An article published March 28 on the website of the Sightline Institute follows up on an Associated Press report from over the winter about the Department of Transportation’s repeal of the Federal Railroad Administration’s electronically controlled pneumatic (ECP) brake rule for tanker cars.
In late December, the AP reported that the Trump administration did not consider in its calculations the most-common type of derailment.
In addition to the AP findings, writers Aven Frey and Eric de Place for the Seattle-based Sightline Institute, which advocates on sustainability and environmental issues in the Pacific Northwest, also said that “PHMSA and the FRA low-balled their predictions for oil train numbers, an assumption that tilted the analysis in favor of the industry.”
SMART Transportation Division has been in favor of the installation of ECP brakes on tanker cars, with National Legislative Director John Risch calling them “the safest, most advanced braking systems in the world.”
The Sightline Institute piece notes that the ECP rule’s repeal “put rail-side communities at substantial risk across the Northwest, particularly because we can expect to see oil train shipping to significantly increase again.”
In response to the repeal of the ECP rule, legislators in the region have taken note.
The Washington State Senate has passed legislation that requires crude oil to be transported by rail to be conditioned to meet a vapor standard that reduces the potential for explosive ignition.
Also, U.S. Rep. Jaime Herrera Beutler, a Republican from Battle Ground, Wash., has twice introduced legislation that reinstates the ECP rule. The current version of the Oil and Flammable Material Rail Safety Act is H.R. 851 and was introduced in January.
Read the entire Sightline Institute article here.
Tag: ECP brake technology
The Associated Press reported Dec. 20 that an analysis by the federal Department of Transportation (DOT) did not take into account up to $117 million in damage reductions when considering the repeal of a Federal Railroad Administration (FRA) rule requiring the installation of electronically controlled pneumatic (ECP) brakes on tanker cars.
The DOT repealed the 2015 rule requiring the installation of the advanced braking system on DOT-117 tank cars that carry explosive fuels in late 2017.
AP reviewed federal documents and found that the damage estimates used by the DOT varied widely between the Obama administration, which enacted the ECP rule, and the Trump administration, which repealed the rule.
“Under Obama, the Transportation Department determined the brakes would cost up to $664 million over 20 years and save between $470 million and $1.1 billion from accidents that would be avoided,” the AP’s Matthew Brown wrote. “The Trump administration reduced the range of benefits to between $131 million and $374 million. Transportation department economists said in their analysis that the change was prompted in part by a reduction in oil train traffic in recent years, which meant there would be fewer derailments. But in making their calculations, they left out the most common type of derailments in which spilled and burning fuel causes property damage but no mass casualties …
“Department of Transportation officials acknowledged the mistake after it was discovered by the AP during a review of federal documents, but said it doesn’t change their decision not to install the brakes,” Brown wrote.
SMART Transportation Division supported the ECP brake rule for the safety benefits that would have been gained and in Nov. 2017 National Legislative Director John Risch made detailed comments to the Pipeline and Hazardous Materials Safety Administration (PHMSA) in support of ECP braking technology.
The Association of American Railroads had lobbied for repeal of the rule since its 2015 inception.
Read the complete Associated Press story.
The Bellingham Herald reports that last week the Department of Transportation’s Pipeline and Hazardous Material Safety Administration (PHMSA) decided to repeal a rule that required electronically controlled pneumatic (ECP) braking systems be installed on all oil trains.
The original rule was intended to increase safety and help prevent the derailment and puncturing of cars. DOT’s original analysis of ECP brakes found that they “can reduce the number of cars in a derailment that puncture and release their contents by almost 20 percent compared to other braking technologies.”
With conventional air brakes, the braking message must go through each car individually before moving on to the next car; this process can take up to two minutes for the brake application to reach the back of a freight train. ECP braking uses electronic controls that applies the brakes to all cars consistently and at the same time, providing more control and shortening the stopping distance, which leads to a lower risk of derailment or coupling breakage.
Washington state Governor Jay Inslee criticized the repeal, saying in a press release that the decision to repeal is a “reckless disregard for the life and property of all who live or work along the rail tracks.”
“I fear the day we witness a destructive or deadly derailment that could have been prevented with readily available technology,” he said.
