Oil Train

[Euclid]

Norm,

 

Yes, that is exactly what I am saying.  It is either that or the railroad industry does not know what they are talking about.  I think that the DOT was duped by a long standing exaggeration of ECP stopping power that has been intentionally implied, as I detailed in the second post on this page.  Some of the railroad industry itself has contributed to this exaggeration before this mandate was in the offing.  Unfortunately for them, they probably helped convince the DOT that ECP was the answer. So the exaggeration came back to bite them.    

[Norm48327]

"I conclude that the USDOT (astoundingly) fails to understand the qualifiers to the answer."

Are you saying that the people who deal with this on a daily basis don't know what they are talking about? Certainly sounds like it.

[Euclid]

Chuck,

 

The quote I posted above with comments from the USDOT is from the N.Y. Times today.  Last Friday, the following comments are attributed to Secretary of Transportation, Anthony Foxx after the mandate was announced.  This is the link: http://www.politico.com/story/2015/05/obama-safety-regulations-train-oil-derailments-117550.html#ixzz3ZNbTCQWb

 

Here are the comments quoted:

 

Foxx maintained that the brakes could prevent a repeat of incidents like a December 2013 collision in which an oil train slammed into a derailed grain train, setting off a series of explosions outside Casselton, N.D.

 

 “ECP brakes can reduce how long it takes a train to stop,” Foxx said. “They can prevent cars from slamming into each other, they can decrease the number of cars that derail, they can greatly reduce the probability that tank cars will puncture. This is proven technology.”

So, here again is the reference to stopping short of an obstacle on the track.  In this case, Secretary Foxx refers to the derailed grain train as the obstacle that was struck in Casselton, ND by the oil train that exploded and burned. 

 

The ability to stop faster to avoid striking an obstacle is surely a valid point. I agree with your point that it is often not successful because the speed is too high and the distance too short.  However, avoiding a collision by stopping short has happened thousands of times in railroad history.  The only problem with the DOT comments is that there is no such enhancement of that ability given by ECP brakes.

[zugmann]

All this talk about air brakes.  Yet dynamic braking and throttle modulation are the preferred ways to handle trains.  I guess ECP would help in severe grade territory to some extent, but they act like we need it to be safe. 

*shrugs*

I can stop fine with what we have now.   Perhaps we need to focus on skills and training and less on fancy gadgets.

 

Let's look at it this way.  Some hotshot engineer races to a stop signal, figuring his ECP brakes will let him stop 70% faster.  But the E in the ECP fails.  No problem, as you still have the ol' standard backup airbrake.  Only problem?  It's 70% worse.  Dump it and pray I guess.    I would never trust ECP to be 70% faster just because of that.  It's like using dynamics - you always have to be prepared in case they crap out. 

[cefinkjr]

Euclid: You implied that you were quoting USDOT when you wrote "... allow train operators to stop faster if there was an obstacle on the tracks.”  It sounds enough like government bureaucratize to be from USDOT.  I assume by "train operators" they mean engineers.

Question for the many engineers on this forum: "How many times in your career have you stopped your train because of an obstacle on the track?"  And a companion question: "How often are you able to stop your train because of an obstacle on the track when you are moving at track speed?"

 

[schlimm]

Euclid

Apparently, the USDOT never learned of the qualifier and went ahead with the ECP mandate as though the qualifier does not exist.  I wonder if there has ever been a regulatory error of this magnitude based on such a simple misunderstanding of a palpable engineering fact.  This is one for the record books. 

I haven't the stomach for reading the entire thread.  It seems to me the point of ECP is to obviate the need for emergency brake applications (which may cause aforementioned pile-ups) by having safer, controlled, 70% shorter distance stops with service applications.    

[BaltACD]

The US has the best form of government that MONEY can buy.

[dehusman]

And Euclid's been the head cheerleader for ECP on this list.

[Euclid]

In the wake of the new tank car rules, here is the pivotal question about ECP brakes:

 

Do ECP brakes decrease train stopping distance by up to 70%—OR—do they decrease train stopping distance by up to 1%?

 

 

 

Here is the answer as I understand it:

 

Both are true, but each has a qualifier.

 

ECP brakes decrease train stopping distance by up to 70% with a “service” application of brakes.

