schlimm http://hosted2.ap.org/APDEFAULT/f70471f764144b2fab526d39972d37b3/Article_2015-02-22-US--Oil%20Trains-Safety/id-302da298369f4215850e884a3895e211
Fuel-hauling trains could derail at 10 a year
Predicts an average of 10 major derailments a year over the next 20 years - 15 in 2015 down to 5 in 2034, toal of 207. Total damages: $4.5 Billion.
Up to 10 "higher consequence events" with greater damage and possible fatalities.
Worst case scenario: 200 deaths, $6 Billion in damage.
Query: Correlation with actual experience since then ?
- Paul North.
Paul_D_North_Jr schlimm http://hosted2.ap.org/APDEFAULT/f70471f764144b2fab526d39972d37b3/Article_2015-02-22-US--Oil%20Trains-Safety/id-302da298369f4215850e884a3895e211 Summary: AP article dated-lined Feb. 22, 2015 reporting on a previously unpublished DOT study from July 2014: Fuel-hauling trains could derail at 10 a year Predicts an average of 10 major derailments a year over the next 20 years - 15 in 2015 down to 5 in 2034, toal of 207. Total damages: $4.5 Billion. Up to 10 "higher consequence events" with greater damage and possible fatalities. Worst case scenario: 200 deaths, $6 Billion in damage. Query: Correlation with actual experience since then ? - Paul North.
Summary: AP article dated-lined Feb. 22, 2015 reporting on a previously unpublished DOT study from July 2014:
Article is the biggest pile of steaming cow droppings I have seen in a while.
Never too old to have a happy childhood!
The shipping of Canadian tar sand bitumen is made more hazardous by what is added to it to make it flowable
http://www.railwayage.com/index.php/safety/why-bitumen-isnt-necessarily-safer-than-bakken.html?channel=60
You can see how this is going to play out. The Canadian government is going to require its railroads to carry a billion dollar in insurance to transport oil. Hopefully thier will be no further serious incidents or this will increase.
Like I always contended, regulations will not be coming from the tree huggers, but from the silent majority in the middle. All the stakeholder's, the producers, shippers, railroads and end user need to continue to search for solutions.
Euclid It is interesting to look back over the last year as this oil by rail controversy has evolved. A year ago, there was confidence that the problem could be solved. Lac Megantic was called an outlier, thus not part of any trend. Just one other fiery oil train wreck came next, but still no trend. Fred Frailey calculated a prediction of future oil train wrecks indicating that more oil train wrecks were sure to follow soon. The industry assured the public that the problem was the DOT-111 tank car not being strong enough to withstand derailments. They assured the public that they would solve that problem by replacing the 111 car with a stronger car that would not breach in a derailment. They told us about stronger steel, more steel, better valves, and better valve protection. I said that I doubted that the improvements would solve the problem, and suggested a whole new generation of unit train for hauling oil. Of course, there was no way that the industry would consider such an option. One part of my suggestion was ECP brakes, and the railroads have since come out swinging against the notion of using ECP brakes. At the same time, there was great promise in the possibility of taking the volatility out of the oil before it was shipped by rail. I read every comment about that possibility and never could come to any conclusion about the feasibility. The topic seems to defy technical consensus. I conclude that the so called “degassing” of Bakken oil will not happen soon, if it is even possible. Now, concurrent with the West Virginia oil train wreck, there was another one in Quebec that has slipped largely under the news media radar. On the face, it was not particularly newsworthy, but at a deeper level, the earth moved in the oil by rail debate. The Quebec wreck proved that the diluted bitumen from the Canadian tar sands is just as volatile and explosive as Bakken crude. So the challenge to de-gas crude for shipping by rail seems more unlikely than ever at this point. Almost, at the same time, the industry seems to have acknowledged that stronger tank cars will not solve the problem. This is a truly spectacular and discrediting reversal. We were told that the industry would reroute the oil trains to protect the public, and slow them down in sensitive areas. Yet slowing down and rerouting the trains seems to be impractical and unlikely. Has any oil traffic been slowed down or rerouted so far? We were told that track inspection and maintenance would be stepped up. Every railroader knows that no amount of track and equipment inspection and maintenance will assure freedom from derailments. If they are not caused from track and equipment problems, they can still be caused by train collisions, train handling, and train slack dynamics. There is simply no low-hanging fruit in solving the oil train problem by better maintenance. Oil trains will continue to derail, and every time, there is the potential for a blockbuster event that will suddenly force the problem to solved by a regulation banning oil by rail. So, now we are left with just one ray of hope. That is to discover some heretofore unknown cause for oil trail derailments. I would say that this is an incredible longshot, but it is all that is left. There is no statistical indication that oil trains derail any more frequently than other types of freight trains. But since we don’t have much history on the topic, there is a possibility that the cause of oil train problem lurks in the dynamics of loaded tank cars in unit trains. Some have suggested the oil sloshing might be involved. Perhaps the relatively higher center of gravity in loaded tank cars plays a role. Maybe the shapeless nature of oil, combined with a higher center of gravity should be looked at.
