Safety agencies' review broadly agrees with Transportation Research Board findings, but does not cite them
http://trn.trains.com/news/news-wire/2017/10/18-ecp-update
Brian Schmidt, Editor, Classic Trains magazine
Did the original mandate include a provision that converting tank cars to ECP brakes had to pass a cost/benefit analysis? If so, how did the actual numbers change from the time the mandate was imposed to this point in time?
Does the mandate automatically reinstate should the “benefit” rise to a certain threshold if oil traffic increases?
Suppose there had been no decrease in benefit, but there had been rising cost due to the compulsory purchase effect imposed on the market by the mandate itself. Would it then have been possible for the mandate to extinguish itself due to causing a cost increase in fulfilling the mandate, and thus causing a failure of the cost/benefit ratio?
Euclid Did the original mandate include a provision that converting tank cars to ECP brakes had to pass a cost/benefit analysis? If so, how did the actual numbers change from the time the mandate was imposed to this point in time? Does the mandate automatically reinstate should the “benefit” rise to a certain threshold if oil traffic increases? Suppose there had been no decrease in benefit, but there had been rising cost due to the compulsory purchase effect imposed on the market by the mandate itself. Would it then have been possible for the mandate to extinguish itself due to causing a cost increase in fulfilling the mandate, and thus causing a failure of the cost/benefit ratio?
There is an often ignored statutory mandate that major regulations provide more benefit than they cost. Since the regulators do the cost benefit analysis, they have a huge opportunity to over state benefits and under state costs. That they will do so is almost a given, and Oboma's regulatory minions did so willfully and gleefully.
What is interesting here is that the DOT got caught and now seems to be in the process of withdrawing the rule without admitting that they cooked the books. This is a man bites dog story, and I am glad to see it.
Mac McCulloch
Part of this, I think, is that the big "benefit" was supposed to be some inchoate interpretation of 'safety' -- which by interpolation from the Government's discussions have largely been co-addressed by things like degassing crude and improving track maintenance and inspection procedures. In my opinion the big failure on the part of the 'minions' was the assumption that the safety gains of ECP applied most significantly in emergency situations, which shows a pathetic understanding of the actual technology at best; that is now in the process of being debunked, perhaps with some face-saving "investigation" time, but it's really a foregone conclusion that for emergency braking situations there's little more than statistical advantage for ECP over 'top and tail' one-pipe application in emergency, and given the much greater safety improvements at lower nominal cost in other areas for HHFT traffic (and, by extension, for most PIH traffic either in special trains or general service) there is no particular 'safety' reason for implementing an ECP mandate.
And, no matter how insinuatingly the FRA et al. try to tout the 'operational advantages' of ECP as something the railroads will love once it's been forced on them... the only place the Government can 'mandate' ECP is on pure safety grounds.
Mac,
It does sort of sound like they are reaching for a conclusion as an excuse to cancel the mandate, and the excuse is the sudden failure of the cost/benefit analysis.
Assuming that DOT overstated the benefits and understated the cost, how did they "get caught," as you say? Was that due to the tank car/ecp tests failing to prove the claimed benefit?
EuclidDid the original mandate include a provision that converting tank cars to ECP brakes had to pass a cost/benefit analysis?
"We are having all these oil train fires! Do something!", said the public to their elected representatives. "We are having all the oil train fires! Do something!", Said Congress to the administration. "We are having all these oil train fires! Do something!" said the admin to the FRA.
The FRA thought for a bit. "We can't say there is no problem, regarless of what statistics say. That will only cause derision to rain down on our heads and get us fired. Okay. ECP braking. The industry has been edging there. It sounds good. It'll get everyone off our backs. When the RRs object, we'll do a study and show it works. Win-win. By the time they get installed, this "problem" will be off the front burner and we'll be off the hot seat. Win-win."
Except the study didn't show it worked.