 

ECP brakes decrease train stopping distance by up to 1% with an “emergency” application of brakes.

 

 

 

I conclude that the USDOT (astoundingly) fails to understand the qualifiers to the answer.  Here is their understanding of the answer upon which they base the ECP mandate:

 

“Transportation officials said the new type of brakes was already in use by some railroads for other types of commodities. Their use would decrease the chances of a catastrophic pileup, reduce the number of punctured cars in an accident, or allow train operators to stop faster if there was an obstacle on the tracks.”

 

 

The problem with that conclusion is that it is only true with the “service” application of brakes, and not with an “emergency” application of brakes.  The examples cited by the USDOT, that is, decreasing catastrophic pileup, reducing the number of punctured cars, and stopping faster for an obstacle are all related only to the use of an “emergency” application of brakes and not to a “service” application.  Therefore, these benefits claimed by USDOT are simply false.   

 

How could a gigantic institution such as the USDOT make such a fundamental error?  And how can the equally large institution comprised of the railroads, tank car owners, and oil producers fail to clearly explain the fundamental error in their reaction to the new ECP mandate?

 

I think there is an answer to that as well.  Since the introduction of ECP brakes starting in the 1990s, there has been intense promotion of the advantages of the system in comparison to the drawbacks of conventional air brakes.  ECP brakes have been promoted as the modern replacement for the “old, obsolete air brakes dating from the 1800s.”  Everyone in the industry was on the ECP bandwagon and singing the praise. 

 

One of the main points favoring ECP was said to be shorter stopping distance with all of the benefit of safety and efficiency that implied.  There is no end to references claiming that ECP provides a reduction of stopping distance of up to 70%.  But the qualifier to that claim was never included because it waters down the claim.  The bandwagon wanted the best news possible, so they did not want to mention that the 70% claim is null with an “emergency” application of brakes.  Yet leaving out that qualifier is disingenuous at best. 

 

Apparently, the USDOT never learned of the qualifier and went ahead with the ECP mandate as though the qualifier does not exist.  I wonder if there has ever been a regulatory error of this magnitude based on such a simple misunderstanding of a palpable engineering fact.  This is one for the record books. 

[wanswheel]

If there’s any interest, MSNBC’s Rachel Maddow briefly interviewed Anthony Foxx (second link), after a fairly lengthy set-up (first link). Lots about oil trains, practically nothing about brakes, though.

http://on.msnbc.com/1ILJRoY

http://on.msnbc.com/1ILGhv0

[Euclid]

Euclid

 

Buslist

 

Euclid

 

tree68

 

wanswheel

Current brake systems occur sequentially, car by car

 

 

Much as I hate to post on this thread again.

 

ECP dumps all the cars at once.

On a mile long train with distributed power, doing so will take all of three seconds.  Big difference?  For a train doing 40 MPH, I think not...

One one thousand, two one thousand, three one thousand.  All brakes activated.  Actual application may take up to ten seconds longer...  

 

 

 

I agree that it does not seem like a few seconds would make any significant difference in total stopping time.  This seems obvious when you consider that total stopping time might be a minute or more.  And yet, there are published claims of reductions in stopping distance of up to 70% with ECP brakes.  The Secretary of Transportation himself has cited the reduced stopping distance in practical terms that implies significant difference in stopping distance between the two brake types.  It is hard to believe that such a claim would be made in total error.  So what is the explanation?  

 

My understanding is that there is a second reason why ECP brakes shorten stopping distance, in addition to the reason involving instant propagation versus sequential propagation.  This second reason apparently contributes far more to a shorter stopping distance than does the instant application.  The second reason is that the air that flows from the reservoir to the brake cylinder on each car moves faster with ECP brakes than it does with conventional pneumatically controlled air brakes.  

 

These are quotes from Railway Technical Web Pages which explain the second reason why ECP brakes stop trains faster.  Here is the site:  http://www.railway-technical.com/brake3.shtml

 

Here are the quotes:

 

 

 

“Because of the sequential operations of standard brakes, there is a flow control which limits how fast the air can flow into the brake cylinder. On ECP systems, because there is instantaneous reaction from all cars at once, these flow controls are not used. The lack of sequential activation and flow controls combined is what makes ECP brakes so responsive.”

