Monday, August 18, 2008

Hazmat Route Restrictions

This appears to be the month for hazmat truck routings to make the news. Earlier we had the controversy over the Boston routing (see: “Federal Preemption of Hazmat Truck Routes”) and now we have an announcement by the Colorado State Patrol about changes to the Hazmat Routing due to the Democratic Convention. Through transport of controlled hazardous materials is prohibited on I25 from the junction with I225 in the south to the junction of I76 in the north.

 

Hazmat Routing for Trucks

 

With the continuing controversy over railroad routing of Hazmat shipments it is good to see that routing decisions for truck shipments raises much less heat. The main reason for this is the fact that it is easier to select alternative routes for truck transportation. The road network is much more extensive than the railroad network, allowing for more alternative routes.

 

While the US Department of Transportation retains the primary responsibility, via the interstate commerce clause of the Constitution, for hazardous route designations, they have delegated much of the authority for the day-to-day management of that system to the various state highway departments. As I mentioned in last weeks blog on this matter, the federal rules provide fairly detailed guidance for the procedures for selecting and establishing Hazmat routes.

 

Railroad Routings are More Complicated

 

The Department of Transportation is still trying to determine how to deal with the question of routing hazardous rail shipments (see: “Comments on Rail Security and Safety Rules – 5-16-08”). Until they can come up with a coherent set of rules and standards to govern the routing of hazardous materials, they will not be able to delegate any of their authority to state agencies.

 

Limited track routings are not the only reason why re-routing of hazmat rail shipments is not nearly as simple as truck routings. Another reason for the increased complications for rail routings is that the vast majority of shipments made by rail are not ‘through’ shipments. Through truck shipments usually transit an urban area without stopping (other than routine traffic stops). Most rail shipments enter an urban area, spend some time in a local rail yard where the train composition is modified (various railcars removed from or added to the train), then (some variable time later) departs that urban area.

 

The reason that these rail yards are in the middle of urban areas is that the cities have grown-up around the transportation infrastructure. Railroads bought the land when it was cheap, or in the case of many western railroads, were given the land by the Federal government. The cost of moving these rail switching yards out of urban areas would be very high.

 

An additional problem is that for the most part each railroad company owns its own tracks and switching yards. There are agreements for sharing the use of such facilities, but they are limited and carefully negotiated. The cost of construction of new switch yards outside of urban centers and rail lines around those centers would have to be borne by the railroads.

 

Buy-out Switch Yards

 

There have been some discussions in a variety of cities about buying out the rail yards in urban areas. This is being done, not out of concern about hazardous materials in urban yards, but because these switch yards are the last pieces of ‘free land’ available in the central urban areas. Developers want to build on these areas.

 

Buying out these switch yards would have many benefits. The obvious is new land for development near the urban center. The railroads could design a more efficient switching network instead of the systems that have grown through a variety of technological eras. Storage of Hazmat railcars during the switching process would be removed from urban population concentrations. Finally, security for the rail switching yard could be included in the design process, increasing its effectiveness.

 

There are a number of impediments to the transfer of these switching yards. First there is the requirement for the relocation of most of the main line and short line routes leading to the rail yard. The next issue to be addressed is what to do with the industrial facilities that have located adjacent to the switch yards and rail lines over the years. Finally the environmental clean up of the numerous fuel, lubricant, and chemical spills that have taken place over the years must be addressed.

 

Urban Destination Shipments

 

Even providing adequate rail lines around urban areas and moving switching yards to the outskirts of suburbia will not stop hazmat shipments in urban areas. There will always be industrial facilities within the urban area that will require the use of hazardous chemicals. Some of these will be delivered by truck and others by rail lines. Adequate safety and security provisions will still be required to protect these shipments and the surrounding populace.

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