known trends and
uncertainties. We also note from
         your earnings call a withdrawal of the 2020 guidance for deliveries
and capital
         expenditures, and although no order cancellations, you are not
building any railcars that
         do not have a firm order behind them, and as the Mexico facility is
expected to begin
         production during the third quarter but not without a firm customer
order, please address
         how you expect deliveries to ramp up for the year. See Item 303 of
Regulation S-K and
         SEC Release No. 33-8350.

       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

      You may contact Beverly Singleton at (202) 551-3328 or Melissa Raminpour
at (202)
551-3379 with any questions.



FirstName LastNameChristopher J. Eppel                       Sincerely,
Comapany NameFreightCar America, Inc.
                                                             Division of
Corporation Finance
May 27, 2020 Page 2                                          Office of
Manufacturing
FirstName LastName