Good summary, but too many players and posters are in denial and/or pointing fingers. A good solution has yet to be found. Possibly there is none acceptable within the parameters of competing economics and safety.
C&NW, CA&E, MILW, CGW and IC fan
schlimm Euclid It is interesting to look back over the last year as this oil by rail controversy has evolved. A year ago, there was confidence that the problem could be solved. Lac Megantic was called an outlier, thus not part of any trend. Just one other fiery oil train wreck came next, but still no trend. Fred Frailey calculated a prediction of future oil train wrecks indicating that more oil train wrecks were sure to follow soon. The industry assured the public that the problem was the DOT-111 tank car not being strong enough to withstand derailments. They assured the public that they would solve that problem by replacing the 111 car with a stronger car that would not breach in a derailment. They told us about stronger steel, more steel, better valves, and better valve protection. I said that I doubted that the improvements would solve the problem, and suggested a whole new generation of unit train for hauling oil. Of course, there was no way that the industry would consider such an option. One part of my suggestion was ECP brakes, and the railroads have since come out swinging against the notion of using ECP brakes. At the same time, there was great promise in the possibility of taking the volatility out of the oil before it was shipped by rail. I read every comment about that possibility and never could come to any conclusion about the feasibility. The topic seems to defy technical consensus. I conclude that the so called “degassing” of Bakken oil will not happen soon, if it is even possible. Now, concurrent with the West Virginia oil train wreck, there was another one in Quebec that has slipped largely under the news media radar. On the face, it was not particularly newsworthy, but at a deeper level, the earth moved in the oil by rail debate. The Quebec wreck proved that the diluted bitumen from the Canadian tar sands is just as volatile and explosive as Bakken crude. So the challenge to de-gas crude for shipping by rail seems more unlikely than ever at this point. Almost, at the same time, the industry seems to have acknowledged that stronger tank cars will not solve the problem. This is a truly spectacular and discrediting reversal. We were told that the industry would reroute the oil trains to protect the public, and slow them down in sensitive areas. Yet slowing down and rerouting the trains seems to be impractical and unlikely. Has any oil traffic been slowed down or rerouted so far? We were told that track inspection and maintenance would be stepped up. Every railroader knows that no amount of track and equipment inspection and maintenance will assure freedom from derailments. If they are not caused from track and equipment problems, they can still be caused by train collisions, train handling, and train slack dynamics. There is simply no low-hanging fruit in solving the oil train problem by better maintenance. Oil trains will continue to derail, and every time, there is the potential for a blockbuster event that will suddenly force the problem to solved by a regulation banning oil by rail. So, now we are left with just one ray of hope. That is to discover some heretofore unknown cause for oil trail derailments. I would say that this is an incredible longshot, but it is all that is left. There is no statistical indication that oil trains derail any more frequently than other types of freight trains. But since we don’t have much history on the topic, there is a possibility that the cause of oil train problem lurks in the dynamics of loaded tank cars in unit trains. Some have suggested the oil sloshing might be involved. Perhaps the relatively higher center of gravity in loaded tank cars plays a role. Maybe the shapeless nature of oil, combined with a higher center of gravity should be looked at. Good summary, but too many players and posters are in denial and/or pointing fingers. A good solution has yet to be found. Possibly there is none acceptable within the parameters of competing economics and safety.
Maybe a better way to put it is it's not likely that there simple tweaks to standard North American railroading that will reduce the the "problem" to a seemingly acceptable level.
Anything beyond a "tweak" renders crude by rail an uneconomic proposition.
