Wednesday, March 25, 2009

Reader Comments – 03-24-09 – Hazmat Routing

Fred Millar, a long time reader and commenter as well as a hazmat transportation consultant, provided comments on two recent blogs dealing with hazmat rail transportation issues. First he wants to correct some information that I provided on routes around Washington, DC and then he suggests information that I might want to dig up. I can always count on my readers to keep me on my toes. Alternate Rail Routes Fred pointed out that in my blog on potential new rail routes around Washington, DC that there was at least one Class 1 rail line that avoided the Washington DC-Balt-Philly-Newark-NYC metroplex. I will certainly bow to Fred’s superior knowledge of rail routes. When he tells me that the Norfolk Southern I81 corridor bypasses these cities (presumably to the west) I must presume that he is correct. The interesting point that this raises is that the ‘offending’ rail line running through Washington, DC is owned by CSX. This would mean that for a CSX customer shipping from say Eastern Virginia to New York State, CSX could run the load along its own lines to through one or more of these cities (I’m not sure where their lines actually run) or they could transfer the shipment to the Norfolk Southern line for the majority of the trip and bypass these urban areas. Of course, Norfolk Southern would presumably get the bulk of the shipping fee. One could see why CSX would be reluctant to share those revenues. This is, of course, the heart of the hazmat re-routing issue. There are a number of reasons why railroads do not want to transfer their customer’s railcars to other lines and most of them come down to revenue. Now railroads do transfer cars to other lines all of the time. Very few long distance rail trips stay completely on one carrier’s rails for the entire trip. But, it is only done when there is no ‘reasonable’ alternative; with ‘reasonable’ being defined by the railroad. To add to the complexity there is the problem of how to define a ‘safer route’. While most of us would assume that a route that bypasses high-threat urban areas (HTUA) would be safer than one that would go through such an area, the issue is more complex than that. Smaller cities would argue that they are also potential terrorist targets and are less able to afford the equipment necessary to respond to a major hazmat incident. Do longer transit times make a TIH railcar more susceptible to terrorist attack if the car avoids HTUA? Even with all of the potential complexities, I believe that the real basis for the lack of voluntary re-routing around HTUA comes down to money. The question comes down to how much money is re-routing worth? Section 333 Meetings Locally, railroads are monopolies. Typically a facility with a rail line has only one railroad that they can turn to to pick-up or deliver railcars from their facility. Where monopolies are necessary or inevitable, they are supposed to be closely regulated. Railroads are separate companies and are not supposed to communicate in a way that might look like they are fixing rates or otherwise regulating business. But railroads have to coordinate schedules and the like. To avoid the appearance of illegally setting rates there is a Federal Railroad Administration regulation that prescribes how and about what they can communicate. One of the approved communication tools is covered under 49 USC § 333. One area that railroads are supposed to be coordinating is the routing of hazardous material shipments so that they can reduce standing time and route around high-risk targets. In his second comment, made on the blog discussing the Chlorine Institute comments on the UP rate controversy before the STB, suggested that I should investigate the § 333 meetings between railroads and some shippers discussing these hazmat shipments. He is apparently concerned that ‘secret’ decisions made in these meetings may have been made without due consideration for public safety and security. I would certainly like to know more about any § 333 discussions about hazmat routing. But, I am not an investigative reporter. I do not have the funds or connections to travel around asking questions of people involved in these discussions. I have only ever talked, face-to-face with one railroad employee, the guy on the local train that brought railcars to our facility. Fred, I’ll try to see what I can find out, but you probably have better contacts than I do. Unless, of course, there is another reader that can point me in the right direction……

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