Ok, but…

The final rule came out last week on tanks cars and trains carrying crude oil and ethanol. For the most part, the rule was pretty reasonable, but in one area, we are all left scratching our heads and going “what?”The new tank car specification, 117, will definitely result in a safer car. It is stronger, less likely to leak when in a derailment due to valves sheared off, and if in a fire will survive intact longer due to enhanced thermal protection. Also in the rule is better identification of exactly what is in the cars, and better identification of the hazard they contain. There are also some other parts including speed restrictions and routing assessments, but the one that has caught my attention is the rule on Electronically Controlled Pneumatic (ECP) brakes.What are ECPs? Well, let’s first take a step back. Way back, in fact, to 1869, and the introduction of the air brake by George Westinghouse (yes, that Westinghouse). All air brakes since the invention of the air brake have worked the same way: reduce the air pressure in the brake pipe, and the brakes will apply. This has served the rail industry well for over 150 years, because it is a fail-safe system. If the brake pipe pressure is lost suddenly, such as in an uncoupling or accident, the brakes will apply. Where the drawback is today, is that the system, by nature of its simplicity, can be slow in applying all of the brakes in a train, because the drop in air pressure in the brake pipe has to travel the length of the train (upwards of 100 cars) to tell the brakes to apply. The delay is brake application in a train can cause the hind cars in a train to run in towards the front of the train, and actually push the train while it is trying to slow down. This also puts huge stress on the cars in the train itself through the couplers and draft gear, and can cause flat spots on the wheels of the cars, which shortens the life of the wheel and of the track it rides on.ECPs change the technology of air brakes by doing the communication portion of the brake control over a wire. The brake pipe just supplies air to the brakes, and the brakes will apply on a train almost simultaneously. Yes, this is a big improvement over what George invented back in the 19th century, but it comes at a cost. First of all is the money. To equip a locomotive with ECP, I have seen estimates of $20-$100,000, all depending on the age of the locomotive. Cars, $5-$15,000 per car. Next is the fact that every car in the train must be equipped with ECP brakes for the system to work. Third is while there is an AAR standard for the brakes from one manufacturer to be interoperable with the brakes from another manufacturer, no railroad has been actually able to make that happen at this time.Adding to all of this is that there are technologies that are being used today that can just about replicate or in some cases exceed the performance of ECP brakes. Distributed power and two-way end of train devices can shorten the brake application time of conventional air brakes, and they don’t require any modification to existing braking systems. They also don’t require reprogramming of the braking curves in a PTC system, and are being used today effectively. But that didn’t change the minds of the rule makers…There is a carve-out for a non-equipped train, and that is a speed limit of 30 mph. In fact, they mention in the rulemaking that this is specifically for small railroads. What they didn’t take into account is that there are 160 short line railroads carrying crude or ethanol, and 30 mph could really put a crimp into their operations, without reducing risk.While it might look like the FRA might have taken a step too far in making this set of rules, let me propose that they might have been a little short sighted in the pocketbook. Railroads are scrambling to introduce and deploy PTC right now, throwing money and resources at the implementation so that they can reduce the overall risk to operate their railroads, and now they have been handed another unfunded mandate to reduce risk that will have to get in line behind PTC. Back in the 1980’s there was a movie based on Tom Wolfe’s book The Right Stuff, and the famous line from that movie discussed the importance of funding to make (in this case, the space program) projects happen: “No bucks, no Buck Rogers.” It is definitely time for the government to make the dollars available if they want us to carry out their safety and risk management ideals.---By Steve Friedland
steven-fb.jpgSteve Friedland is a child of the railroad industry. Following summers and vacations working on the track gang for the family-owned Morristown & Erie Railway, a 42-mile New Jersey short line, he started full-time in 1994. He has worked in all areas of the railroad, including track, mechanical, signals, and operations, and currently is a member of the management team for the company as director of operations in Morristown, N.J. In 1999, he founded Short Line Data Systems, a provider of railroad EDI and dispatching software, AEI hardware, and management consulting to the short line industry. He currently serves as the ASLRRA representative to the AAR's Wireless Communications Committee and is chairman of the joint AAR-ASLRRA Short Line Information Improvement Committee. He also is a member of the ASLRRA's board of directors.