WASHINGTON — The Association of American Railroads says long freight trains are safe and has told the Federal Railroad Administration that there’s no need for an emergency order that would cap train length at 7,500 feet.
The Brotherhood of Locomotive Engineers and Trainmen on Oct. 9 called on the FRA to limit train length, claiming that trains longer than 7,500 feet pose an immediate safety hazard.
“Respectfully, there is no emergency,” Ian Jefferies, the AAR’s president, wrote in a letter to FRA Administrator Amit Bose on Oct. 12. “Railroads have safely operated millions of trains in excess of 7,500 feet over the last eight decades. Experience shows that these trains are safe. As such, there is absolutely no safety justification for the extraordinary step of an emergency order.”
The FRA issued a pair of non-binding safety advisories in April — one covering train makeup and one on the complexities of operating long trains — in the wake of several derailments that were related to a combination of train handling, train length and weight, and how tonnage was distributed throughout trains.
The FRA issues safety advisories to raise awareness and promote discussions around safety concerns, while an emergency order has the binding effect of a regulation and requires a higher burden of proof.
The April 27 train length advisory urged railroads to take steps to address the complexities of operating long trains. It was issued after three recent derailments involving trains with more than 200 cars, a length of 12,250 feet or more, and a weight over 17,000 tons.
“Since that time, nothing has happened to suddenly justify emergency action by FRA,” Jefferies wrote. “None of the derailments cited in BLET’s letter or FRA’s Safety Advisory were determined to have been caused by excessive train length. With the exception of the derailment in East Palestine [Ohio], which involved an overheated bearing, all involved train makeup or train handling issues.” (It should be noted that the National Transportation Safety Board has yet to issue reports on the cause of three of the four incidents cited in the BLET’s letter.)
The Class I railroads use a variety of methods to ensure safe operations, including train marshaling rules and the use of distributed power to manage in-train forces, AAR said. The railroads also require locomotive engineers to demonstrate in simulators that they can safely operate long, heavy trains before becoming qualified on a specific territory, AAR said.
The U.S. Class I railroads have increased train lengths since 2017 as part of a strategy to move tonnage on fewer but longer trains. Operating longer trains increases fuel efficiency and reduces the production of greenhouse gas emissions, AAR said, while also improving grade crossing safety by reducing the number of trains.
Mainline derailments have not increased since 2017, but the April FRA safety advisory said officials had “noticed a rising trend in recent incidents where train build and makeup have been identified as a potential cause or contributing factor.”
Recent studies that examined train length found no correlation with derailment rates, AAR noted, pointing to a 2019 Government Accountability Office report and a 2022 FRA report on Precision Scheduled Railroading.
“FRA’s Class I accident data for mainline accidents shows that over the last decade and across the system, accident rates have decreased as train length has increased,” Jefferies wrote.
The overall mainline accident statistics, however, do not show whether trains over 7,500 feet derail more or less often than trains under 7,500 feet.
Two years ago Congress funded a National Academies study on trains longer than 7,500 feet, which is currently under way. Congress also mandated that FRA collect accident and incident data on crew size and train length. Separately, FRA has begun a study of air brake performance in longer trains.
The FRA in July proposed requiring the Class I railroads to provide monthly data that tracks train length and tonnage as well as the number of reportable accidents for trains over and under 7,500 feet.
The FRA says it wants to use the data to better understand the impact of train length on safety and whether trains over a certain length are disproportionately involved in derailments or incidents such as stalls or a loss of communications.
In public comments submitted to the FRA, representatives from Amtrak, rail labor unions, the Illinois Commerce Commission, and the Chicago-area Coalition to Stop CPKC all backed the train-length data collection proposal.
The AAR opposed the rule proposal, arguing that the data collection would be burdensome, its low accident reporting threshold would make comparison with other years difficult, and that it undermines the FRA’s own proposal to mandate crew size.
An FRA spokesman said the agency is working on a response to the BLET’s train-length letter.
