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500 Fifth Street, NW, Washington, DC 20001 Phone 202.334.2934 www.TRB.org October 26, 2016 The Honorable Anthony Foxx Secretary U.S. Department of Transportation 1200 New Jersey Ave, SE Washington, DC 20590 Dear Secretary Foxx: In response to a request from Congress in the Fixing Americaâs Surface Transportation (FAST) Act, the National Academies of Sciences, Engineering, and Medicine have formed the Committee on the Review of Department of Transportation (DOT) Testing of Electronically Controlled Pneumatic (ECP) Brakes. The committee is preparing a letter report that addresses the first phase in the statement of task (Appendix A). This report will review the plan prepared by DOT to test the assumptions that the department has identified in its comparison of the emergency braking performance of railroad tank car ECP brakes with that of other braking systems.1 Completion of the letter report is expected by the end of this year. The FAST Act also requires the Secretary of Transportation to incorporate the results of the testing mentioned above into a determination of whether the ECP braking system requirements in the Hazardous Materials: Enhanced Tank Car Standards and Operational Controls for High-Hazard Flammable Trains; Final Rule (May 8, 2015) are justified. The Secretaryâs determination is to be made by December 2017. The committee understands that the need to meet the congressional deadline has motivated DOT to begin implementing its test plan before it receives the committeeâs letter report. After receiving that report, DOT would consider additional tests that might be needed in response to the committeeâs recommendations. At the committeeâs information-gathering session held on October 14, DOT representatives presented an informative overview of the substantial analyses that were conducted in developing DOTâs current requirement for ECP brakes and the departmentâs plan for additional analysis and testing. After considering the information presented at the session and the accompanying written materials, the committee has questions about whether the proposed tests target the most important assumptions in assessing the emergency performance of alternative unit train braking systems. The committee is gathering additional information and carrying out an analysis that will be explained in its forthcoming letter report, which will undergo an independent external review in accordance with the National Academiesâ study process. Because the committee is concerned that conducting additional tests without consideration of its advice might result in the inefficient use of limited resources, the committee recommends that DOT suspend its testing activities until the committeeâs report has been issued. The committee believes that such an approach will help ensure that the most important assumptions involved in the comparison of braking systems are identified and tested. I would be happy to discuss this matter with you at the earliest time we are both available. Sincerely, Louis J. Lanzerotti Committee Chair cc: Trevor Dean, DOT/FRA Kevin Kesler, DOT/FRA 1 DOTâs plan is presented in Appendix B.
Appendix A Review of Department of Transportation Testing of Electronically Controlled Pneumatic Brakes Project Scope In the first phase of this project, an ad hoc committee will review a test and analysis plan prepared by DOT and comment in a letter report on whether the proposed tests will provide objective, accurate, and reliable results to test the assumptions that DOT has identified in its comparison of the emergency braking performance of railroad tank car electronically controlled pneumatic (ECP) brakes to conventional brakes or braking systems such as distributed power and two-way end-of-train devices. The committee will provide a written explanation detailing the need for any additional or alternative testing. The key question is whether ECP brakes would reduce the incidence and severity of spills of crude oil or ethanol from derailments compared with the alternative braking systems examined. In the second phase of this project, the committee will review the conduct of DOTâs tests, reports of test results, and, based on DOTâs test results and analysis, provide its findings and conclusions addressing the performance of ECP brakes relative to other braking technologies or systems tested by DOT. The committeeâs reviews and letter reports will be limited to these tasks; the committee will not make recommendations about which braking systems should be required of railroads in revenue service.
Appendix B Analysis and Test Plan to Assess the Effectiveness of ECP Brakes in Reducing the Risks Associated with High-Hazard Flammable Trains Version 0.9 with notes on status September 19, 2016 [The plan and brief notes on status were provided by Kevin Kesler, Federal Railroad Administration, on October 11, 2016.] 1. INTRODUCTION Section 7311(b) of the Fixing Americaâs Surface Transportation Act (FAST Act) directs the Secretary of the Department of Transportation (DOT) to conduct tests to provide data to inform a review of the costs, benefits, and effects of Electronically Controlled Pneumatic (ECP) brakes that were used in the Regulatory Impact Analysis (RIA) for the âEnhanced Tank Car Standards and Operational Control for High-Hazard Flammable Trainsâ final rule (HHFT Rule; 80 FR 26643) published on May 8, 2015. DOT developed this analysis and test plan to provide the necessary data to allow the Secretary to determine if ECP brakes are justified. The plan involves additional analysis (including computer simulation) and full-scale, physical tests. DOT has contracted with the Transportation Research Board (TRB) of the National Academy of Sciences to provide independent oversight of the planned analysis and test work. TRB has formed a committee of experts to: 1. Familiarize itself with the analysis and testing that DOT relied upon for the HHFT Rule; 2. Review the detailed test and analysis plan DOT proposes and, in a letter report, confirm it meets the FAST Actâs requirement to âobjectively, accurately, and reliably measure the performance of ECP brake systems relative to other braking technologies or systems, such as distributed power and 2-way end-of-train devicesâ or recommend changes; 3. Review and oversee the testing procedures used by DOT or its contractors; 4. Review the test reports provided by DOT following the completion of testing and hold an open meeting to discuss the results; and 5. Provide a final letter report to DOT analyzing results of the testing and making findings and conclusions. The output from the analysis and testing described in this plan will be a series of reports describing methods and results. DOT will use the results, once confirmed by the TRB committee, to update the discussion of ECP brakes in the RIA for the HHFT Rule. DOT has contracted with suppliers to conduct the analysis and testing specified in this plan. Some of the tests are to be conducted at the Federal Railroad Administrationâs (FRAâs) Transportation Technology Center in Pueblo, Colorado, due to the unique testing infrastructure available at the facility.