 

 

“With the new responsiveness of ECP braking, braking distances will be reduced. A range of 30 - 70% reduction has been quoted. This will allow shorter stopping distances and will, in turn, allow higher speeds. The improved train handling will reduce slack action, breakaways and derailments and will lead to a reduction in draft gear maintenance.”

 

 

 

 

. 

 

This discussion relates to service brakeing not emergency application where there is no need for flow control.

 

 

 

Buslist,

 

You raise an interesting point, and I would like to see an elaboration.  Do you have a technical source that fully explains that?  Where exactly in the conventional air brake systems are the flow controls, what flow are they controlling, how do they control it, and why is it necessary to control it?

 

I find many sources that describe the much shorter stopping distance of ECP brakes, and none of them make the distinction that you have made; that is, that the shorter stopping distance only applies to service applications, and not to emergency applications. 

 

If you are correct, it seems like a leaving out that detail would be extremely misleading.  When I hear of comparison of stopping ability with any type of vehicle brake, I assume that the two brake types are being applied to their maximum stopping power.  So it seems very odd to compare stopping distance of train brakes, but to not include the fundamentally most effective stopping mode in that comparison.    

 

Buslist,

[Euclid]

Buslist

 

Euclid

 

tree68

 

wanswheel

Current brake systems occur sequentially, car by car

 

 

Much as I hate to post on this thread again.

 

ECP dumps all the cars at once.

On a mile long train with distributed power, doing so will take all of three seconds.  Big difference?  For a train doing 40 MPH, I think not...

One one thousand, two one thousand, three one thousand.  All brakes activated.  Actual application may take up to ten seconds longer...  

 

 

 

I agree that it does not seem like a few seconds would make any significant difference in total stopping time.  This seems obvious when you consider that total stopping time might be a minute or more.  And yet, there are published claims of reductions in stopping distance of up to 70% with ECP brakes.  The Secretary of Transportation himself has cited the reduced stopping distance in practical terms that implies significant difference in stopping distance between the two brake types.  It is hard to believe that such a claim would be made in total error.  So what is the explanation?  

 

My understanding is that there is a second reason why ECP brakes shorten stopping distance, in addition to the reason involving instant propagation versus sequential propagation.  This second reason apparently contributes far more to a shorter stopping distance than does the instant application.  The second reason is that the air that flows from the reservoir to the brake cylinder on each car moves faster with ECP brakes than it does with conventional pneumatically controlled air brakes.  

 

These are quotes from Railway Technical Web Pages which explain the second reason why ECP brakes stop trains faster.  Here is the site:  http://www.railway-technical.com/brake3.shtml

 

Here are the quotes:

 

 

 

“Because of the sequential operations of standard brakes, there is a flow control which limits how fast the air can flow into the brake cylinder. On ECP systems, because there is instantaneous reaction from all cars at once, these flow controls are not used. The lack of sequential activation and flow controls combined is what makes ECP brakes so responsive.”

 

 

“With the new responsiveness of ECP braking, braking distances will be reduced. A range of 30 - 70% reduction has been quoted. This will allow shorter stopping distances and will, in turn, allow higher speeds. The improved train handling will reduce slack action, breakaways and derailments and will lead to a reduction in draft gear maintenance.”

 

 

 

 

. 

 

This discussion relates to service brakeing not emergency application where there is no need for flow control.

 

Buslist,

 

You raise an interesting point, and I would like to see an elaboration.  Do you have a technical source that fully explains that?  Where exactly in the conventional air brake systems are the flow controls, what flow are they controlling, how do they control it, and why is it necessary to control it?

 

I find many sources that describe the much shorter stopping distance of ECP brakes, and none of them make the distinction that you have made; that is, that the shorter stopping distance only applies to service applications, and not to emergency applications. 

 

If you are correct, it seems like a leaving out that detail would be extremely misleading.  When I hear of comparison of stopping ability with any type of vehicle brake, I assume that the two brake types are being applied to their maximum stopping power.  So it seems very odd to compare stopping distance of train brakes, but to not include the fundamentally most effective stopping mode in that comparison.    

[Buslist]

Euclid

 

tree68

 

wanswheel

Current brake systems occur sequentially, car by car

 

 

Much as I hate to post on this thread again.

 

ECP dumps all the cars at once.

