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PHMSARulemakingPHMSA-2012-0082

Hazardous Materials: Rail Petitions and Recommendations to Improve the Safety of Railroad Tank Car Transportation

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National Mining Association filed 1 comment on this docket between Oct 29, 2014 and Oct 29, 2014. 154 other organizations filed here. The comment window closed 3910d ago.

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Oct 29, 2014· National Mining Association - Comment· PHMSA-2012-0082-3375

September 30, 2014 Ben Supko Pipeline and Hazardous Materials Safety Administration U.S. Department of Transportation West Building, Ground Floor, Room W12-140 Routing Symbol M-30 1200 New Jersey Avenue SE. Washington, D.C. 20590 Re: Docket No: PHMSA-2012-0082 (hm-251): Hazardous Materials: Enhanced Tank Car Standards and Operational Controls for High-Hazard Flammable Trains Dear Mr. Supko, The National Mining Association (NMA) submits the following comments in response to the Pipeline and Hazardous Materials Safety Administrations (PHMSA) notice of proposed rulemaking to improve the regulations applicable to the transportation of hazardous materials by rail. The National Mining Association (NMA) is a national trade association that includes the producers of most of the nations coal, metals, industrial and agricultural minerals; the manufacturers of mining and mineral processing machinery, equipment and supplies; and the engineering and consulting firms, financial institutions and other firms serving the mining industry. NMAs members ship their products by rail throughout the United States and could be significantly impacted by the PHMSAs proposed rule. In fact, coal and mineral shipments account for over half of the total tonnage shipped by Class I railroads and approximately 30 percent of total gross freight revenue. Although the proposed rule applies primarily to the rail transportation of crude oil and ethanol, the nationwide footprint of the proposal could significantly impact the shipment of commodities which are not the focus of the rule, including those produced and transported by NMA members. Under the proposed rule, PHMSA would implement a nationwide speed limit of 50 miles per hour for all High Hazard Flammable Trains (HHFT) and a 40 mile per hour speed restriction for any HHFT unless all cars containing flammable liquids meet or exceed the standards proposed by DOT. While NMA supports efforts of PHMSA, the rail industry, and its shippers to develop safety protocol that protect our communities from the risks associated with the transportation of highly flammable materials, it is important to do so in an efficient and measured way. The trains subject to these restrictions share track with those carrying a host of other commodities of which NMA members comprise the total majority. As an interconnected network, the effects of the lost velocity on the rail network would be felt by all rail customers increasing transit times, costs to shippers, and resulting in greater railway congestion. Consequently, available growth capacity of the entire network could be significantly reduced and make adjusting for disruptions like severe weather increasingly difficult. Restoring the capabilities of the existing network could take many years and billions of dollars in additional capital expenditures. NMA encourages PHMSA to work with the rail industry and others to put in place essential safeguards without unnecessary and significant impacts to the interconnected community of rail customers. Thank you for considering these comments. Should you have any questions please feel free to contact me at (202) 463-2643 or aeckman@nma.org. Respectfully submitted, Adam Eckman Associate General Counsel National Mining Association

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Abstract

Hazardous Materials Railroad Tank Cars

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