-Don (Random stuff, mostly about trains - what else? http://blerfblog.blogspot.com/)
oltmannd Euclid Did the original mandate include a provision that converting tank cars to ECP brakes had to pass a cost/benefit analysis? "We are having all these oil train fires! Do something!", said the public to their elected representatives. "We are having all the oil train fires! Do something!", Said Congress to the administration. "We are having all these oil train fires! Do something!" said the admin to the FRA. The FRA thought for a bit. "We can't say there is no problem, regarless of what statistics say. That will only cause derision to rain down on our heads and get us fired. Okay. ECP braking. The industry has been edging there. It sounds good. It'll get everyone off our backs. When the RRs object, we'll do a study and show it works. Win-win. By the time they get installed, this "problem" will be off the front burner and we'll be off the hot seat. Win-win." Except the study didn't show it worked.
Euclid Did the original mandate include a provision that converting tank cars to ECP brakes had to pass a cost/benefit analysis?
Well it worked to some extent. To what extent did it have to work in order to fulfill what had been promised in the terms of the mandate? Was there some original condition that required ECP to prevent a certain number of derailed cars and punctures compared to the other braking methods?
According to the first post, DOT is saying that the cost/benefit ratio has failed due to the benefit falling due to a reduction of oil traffic, and not due to a reduction of ECP performance as would be indicated when you say the study showed ECP did not work.
In my opinion, the real "excuse" was initiating an ECP mandate on faulty (and perhaps verging on fraudulent) grounds, not in subsequently finding a face-saving reason to let the mandate drop.
As noted, the original 'cost/benefit analysis' involved "safety in the Blast Zone" as the principal benefit -- and as has been stated in previous Euclid posts and threads, it is difficult to overstate the perceived value of safety from large, luminous fireballs either to the public or its duly-elected representatives.
The first problem that came up was that, no particular surprise to engineers, the critical speed that produced significant puncturing, even in the most 'armored' tank-car design that made any economic sense, was remarkably low. (Part of this realization was the proposal to limit HHFTs to 40mph, which of course is still many mph too high...) So some method of dramatically getting way off a derailing train was necessary ... and ECP became the only 'magic bullet' whose promoters could provide nifty graphs of how much quicker and 'safer' a controlled brake application could be. Problem was, of course, that only about 5 minutes with the description that accompanies the nifty graphs at WABTEC or NYAB reveals that the 'quicker' and 'safer' don't apply in nearly equal measure to emergency brake applications; the 'magic bullet' turned out to be a bit like chemotherapy for malignant melanoma, very very expensive for basically zero statistically-significant improvement in any given practical incident.
And, meanwhile, the proximate cause of the fireballs was cured, rather early in the game, by the Government order to ensure degassing the crude at its source (which in my opinion should have been done long before even considering putting something like Eagle Ford or Bakken crude into tank cars), and the proximate cause of much, if not most, of the derailments was cured through better inspection and maintenance ... you haven't seen much incidence of catastrophic derailment of key trains recently, even in the relative absence of Bakken unit trains.
The pity in this whole predictable shenanigan is that ECP does represent meaningful improvement in many aspects of train handling. Just not anything particular the government can mandate or even influence.
Overmod In my opinion, the real "excuse" was initiating an ECP mandate on faulty (and perhaps verging on fraudulent) grounds, not in subsequently finding a face-saving reason to let the mandate drop. As noted, the original 'cost/benefit analysis' involved "safety in the Blast Zone" as the principal benefit -- and as has been stated in previous Euclid posts and threads, it is difficult to overstate the perceived value of safety from large, luminous fireballs either to the public or its duly-elected representatives. The first problem that came up was that, no particular surprise to engineers, the critical speed that produced significant puncturing, even in the most 'armored' tank-car design that made any economic sense, was remarkably low. (Part of this realization was the proposal to limit HHFTs to 40mph, which of course is still many mph too high...) So some method of dramatically getting way off a derailing train was necessary ... and ECP became the only 'magic bullet' whose promoters could provide nifty graphs of how much quicker and 'safer' a controlled brake application could be. Problem was, of course, that only about 5 minutes with the description that accompanies the nifty graphs at WABTEC or NYAB reveals that the 'quicker' and 'safer' don't apply in nearly equal measure to emergency brake applications; the 'magic bullet' turned out to be a bit like chemotherapy for malignant melanoma, very very expensive for basically zero statistically-significant improvement in any given practical incident. And, meanwhile, the proximate cause of the fireballs was cured, rather early in the game, by the Government order to ensure degassing the crude at its source (which in my opinion should have been done long before even considering putting something like Eagle Ford or Bakken crude into tank cars), and the proximate cause of much, if not most, of the derailments was cured through better inspection and maintenance ... you haven't seen much incidence of catastrophic derailment of key trains recently, even in the relative absence of Bakken unit trains. The pity in this whole predictable shenanigan is that ECP does represent meaningful improvement in many aspects of train handling. Just not anything particular the government can mandate or even influence.