On a mile long train with distributed power, doing so will take all of three seconds.  Big difference?  For a train doing 40 MPH, I think not...

One one thousand, two one thousand, three one thousand.  All brakes activated.  Actual application may take up to ten seconds longer...  

 

 

 

I agree that it does not seem like a few seconds would make any significant difference in total stopping time.  This seems obvious when you consider that total stopping time might be a minute or more.  And yet, there are published claims of reductions in stopping distance of up to 70% with ECP brakes.  The Secretary of Transportation himself has cited the reduced stopping distance in practical terms that implies significant difference in stopping distance between the two brake types.  It is hard to believe that such a claim would be made in total error.  So what is the explanation?  

 

My understanding is that there is a second reason why ECP brakes shorten stopping distance, in addition to the reason involving instant propagation versus sequential propagation.  This second reason apparently contributes far more to a shorter stopping distance than does the instant application.  The second reason is that the air that flows from the reservoir to the brake cylinder on each car moves faster with ECP brakes than it does with conventional pneumatically controlled air brakes.  

 

These are quotes from Railway Technical Web Pages which explain the second reason why ECP brakes stop trains faster.  Here is the site:  http://www.railway-technical.com/brake3.shtml

 

Here are the quotes:

 

 

 

“Because of the sequential operations of standard brakes, there is a flow control which limits how fast the air can flow into the brake cylinder. On ECP systems, because there is instantaneous reaction from all cars at once, these flow controls are not used. The lack of sequential activation and flow controls combined is what makes ECP brakes so responsive.”

 

 

“With the new responsiveness of ECP braking, braking distances will be reduced. A range of 30 - 70% reduction has been quoted. This will allow shorter stopping distances and will, in turn, allow higher speeds. The improved train handling will reduce slack action, breakaways and derailments and will lead to a reduction in draft gear maintenance.”

 

. 

This discussion relates to service brakeing not emergency application where there is no need for flow control.

[dehusman]

Anybody besides me notice that virtually all the people who design, build, own, repair, use, operate or physically have to deal with tank cars or trains were against the ECP and all the people in favor of them were regulators, environmental or civic groups?

The AAR's report was developed by the foremost transportation research center in the US that has had a hand in testing most of the new developments in railroad safety for the last several decades.  Railroad safety and vehicle dynamics is what they do every day.  If anybody would know about train dynamics it would be them.

[Euclid]

tree68

 

wanswheel

Current brake systems occur sequentially, car by car

 

 

Much as I hate to post on this thread again.

 

ECP dumps all the cars at once.

On a mile long train with distributed power, doing so will take all of three seconds.  Big difference?  For a train doing 40 MPH, I think not...

One one thousand, two one thousand, three one thousand.  All brakes activated.  Actual application may take up to ten seconds longer...  

 

I agree that it does not seem like a few seconds would make any significant difference in total stopping time.  This seems obvious when you consider that total stopping time might be a minute or more.  And yet, there are published claims of reductions in stopping distance of up to 70% with ECP brakes.  The Secretary of Transportation himself has cited the reduced stopping distance in practical terms that implies significant difference in stopping distance between the two brake types.  It is hard to believe that such a claim would be made in total error.  So what is the explanation?  

 

My understanding is that there is a second reason why ECP brakes shorten stopping distance, in addition to the reason involving instant propagation versus sequential propagation.  This second reason apparently contributes far more to a shorter stopping distance than does the instant application.  The second reason is that the air that flows from the reservoir to the brake cylinder on each car moves faster with ECP brakes than it does with conventional pneumatically controlled air brakes.  

 

These are quotes from Railway Technical Web Pages which explain the second reason why ECP brakes stop trains faster.  Here is the site:  http://www.railway-technical.com/brake3.shtml

 

Here are the quotes:

 

 

 

“Because of the sequential operations of standard brakes, there is a flow control which limits how fast the air can flow into the brake cylinder. On ECP systems, because there is instantaneous reaction from all cars at once, these flow controls are not used. The lack of sequential activation and flow controls combined is what makes ECP brakes so responsive.”

 

 

“With the new responsiveness of ECP braking, braking distances will be reduced. A range of 30 - 70% reduction has been quoted. This will allow shorter stopping distances and will, in turn, allow higher speeds. The improved train handling will reduce slack action, breakaways and derailments and will lead to a reduction in draft gear maintenance.”