-Don (Random stuff, mostly about trains - what else? http://blerfblog.blogspot.com/)
A major problem with moving crude oil either by tank car or pipeline is that the vehicle is stupid. Information about integrity is either very slow or nonexistant. Pipeline SCADA (Supervisory Control and Data Acquisition) is all too often has infrequent data acquisition along the pipeline r.o.w. By the time the pipeline management understands what is going on many, many more gallons of crude is on the ground in comparison with these infamous derailments of the last two years. If the rogue TransCanada had ever proposed enhanced SCADA frequency and continuous fiberoptic surveillance of a pipeline with failure redundancy, that is, pipe within pipe; then Keystone XL might have had merit.
Now, railroad tank cars are stupid as well. There is nothing monitoring what the crude oil is doing. There are no sensors to identify heat that the cargo characteristics might be developing. There is nothing to measure slosh. There is nothing to monitor the roadibility of the tank car while in transit. There is nothing to express pressure relief valve operation. The multiple factors are not known before derailment. Tank cars need to be equipped with sensors enabling operation in order to prevent catastrophe.
If the engineer and conductor had smart tank cars they will know to slow or stop and respond.
So, at this point, if a railroad accepts bakken crude using under engineered tank cars for prevention; are they criminally negligent for derailment and explosion? If the railroad uses a stupid tank car that could otherwise be engineered and made smart and part of the exisiting fleet, are they negligent?
Might smart tank cars provide the information required to determine whether or not ECP brakes make sense? Might smart tank cars provide the information to determine best practices for train length, train makeup, train braking, train acceleration, and train speed.
The railroad industry needs smart tank cars. It matters little how strong a derailed tank car is built. It matters whether or not there was adequate informatioon available to safely handle the dangerous lading.
WilliamKiesel A major problem with moving crude oil either by tank car or pipeline is that the vehicle is stupid. Information about integrity is either very slow or nonexistant. Pipeline SCADA (Supervisory Control and Data Acquisition) is all too often has infrequent data acquisition along the pipeline r.o.w. By the time the pipeline management understands what is going on many, many more gallons of crude is on the ground in comparison with these infamous derailments of the last two years. If the rogue TransCanada had ever proposed enhanced SCADA frequency and continuous fiberoptic surveillance of a pipeline with failure redundancy, that is, pipe within pipe; then Keystone XL might have had merit. Now, railroad tank cars are stupid as well. There is nothing monitoring what the crude oil is doing. There are no sensors to identify heat that the cargo characteristics might be developing. There is nothing to measure slosh. There is nothing to monitor the roadibility of the tank car while in transit. There is nothing to express pressure relief valve operation. The multiple factors are not known before derailment. Tank cars need to be equipped with sensors enabling operation in order to prevent catastrophe. If the engineer and conductor had smart tank cars they will know to slow or stop and respond. So, at this point, if a railroad accepts bakken crude using under engineered tank cars for prevention; are they criminally negligent for derailment and explosion? If the railroad uses a stupid tank car that could otherwise be engineered and made smart and part of the exisiting fleet, are they negligent? Might smart tank cars provide the information required to determine whether or not ECP brakes make sense? Might smart tank cars provide the information to determine best practices for train length, train makeup, train braking, train acceleration, and train speed. The railroad industry needs smart tank cars. It matters little how strong a derailed tank car is built. It matters whether or not there was adequate informatioon available to safely handle the dangerous lading.
There is no evidence of any tank cars DOT 111 or any others spontaineously exploding because of unmonitored pressures in the cars when the cars have not been involved in a derailment.
oltmanndMaybe a better way to put it is it's not likely that there simple tweaks to standard North American railroading that will reduce the the "problem" to a seemingly acceptable level. Anything beyond a "tweak" renders crude by rail an uneconomic proposition.
Thanks to Chris / CopCarSS for my avatar.
WilliamKiesel A major problem with moving crude oil either by tank car or pipeline is that the vehicle is stupid. <snip> Now, railroad tank cars are stupid as well. There is nothing monitoring what the crude oil is doing. There are no sensors to identify heat that the cargo characteristics might be developing. There is nothing to measure slosh. There is nothing to monitor the roadibility of the tank car while in transit. There is nothing to express pressure relief valve operation. The multiple factors are not known before derailment. Tank cars need to be equipped with sensors enabling operation in order to prevent catastrophe.
A major problem with moving crude oil either by tank car or pipeline is that the vehicle is stupid.
<snip>
Why?
So far there have been NO derailments traced back to anything in the car causing the derailment or relief.
There have been no derailments due to the product "overheating" prior to being involved in a post accident fire.
There have been no derailments that have been shown to have been caused by "slosh".
There have been no derailments or releases caused by anything related to a pressure relief valve.