The PHMSA cited a reduction in benefits to the rail carriers from $254 million in benefits to businesses and $215 to $358 million in savings related to safety when the first analysis of ECP braking was done, down to $131 to $198 million in total benefits, as the reason for their repeal of the rule. PHMSA said the lower estimates stem from a decrease in the amount of oil being transported by rail.
The Association of American Railroad (AAR), an organization representing rail carriers, praised the repeal, while Inslee, environmental groups and unions protest this reduction in safety.
Click here to read the full story from the Bellingham Herald.
In a blow to safety, the U.S. Department of Transportation (DOT) repealed a 2015 Federal Railroad Administration (FRA) rule that required railroads to implement electronically controlled pneumatic (ECP) braking technology on trains hauling hazardous flammable contents.
“Clearly the railroad industry’s overwhelming influence over the Trump administration is paying off in repealing the ECP brake rule,” said SMART TD National Legislative Director John Risch. “ECP brakes are the safest, most advanced braking systems in the world and without some government requirement we will continue to use our current, outdated 150-year-old braking technology for the foreseeable future.”
The ECP brakes mandate was part of the 2015 rulemaking on DOT-117 tank cars. The rule stated that trains meeting the definition of a high-hazard flammable unit train (HHFUT) with at least one tank care with Packing Group I materials must be operated with ECP brakes by Jan. 1, 2021, or face reduced maximum speeds. All other HHFUT’s were required to have the system installed after 2023. DOT defines HHFUT as a single train with 70 or more tank cars loaded with Class 3 flammable liquids.
The Association of American Railroads has been lobbying for repeal of the rulemaking since its 2015 inception.
In Nov. 2017, Risch made comments to the Pipeline and Hazardous Materials Safety Administration (PHMSA) in support of ECP braking technology. Click here to read those comments.
These comments are on behalf of the Transportation Division of the International Association of Sheet Metal, Air, Rail and Transportation Workers (SMART). The SMART Transportation Division, formerly the United Transportation Union, is an organization representing approximately 125,000 transportation employees with active rail members in all operating crafts, including engineers, conductors, trainmen, switchmen and yardmasters.
This is in response to the PHMSA’s request for additional information regarding its current regulations on Electronically Controlled Pneumatic (ECP) braking systems.
As a locomotive train engineer for 30 years who has operated trains with ECP brakes, I can attest that ECP brakes are the greatest safety advancement I have seen in my 40 years in the railroad industry. ECP brakes slow and stop trains up to 70 percent faster than conventional brakes and are the safest, most-advanced train braking system in the world.
The most recent analysis of ECP braking systems has focused almost exclusively on comparing ECP brakes with conventional braking systems during emergency brake applications. The analysis also evaluated conventional brakes with distributed power, which is a small aid to conventional brake systems. I readily admit that ECP brakes are only slightly better than conventional brake systems during emergency brake applications. But reviewing ECP brakes only as they apply to emergency applications is a mistake because emergency brake applications on freight trains are a rare event. PHMSA needs to consider other very significant safety benefits that ECP brakes provide in the safe movement of trains.
The most recent ECP review was unnecessary and was a response by Congress to demands from the nation’s railroads to repeal the rule. ECP brakes have been studied and analyzed for years, and the jury is in — if we truly want to take rail safety to a higher level, ECP brakes are the means by which to do so.
The latest study focused on one aspect of ECP brakes because in emergency applications ECP brakes are only slightly better than conventional brakes and would not justify the entire costs of their installation. The real failure will be if PHMSA does not look at comprehensive analyses of ECP brakes that have already been done on freight train operations. This can be corrected by reviewing past studies, including FRA’s final report titled ECP Brake System for Freight Service that was produced by Booz Allen Hamilton and released in August 2006.
Conventional train air brake systems are a 140-year-old technology that has evolved to its maximum capabilities. You can add dynamic braking, which has been around since the 1930s, and you can add distributive power, which has been around since the 1990s, to conventional air brakes, and you gain slightly in improved braking. But the only dramatic advancement to improve a freight train’s braking ability and safety is from ECP brakes. As a locomotive engineer, operating a train with ECP brakes is like driving the new top-of-the-line Tesla while operating a freight train with outdated conventional brakes is like driving a 1974 Ford Galaxie 500. The differences are that significant and substantial.