[tree68]

wanswheel

Current brake systems occur sequentially, car by car

Much as I hate to post on this thread again.

ECP dumps all the cars at once.

On a mile long train with distributed power, doing so will take all of three seconds.  Big difference?  For a train doing 40 MPH, I think not...

One one thousand, two one thousand, three one thousand.  All brakes activated.  Actual application may take up to ten seconds longer...  

[wanswheel]

Old news (March 11, 2015) from OilPrice.com:

After a slew of oil train derailments over the past month, the Obama administration is under assault…from lobbyists that is.

A barrage of lobbying has descended upon the White House as it considers new regulations on trains carrying crude oil. And the petitioning is coming from all sides. EnergyWire reported that a day after a 105-railcar train jumped the tracks in Illinois and caught fire – which in turn came only two weeks after a massive train explosion in West Virginia – lobbyists from the rail industry visited the White House for private meetings.

According to White House logs, representatives from CSX, BNSF, Canadian Pacific Railway, Kansas City Southern, and the Association of American Railroads (AAR) – the rail industry’s trade group – met with officials from the executive branch. The brass from the rail companies wanted to head off new regulations from the Department of Transportation that would require trains install new high-tech brake systems intended to reduce the chance of a derailment. The regulations are currently under review by White House officials.

The so-called electronically controlled pneumatic (ECP) brakes would allow all railcars to slam on the brakes at the same time. Current brake systems occur sequentially, car by car. Ed Hamberger, CEO of AAR, says the rule would do very little for safety while adding costs onto the industry, and he called the Transportation Department’s analysis “flawed.” In fact, the trade group says, Transportation regulators “grossly overstate benefits and understate costs.”

[Euclid]

BaltACD

 

Euclid

 

 

What amazes me is that these two gigantic institutions can be so diametrically opposed on an objective engineering question regarding train braking.  

 

 

 

The best arguments in the world are two engineers on different sides of the same fact - they will argue it to their deaths.  Since Foxx is a politician first it automatically takes 10 points away from whatever argument he proposes.  Cost/benefit analysis needs to be performed on any mandated appliances.  How many US lives have been lost, how many serious injuries have been caused in oil train derailments because of the lack of ECP on oil trains.

 

I am referring to the objective question of whether ECP brakes can reduce stopping distance by 70%, or whether they do not reduce stopping distance at all.  It seems like that is the pivotal question.  I am surprised that it seems to have no answer at this point in ECP development, testing, and application. 

 

The point of the quotes I posted was to show that the DOT at least offers a practical reason for ECP, whereas the AAR only says that DOT has not proven its case.  Secretary Foxx even went so far as to say that the shorter stopping distance of ECP will even prevent collisions such as the one that lead to the Casselton oil train wreck.   

 

I was surprised that AAR President Ed Hamberger suggested that President Obama broke his promise regarding the DOT rulemaking.

[Buslist]

Lots of knowledgeable folks questioning the ECP requirement.

 

[But] CN does not support the implementation of ECP brakes for high-hazard flammable trains as the rail industry is of the opinion this technology has not proven to provide a meaningful safety benefit. CN also has serious concerns about interoperability and the reliability of the technology in Canada’s harsh winter weather." — CN officials

 

 

On the other hand, we are deeply troubled by the requirement for ECP brakes, a braking technology that is still in development and not proven in regular service. This requirement could dramatically and widely slow railroad operations and impair railroads’ ability to serve customers in all sectors of a growing economy. With respect to sharing shipping information and supporting community readiness, CSX has long recognized the need for balance between national security interests and public agencies’ need to know about the products moving through communities." — CSX Corp. officials

 

NS has been experimenting with ECP brakes on a small number of coal trains since 2007, but it is not widely used on our system. We stand with the AAR and question the benefits and consequences of this rule. We will evaluate the new ECP rule to determine how it will impact our operations and work with the owners of the tank cars to determine the best way forward." — Norfolk Southern Corp. officials

 

"ECP brakes do not prevent derailments from happening; rather, this technology has some limited potential to mitigate the severity of a derailment. The Railway Association of Canada believes this marginal safety benefit must be weighed against the considerable operational challenges of implementing this technology, and the additional risk posed to employee safety. RAC believes that the new tank car standard recently announced by Transport Canada will deliver the most meaningful results in mitigating the impacts of a potential derailment. RAC also believes that by focusing resources on other technologies proven to prevent derailments, the railway industry can have a much more meaningful safety impact." — Railway Association of Canada officials