These are all really nifty things to measure, but what problem are you trying to solve? There is no evidence that says that any of the things you propose to measure have contributed to causing an accident or release.
They would know how to slow down and stop, but they wouldn't know how to "respond", well not in the way you mean. Train crews are NOT first responders. They have no training on how to repair tank cars, they have no equipment to provide personal protection from tank car commodities and they have no equipment to repair the valves or shells of tank cars. If there is a problem that they can see involving a release, their training is to get the documentation and get the prescribed safe distance away from the train, call for help, then provide the commodity emergency response information to the REAL first responders when they show. up.
ECP brakes are conventional brakes with a different actuating line. They are still air brakes. The major benefit of ECP is that the application or release signal can be transmitted to the entire train at the same time. With the advent of DPU locomotive configurations, the conventional brake application signal is transmitted from the head and rear end at almost the same time, reducing the benefit of ECP.
All of the data points you mention (speed, length, makeup, tonnage, etc) can already and have already been studied without needing "smart" tank cars. Knowing the internal temperature of a tank car is not related to how long the train is.
They need to have a "smart" car when designing and testing a car. The industry has been designing and testing the next generation tank car designed for inhalation hazard chemicals for the last several years and has had cars out fitted with sensors to measure the performance of the car while they operate it in real trains. But once the operation is proved, there is no need to continuously monitor the operation, especially if what you are monitoring has no bearing on whether or not there is a failure.
There are lots of things that could be improved to make operations safer. Why waste time and resources on things that have no impact on the safe operation of the car, when there are things that DO impact the safe operation of the car that could be improved.
Dave H. Painted side goes up. My website : wnbranch.com
As Dave says, most sensor values would be largely irrelevant. Derailments that are caused by the car itself trace back to the running gear. It would be possible to have sensors on each bearing to detect trouble there but more frequent wayside detectors will provide broader benefit. They could catch the train on an adjacent track before it derails into the tank train
Maybe excessive truck hunting could be identified, if it has even ever been a cause. Broken or loose wheels can sometimes travel for a short while before completely derailing and it might be possible to measure for that. But a broken axle will fail instantly so early detection is not feasible.
Murphy Siding oltmannd Maybe a better way to put it is it's not likely that there simple tweaks to standard North American railroading that will reduce the the "problem" to a seemingly acceptable level. Anything beyond a "tweak" renders crude by rail an uneconomic proposition. If shipment by rail becomes an uneconomic proposition, then how does the oil move? In the pipelines that don't exist? Or do they just cap the wells, and try to put the genie back in the bottle?
oltmannd Maybe a better way to put it is it's not likely that there simple tweaks to standard North American railroading that will reduce the the "problem" to a seemingly acceptable level. Anything beyond a "tweak" renders crude by rail an uneconomic proposition.
If shipment by rail becomes an uneconomic proposition, then how does the oil move? In the pipelines that don't exist? Or do they just cap the wells, and try to put the genie back in the bottle?
It doesn't move. If you can't get it where it needs to be at a price that beats other sources, you don't move it. You stop pumping.
oltmannd Murphy Siding oltmannd Maybe a better way to put it is it's not likely that there simple tweaks to standard North American railroading that will reduce the the "problem" to a seemingly acceptable level. Anything beyond a "tweak" renders crude by rail an uneconomic proposition. If shipment by rail becomes an uneconomic proposition, then how does the oil move? In the pipelines that don't exist? Or do they just cap the wells, and try to put the genie back in the bottle? It doesn't move. If you can't get it where it needs to be at a price that beats other sources, you don't move it. You stop pumping.
aka, "free market" economics. Since the price of crude plunged, even with a modest increase, exploration in the Bakken slowed down. Extracting the remainder of existing wells will continue until even that becomes more expensive than other sources.
The CSX derailment and railroad tank car safety is scheduled to be discussed today on "Fresh Air", the NPR radio program hosted by Teri Gross (or sometimes other hosts). Times vary, depending on the local NPR station. The program is usually a good source of info, but this topic is probably outside their usual areas of expertise, so I'm not sure what to expect.
Tom
Murphy Siding oltmannd Maybe a better way to put it is it's not likely that there simple tweaks to standard North American railroading that will reduce the the "problem" to a seemingly acceptable level. Anything beyond a "tweak" renders crude by rail an uneconomic proposition. If shipment by rail becomes an uneconomic proposition, then how does the oil move?
If shipment by rail becomes an uneconomic proposition, then how does the oil move?