I am referring to an "excuse" to get out of making a mandate that now seems less needed. And perhaps the excuse also is desired to mask a change of political will higher up in the organizations invovled.
But nobody ever claimed that ECP was truely a "magic bullet" in that it would prevent all oil train pileups, punctures, and fires. And while the stopping distance difference favors ECP far less in the "emergency" application than in a "service" application, there is still an advantage in favor of ECP in the "emergency" applicaiton. I would not conclude that the advantage of ECP in this reduction of damage during a derailment is statistically zero.
If anything the tests failed to prove what they set out to prove because the tests themselves were too inadequate to prove anything in meaninful quantities.
I think we should celebrate there is one less piece of "knee-jerk' legislation in the world.
EuclidWell it worked to some extent. To what extent did it have to work in order to fulfill what had been promised in the terms of the mandate? Was there some original condition that required ECP to prevent a certain number of derailed cars and punctures compared to the other braking methods? According to the first post, DOT is saying that the cost/benefit ratio has failed due to the benefit falling due to a reduction of oil traffic, and not due to a reduction of ECP performance as would be indicated when you say the study showed ECP did not work.
Simulation results showed a near meaningless reduction in cars derailed. That means it was not shown to work.
Euclid I would not conclude that the advantage of ECP in this reduction of damage during a derailment is statistically zero.
It has not been shown to be greater than zero, so no advantage that can be counted on, at least within the parameters of the study.
To proceed, you need a different study.
oltmannd Euclid I would not conclude that the advantage of ECP in this reduction of damage during a derailment is statistically zero. It has not been shown to be greater than zero, so no advantage that can be counted on, at least within the parameters of the study. To proceed, you need a different study.
What do you mean by the phases, "near meaningless" and "not greater than zero"? The tests showed that ECP resulted in fewer derailments than the other systems. How can fewer derailment be zero advantage?
Look up the Ford Pinto.
Ford determined that paying out claims as the results of poor design of the car (the gas tanks kept exploding) was cheaper than fixing the design flaw.
Carrying that forward to this discussion, it's cheaper to clean up the occasional derailment than it is to install ECP apparatus in all of the necessary rolling stock.
As long as cleaning up derailments is cheaper than installing ECP, there is no advantage to installing ECP. When either the cost of cleaning up derailments rises to the point of being more expensive than ECP, or the cost of ECP drops below the cost of cleaning up derailments, ECP will happen.
Note, too, that the number of derailments that would potentially be mitigated by ECP is a small percentage of total derailments, which will make it even harder for ECP to become economically viable.
Larry Resident Microferroequinologist (at least at my house) Everyone goes home; Safety begins with you My Opinion. Standard Disclaimers Apply. No Expiration Date Come ride the rails with me! There's one thing about humility - the moment you think you've got it, you've lost it...
tree68As long as cleaning up derailments is cheaper than installing ECP, there is no advantage to installing ECP.
You are referring to the amount of benefit not being more than the amount of cost, and therefore that cost/benefit advantage is zero. I understand that point. And that may very well be the case.
I am questioning the claims by some that ECP showed zero reduction in damage during derailments in the testing. As I understand the results, there was some reduction in the number of cars derailed, number of punctures, etc. Maybe it was a number deemed to be inadequate, but it was not zero.
tree68Note, too, that the number of derailments that would potentially be mitigated by ECP is a small percentage of total derailments,...
How do you arrive at that conclusion?
EuclidHow do you arrive at that conclusion?
Numerous discussions here. Not every derailment is a high-speed, slam-bang pile-up.
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