 

"It is disappointing that the final ruling [includes] ECP brakes and did not fully address our concerns as small businesses that are critical in the successful transportation of these commodities. We will be taking the next several days to carefully review these documents, evaluate the impact on our members and to consider next steps." — Linda Bauer Darr, president of the American Short Line and Regional Railroad Association

 

The inclusion of a requirement for ECP brakes will add to the artificial constraints created by a timeline for retrofitting the existing tank car fleet that does not fully account for limited shop capacity available to complete the work. The safety impact of ECP brakes is marginal at best." — American Petroleum Institute President and CEO Jack Gerard

 

The DOT’s addition of ECP brakes to the retrofit standard is not only questionable from a safety improvement perspective, it makes the probability of retrofit even more unlikely for these cars." — GATX Corp. President and CEO Brian Kenney

 

RSI‐CTC provided extensive information and analysis to officials in the U.S. regarding the challenges of requiring ECP brakes to rail tank cars. That data and analysis show that ECP brakes do not achieve significant safety advantages in derailment scenarios as compared to alternative braking systems which are already being used and which present far fewer technical and logistical challenges than ECP brakes." — Tom Simpson, president of the Railway Supply Institute, on behalf of the Committee on Tank Cars

 

[BaltACD]

Euclid

 

 

What amazes me is that these two gigantic institutions can be so diametrically opposed on an objective engineering question regarding train braking.  

The best arguments in the world are two engineers on different sides of the same fact - they will argue it to their deaths.  Since Foxx is a politician first it automatically takes 10 points away from whatever argument he proposes.  Cost/benefit analysis needs to be performed on any mandated appliances.  How many US lives have been lost, how many serious injuries have been caused in oil train derailments because of the lack of ECP on oil trains.

[Buslist]

Euclid

Following the release of the new tank car rules Friday, this sums up the large disagreement between the AAR (quoting Ed Hamberger) and the USDOT (quoting Anthony Foxx) regarding the ECP brake mandate included in the rules.  It’s in this link followed by quotes in dark green:

 

http://www.politico.com/story/2015/05/obama-safety-regulations-train-oil-derailments-117550.html

 

“The DOT couldn’t make a safety case for ECP but forged ahead anyhow,” railroads association President Ed Hamberger said in a statement. “This is an imprudent decision made without supporting data or analysis. I have a hard time believing the determination to impose ECP brakes is anything but a rash rush to judgment.”

 

 

 

Here is Secretary of Transportation Anthony Fox offering his view contrary to that of AAR President Ed Hamberger:

 

 

Foxx maintained that the brakes could prevent a repeat of incidents like a December 2013 collision in which an oil train slammed into a derailed grain train, setting off a series of explosions outside Casselton, N.D.

 

“ECP brakes can reduce how long it takes a train to stop,” Foxx said. “They can prevent cars from slamming into each other, they can decrease the number of cars that derail, they can greatly reduce the probability that tank cars will puncture. This is proven technology.”

 

What amazes me is that these two gigantic institutions can be so diametrically opposed on an objective engineering question regarding train braking.  Maybe the USDOT can be excused for acting on emotion instead of the engineering, but what about the AAR?  With the incredible cost being forced upon them to adopt ECP brakes; why, with this mandate looming; were they not able to make a convincing case to the regulators on such a simple issue as train stopping distance? 

 

Just reading between the lines, I think it was inevitable that the ECP mandate was going to be included in the new tank car rules.  That outcome was obviously portended in the “stacked deck” of three options that the USDOT released last summer.  I conclude that the AAR may have been blindsided by the power of the ECP supplier industry to seize the golden opportunity presented by the oil train crisis.  I’ll bet they made one heck of a presentation of ECP to the regulators.  I have no idea whether the AAR ever made their case to the regulators.  They sure are not doing so in the above statement by President Hamberger.   

 

 

*          *

 

 What you are missing is that there some zealots in the Office of Safety that believe what they want to believe ( sound familier) independent of what data the AAR might presen. And I know a few of them.