But Bakken oil will not become uneconomical due to the cost of adding safety unless those additions are mandated. I think that will be the next shoe to drop. And then Bakken oil will stay in the ground.
dehusman WilliamKiesel A major problem with moving crude oil either by tank car or pipeline is that the vehicle is stupid. <snip> Now, railroad tank cars are stupid as well. There is nothing monitoring what the crude oil is doing. There are no sensors to identify heat that the cargo characteristics might be developing. There is nothing to measure slosh. There is nothing to monitor the roadibility of the tank car while in transit. There is nothing to express pressure relief valve operation. The multiple factors are not known before derailment. Tank cars need to be equipped with sensors enabling operation in order to prevent catastrophe. Why? So far there have been NO derailments traced back to anything in the car causing the derailment or relief. There have been no derailments due to the product "overheating" prior to being involved in a post accident fire. There have been no derailments that have been shown to have been caused by "slosh". There have been no derailments or releases caused by anything related to a pressure relief valve. These are all really nifty things to measure, but what problem are you trying to solve? There is no evidence that says that any of the things you propose to measure have contributed to causing an accident or release. If the engineer and conductor had smart tank cars they will know to slow or stop and respond. They would know how to slow down and stop, but they wouldn't know how to "respond", well not in the way you mean. Train crews are NOT first responders. They have no training on how to repair tank cars, they have no equipment to provide personal protection from tank car commodities and they have no equipment to repair the valves or shells of tank cars. If there is a problem that they can see involving a release, their training is to get the documentation and get the prescribed safe distance away from the train, call for help, then provide the commodity emergency response information to the REAL first responders when they show. up. Might smart tank cars provide the information required to determine whether or not ECP brakes make sense? Might smart tank cars provide the information to determine best practices for train length, train makeup, train braking, train acceleration, and train speed. ECP brakes are conventional brakes with a different actuating line. They are still air brakes. The major benefit of ECP is that the application or release signal can be transmitted to the entire train at the same time. With the advent of DPU locomotive configurations, the conventional brake application signal is transmitted from the head and rear end at almost the same time, reducing the benefit of ECP. All of the data points you mention (speed, length, makeup, tonnage, etc) can already and have already been studied without needing "smart" tank cars. Knowing the internal temperature of a tank car is not related to how long the train is. The railroad industry needs smart tank cars. It matters little how strong a derailed tank car is built. It matters whether or not there was adequate informatioon available to safely handle the dangerous lading. They need to have a "smart" car when designing and testing a car. The industry has been designing and testing the next generation tank car designed for inhalation hazard chemicals for the last several years and has had cars out fitted with sensors to measure the performance of the car while they operate it in real trains. But once the operation is proved, there is no need to continuously monitor the operation, especially if what you are monitoring has no bearing on whether or not there is a failure. There are lots of things that could be improved to make operations safer. Why waste time and resources on things that have no impact on the safe operation of the car, when there are things that DO impact the safe operation of the car that could be improved.
thanks Dave saved me typing a similar response, you only missed (I think) the railroads obligation under common carrier rules to accept traffic in what is considered (at the time) safe equipment. No criminal liability for accepting it, liability if not accepting it. Interesting how outsiders have all the answers without taking the time to understand the system.
Buslist ...the railroads obligation under common carrier rules to accept traffic in what is considered (at the time) safe equipment. No criminal liability for accepting it, liability if not accepting it.
...the railroads obligation under common carrier rules to accept traffic in what is considered (at the time) safe equipment. No criminal liability for accepting it, liability if not accepting it.
The law requiring railroads to accept Bakken oil traffic will have to change if a law or executive order forbids shipping it in existing tank cars.
schlimm oltmannd Murphy Siding oltmannd Maybe a better way to put it is it's not likely that there simple tweaks to standard North American railroading that will reduce the the "problem" to a seemingly acceptable level. Anything beyond a "tweak" renders crude by rail an uneconomic proposition. If shipment by rail becomes an uneconomic proposition, then how does the oil move? In the pipelines that don't exist? Or do they just cap the wells, and try to put the genie back in the bottle? It doesn't move. If you can't get it where it needs to be at a price that beats other sources, you don't move it. You stop pumping. aka, "free market" economics. Since the price of crude plunged, even with a modest increase, exploration in the Bakken slowed down. Extracting the remainder of existing wells will continue until even that becomes more expensive than other sources.