Below are 11 key reasons why ECP brakes are better than conventional air brakes:
- ECP brakes maintain a train’s brake pipe pressure 100 percent of the time, conventional brakes do not.The colder the weather, the thinner the air, the more crucial maintaining brake pressure is.
- ECP brakes allow for a “graduated” release. An engineer can partially release the train’s brakes without having to fully release them. This is vitally important because once a train’s brakes are released, it takes time to recharge the train’s brake pipe pressure in order for the brakes to work again. The graduated release feature allows an engineer to maintain the speed of his/her train down steep grades with a partial application of the brakes and without fully releasing and reapplying the train’s brakes repeatedly.The graduated release feature all but eliminates the possibility of a runaway train.
- When the engineer makes an emergency application of the brakes, every car with ECP brakes applies its brakes 100 percent of the time.This is not always true with conventional brakes.
- ECP brakes would have prevented the terrible Lac-Megantic oil train tragedy that killed 47 people and destroyed the town, a factor cited in Transport Canada’s report on the accident.These brakes would have prevented the accident because when air pressure on a car equipped with ECP brakes drops below 50 psi, the car automatically goes into emergency. Therefore, even an improperly secured train will not roll away.
- ECP brakes allow the crew to monitor every car in the train in real timeto determine if the brakes are applied or released. Conventional brakes do not.
- ECP brakes record retrievable data associated with brake failures.There is no such review for conventional brakes. Trains are inspected every 1,000-1,800 miles, and if the brakes are working during the inspection, the car moves on. If a car has brakes that fail to apply during that inspection, the car is taken to a repair facility. Often, that facility is a heated shop where the car warms up. The brakes are then tested, and if they work at that point, the car is not repaired and instead placed back in the train.
- ECP brakes all but eliminate in-train forces because all the cars apply and release at once.Conventional brakes create a multitude of in-train forces, some of which damage couplers, knuckles, draft rigging and merchandise. These in-train forces also cause break-in-twos and derailments.
- ECP brakes cause all cars to brake evenly, which dramatically reduces damage to wheels and brake shoes, saving a great deal of money in maintenance and repair.Conventional brakes do not. The modest cost of installing ECP brakes, approximately $3,000 per car on a new DOT 117 tank car that costs $144,000 to build, and about $60,000 per locomotive, will be more than paid for in the savings in car repairs, let alone reduced train derailments.
- ECP brakes can be modified to apply hand brakes to a railcar automatically from the locomotive, allowing the crew to apply a hand brake on every car in the train in seconds.Conventional brakes must be applied by hand, and it can take an hour or more to properly secure a train.
- ECP brakes are required by the American Association of Railroads (AAR) for the movement of nuclear waste trains because they are the safest braking system available.
- ECP brakes can be modified and will evolve to do everything sophisticated wayside train detectors do nowand will do it in real time, eventually eliminating the need for wayside detectors.
For the safety of rail workers and the residents in surrounding cities and towns that trains run through, it is vital that ECP brakes be phased in on freight trains. We ask that PHMSA retain the final rule so we can gradually and cost effectively evolve our antiquated, outdated freight train braking systems into the best they can be.
In addition, we request that PHMSA hold a public hearing where I can explain in detail the benefits of ECP brakes and answer any questions the agency might have.
Thank you for the opportunity to comment.
John Risch
National Legislative Director
SMART- Transportation Division
WASHINGTON – John Risch, SMART TD National Legislative Director, participated in hearings as a member of the Roundtable on Emerging Railroad Technologies on March 21, 2017. Discussion focused on new and emerging trends in railroad safety including train crew size, recent advancements in train brake technology, and early warning systems.
“Thank you Chairman Schuster, Subcommittee Chair Denham, and Ranking Member Capuano for inviting me to the roundtable discussion on emerging railroad technologies. With nearly 40 years in the railroad industry, I was pleased to have the opportunity to discuss the importance of maintaining minimum crew sizes, implementing Positive Train Control (PTC), and most importantly investing in the installation of Electronic Controlled Pneumatic (ECP) brakes, which are vital to safety of our railroads,” said John Risch, SMART-TD National Legislative Director.
“I look forward to working with the members of the committee to improve railroad safety as we discuss opportunities to strengthen our nation’s infrastructure,” Risch continued.
Click here to read Risch’s complete notes from the hearing.
Click here for information on participants and to view video.