[Buslist]

oltmannd

Hamberger also said, " The DOT’s study is flawed and [electronic] brakes do not significantly improve safety and are unreliable. "

Do not underestimate the impact of "unreliable"!  

 

 

Looks to me like Ed is setting the stage for a lawsuit here. The AAR has successfully sued FRA over regulations before. 

I'm not sure of the legal status of this regulation as there was no ANPRM or NPRM, does it still need to pass the OMB required cost/benefit analysis?

[Euclid]

Following the release of the new tank car rules Friday, this sums up the large disagreement between the AAR (quoting Ed Hamberger) and the USDOT (quoting Anthony Foxx) regarding the ECP brake mandate included in the rules.  It’s in this link followed by quotes in dark green:

 

http://www.politico.com/story/2015/05/obama-safety-regulations-train-oil-derailments-117550.html

 

“The DOT couldn’t make a safety case for ECP but forged ahead anyhow,” railroads association President Ed Hamberger said in a statement. “This is an imprudent decision made without supporting data or analysis. I have a hard time believing the determination to impose ECP brakes is anything but a rash rush to judgment.”

 

 

 

Here is Secretary of Transportation Anthony Fox offering his view contrary to that of AAR President Ed Hamberger:

 

 

Foxx maintained that the brakes could prevent a repeat of incidents like a December 2013 collision in which an oil train slammed into a derailed grain train, setting off a series of explosions outside Casselton, N.D.

 

“ECP brakes can reduce how long it takes a train to stop,” Foxx said. “They can prevent cars from slamming into each other, they can decrease the number of cars that derail, they can greatly reduce the probability that tank cars will puncture. This is proven technology.”

 

What amazes me is that these two gigantic institutions can be so diametrically opposed on an objective engineering question regarding train braking.  Maybe the USDOT can be excused for acting on emotion instead of the engineering, but what about the AAR?  With the incredible cost being forced upon them to adopt ECP brakes; why, with this mandate looming; were they not able to make a convincing case to the regulators on such a simple issue as train stopping distance? 

 

Just reading between the lines, I think it was inevitable that the ECP mandate was going to be included in the new tank car rules.  That outcome was obviously portended in the “stacked deck” of three options that the USDOT released last summer.  I conclude that the AAR may have been blindsided by the power of the ECP supplier industry to seize the golden opportunity presented by the oil train crisis.  I’ll bet they made one heck of a presentation of ECP to the regulators.  I have no idea whether the AAR ever made their case to the regulators.  They sure are not doing so in the above statement by President Hamberger.   

 

 

*          *

[oltmannd]

Hamberger also said, " The DOT’s study is flawed and [electronic] brakes do not significantly improve safety and are unreliable. "

Do not underestimate the impact of "unreliable"!  

[Euclid]

The AAR statement on the new federal mandate requiring ECP brakes on oil trains:

 

 

 

https://www.aar.org/newsandevents/Press-Releases/Pages/New-US-Rules-Governing-Flammable-Liquids-Moved-by-Rail-Enact-Misguided-Braking-Requirement-That-Threatens-Rail-Capacity.aspx

 

 

FOR​​​ IMMEDIATE RELEASE

 

New U.S. Rules Governing Flammable Liquids Moved by Rail Enact Misguided Braking Requirement That Threatens Rail Capacity and Service

Based on Flawed Safety Data; Will Trigger Slower Trains Nationwide

WASHINGTON D.C. May 1, 2015- The Association of American Railroads (AAR) today welcomed the tank car rule released by the Department of Transportation (DOT), which requires enhanced design standards the freight railroads have been advocating for years, but said it was disappointed the rule requires either the use of ECP brakes or imposes a 30 mph speed limit.

“First and foremost, the DOT has no substantial evidence to support a safety justification for mandating ECP brakes, which will not prevent accidents,” said Edward R. Hamberger, AAR president and CEO. “The DOT couldn’t make a safety case for ECP but forged ahead anyhow. This is an imprudent decision made without supporting data or analysis. I have a hard time believing the determination to impose ECP brakes is anything but a rash rush to judgment.”

Hamberger also questioned how a safety mandate of such magnitude could become a regulation when the negligible ECP simulation analysis the government conducted concluded with the cautionary note, “Given that this is based on a limited simulation set, the results could be a bit optimistic and should be taken with a grain of salt.”