Not really. Most of the detinations for the Bakken oil are on the east coast and most are set up to take North Sea and Nigerian oil. Many have already swiched back to those sources as market prices fluctuate. Add some more dollars to the transport of Bakken, and crude by rail will dry up in relatively short order.
Euclid Buslist ...the railroads obligation under common carrier rules to accept traffic in what is considered (at the time) safe equipment. No criminal liability for accepting it, liability if not accepting it. The law requiring railroads to accept Bakken oil traffic will have to change if a law or executive order forbids shipping it in existing tank cars.
The rate could change if costs go up. Equipment costs go up with cost to provide equipment. The law allows rates a % over and above variable cost. Everything being discussed will add to variable cost. Bakken oil makes it's living in the spread with Brent crude. Transport costs eat into that margin.
Keep adding to the cost and the margin will be gone the crude by rail will dry up.
How will the industry know the cost of making the Bakken shipping safe? Will they need to actually implement additional safety until there is enough safety?
If so, they could then raise the cost to cover that cost of added safety. Then if the cost of shipping were deemed too high by the oil producers, they would decide against shipping the oil by rail.
If the oil business were to dry up in the short term, the losers would be the speculators in the car leasing business and the car builders that will have car orders cancelled. Were the business to dry up there would be a whole lot of tank cars existant with nothing to haul.
While rail employment would take a dip, with the attrition of retirement age employees most if not all existing employees would ultimately be retained. The additional power that the carriers have been purchasing would then permit the scraping of older power that had been kept working with the current power shortages.
Capital spending for added tracks, etc. would likely slow, too.
But then the 'backlog' of grain & fertilizer, etc. could be moved faster instead, and maybe also the backlog of containers at the West Coast ports . . .
oltmannd schlimm aka, "free market" economics. Since the price of crude plunged, even with a modest increase, exploration in the Bakken slowed down. Extracting the remainder of existing wells will continue until even that becomes more expensive than other sources. Not really. Most of the detinations for the Bakken oil are on the east coast and most are set up to take North Sea and Nigerian oil. Many have already swiched back to those sources as market prices fluctuate. Add some more dollars to the transport of Bakken, and crude by rail will dry up in relatively short order.
schlimm aka, "free market" economics. Since the price of crude plunged, even with a modest increase, exploration in the Bakken slowed down. Extracting the remainder of existing wells will continue until even that becomes more expensive than other sources.
That is the market at work.
Where are we at with the new DOT tank car standards? I thought they were finalized and made public last summer, but lately I have heard that they won't be ready until this coming May.
Now that the carbuilders have said that it is impossible to prevent tank car breaches in high speed derailments by making the cars stronger, what is the point of new DOT standards to make the cars stonger?
Euclid Where are we at with the new DOT tank car standards? I thought they were finalized and made public last summer, but lately I have heard that they won't be ready until this coming May. Now that the carbuilders have said that it is impossible to prevent tank car breaches in high speed derailments by making the cars stronger, what is the point of new DOT standards to make the cars stonger?
We are still waiting.
The process works something like this:
The FRA identifies a need and then assembles a group of experts - nominally those folk who work on standing committees in the AAR (I believe there is a tank car committee that has been around for a long time). The committee has connections to the car builders (probably voice but no vote on the committee - I don't remember).
The FRA asks the experts for solutions to the problems - things that will make a difference and can be practically applied. The FRA sorts through this information and decides on rule making that will mandate the what, how and when.
Then the FRA proposes a rule and asks for comments from all interested parties. They evaluate the comments and then issue a final rule.
This process is how we got shelf couplers, skid plates on tank valves and head shields among other things.
One thing that's key in the process is that the FRA leans on others for expertise, both technical and practical (what can be done, is it cost effective, when can it be done, who can do it?)
I think the rule making is hung up between the comments and final rule being issued. This means the problem is somewhere internal in the government. It could be just ineffiency in the FRA itself or a squabble within the DOT or problems with others elsewhere in the adminstration or goverment. Who know?
The current adminsitration doesn't have a very good record of speedy rule making. Best current example is PTC.
EuclidNow that the carbuilders have said that it is impossible to prevent tank car breaches in high speed derailments by making the cars stronger, what is the point of new DOT standards to make the cars stonger?
Stronger = better, not perfect. Stonger cars will breach less often.
Euclideing that the new DOT standards have not yet been released, does that mean that we have no way of knowing what those standards will require?
I guess a surprise is always possible, but the rules usually look a lot like the drafts that circulated for comment.
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