“President Obama pledged to advance common-sense regulations that are based on the best available science, promote predictability and reduce uncertainty,” Hamberger said. “ECP brakes meet none of these.”

“DOT has handed down an unprecedented railroad operating requirement that is 100 percent dependent on the actions of rail customers or tank cars owners,” Hamberger said. “This decision not only threatens the operational management of the U.S. rail system, but trains moving 30 mph will compromise network capacity by at least 30 percent. The far-reaching effects of this decision will be felt by freight and passenger customers alike. Slow-moving trains will back up the entire rail system.”

“Attention and resources should be allocated to addressing the underlying causes of rail accidents and brakes simply aren’t on that list. Unjustified regulations such as this trigger a reallocation of investments that will not generate the kind of safety benefits the industry and the public expects. The regulation does not take into account the disruption the ECP mandate will wreak on railroad – both freight and passenger – operations.”

“We have worked cooperatively with the government during this rulemaking process, as our goal has always been to make a safe rail network even safer. We support tougher tank cars and we see many of the rule’s components building on our crude-by-rail safety achievements.”

However, the AAR President said the industry is extremely disappointed with how the ECP mandate unfolded. “DOT’s study is flawed and ECP brakes do not significantly improve safety and are unreliable. No justified safety case for ECP brakes has ever been made.”

Hamberger pointed out that freight railroads have on their own volition implemented stepped-up safety practices and protocols for handling and moving crude oil trains, as well as increased emergency training for firefighters and first responders. Last month, the AAR and the American Petroleum Institute announced a new crude-by-rail safety course for first responders offered through the TRANSCAER program​.

“The goal of America’s freight railroads remains zero accidents and we will continue doing what we can to prevent accidents from happening and earn the public’s trust and confidence,” Hamberger said.

[wanswheel]

Excerpt from the NY Times

http://www.nytimes.com/2015/05/02/business/energy-environment/us-sets-new-rules-for-oil-shipments-by-rail.html?_r=0

On Thursday, seven senators, including Charles E. Schumer, Democrat of New York, unveiled a bill that would seek to impose a $175 per shipment fee on older cars to speed up their removal from service.

Senator Schumer said Friday’s announcement gave railroads too much time to remove older cars from service...

The Association of American Railroads said it backed the new tank car requirements but objected to a requirement that railroads should adopt new electronically controlled pneumatic brakes, or E.C.P., starting in 2021 for oil trains.

“The D.O.T. couldn’t make a safety case for E.C.P. but forged ahead anyway,” Edward R. Hamberger, the president and chief executive of the Association of American Railroads, said in a statement. “I have a hard time believing the determination to impose E.C.P. brakes is anything but a rash rush to judgment.”

[Euclid]

Wanswheel,

 

Thanks for posting that new information about the finalized tank car rules.  They told me yesterday that the rules would be released “soon,” but they would not say when.

 

So ECP brakes for oil trains are now mandated with a phase-in period.  I was expecting that.

 

It is interesting that the DOTs’ reasoning for ECP brakes is to mitigate damage after a derailment begins.  That sounds familiar.

 

The industry cited that as a reason to reject ECP brakes, claiming that fitting tank cars with ECP brakes would not prevent accidents, but merely limit the number of cars that derail in an accident.  But apparently, the regulators saw the obvious benefit of reducing the number of cars in a derailment, even if the derailment is not prevented in the first place.    

 

[wanswheel]

May 1 (Reuters) - The U.S. and Canada rolled out new oil railcar standards on Friday that require a new car design to be phased in and introduce more stringent speed limits and enhanced braking for tank cars to reduce damage in derailments.

Under the regulations, tank cars built after Oct. 1 must have thicker hulls, full-height headshields, thermal protection, and improved pressure valves. Existing tank cars must be retrofitted with these components.

The rule requires replacing tank cars known as DOT-111 for crude by rail within three years.

http://www.dot.gov/briefing-room/final-rule-on-safe-rail-transport-of-flammable-liquids

[Anonymous]

Norm48327

I believe Bucky's audience has left the theater.

 

https://www.youtube.com/watch?v=NmPhaG1ud38

 

 

 

[Norm48327]

I believe Bucky's audience has left the theater.