Link to this: https://billhustonpodcast.blogspot.com/2020/01/lng-by-rail-comments-by-environmental.html
I was asked to do some research and find interesting objections to PHMSA's LNG by Rail Rulemaking presently before PHMSA, such as comments made by big environmental groups. I put some files up on Dropbox and gave links below to browse online, or to download the entire set.
There are the two related dockets:
I'm not sure if this is all of the big groups, but this should
give you a good idea of the top objections.
Right now, here's what's there:
https://www.dropbox.com/sh/gwv6v7tupqdehjk/AADA2gBev2deyH4-MjeM9vW3a?dl=0
Download these all at once: (recommended from a desktop computer)
https://www.dropbox.com/sh/gwv6v7tupqdehjk/AADA2gBev2deyH4-MjeM9vW3a?dl=1
I find reading these like a crash course in learning about the issue.
Commentary on the Special Permit
The only reason the Special Permit is needed, is because there is
presently no US DOT approved package for transporting LNG by rail.
Thus, a SP is needed to actually transport LNG by rail by EXEMPTING THE OPERATOR
from complying with the law regarding approved packages for HAZMAT.
My friend Ron Barton (NYS DOT, retired) says this SP has very restrictive permit
conditions, which will be very costly for the operator to implement.
He says (in his expert opinion) it will be very unlikely this SP will ever be used, for multiple reasons.
Another concern is the lack of the railcars. Ron told me this, and then this appeared confirming:
"PHMSA said moving LNG by rail would be no different than other flammable cryogenic liquids already authorized for bulk rail transport. NTSB, however, found very few DOT-113 cars (405), commonly used for cryogenic ethylene service, are available. Even fewer (67) exist that meet the specifications PHMSA is considering for LNG transportation."
https://www.naturalgasintel.com/articles/120760-ntsb-sounds-alarm-on-proposal-to-authorize-lng-by-rail-across-us
IF PHMSA adopts these proposed rules, the legal effect will be to make
the DOT-113 variant railcar an approved package for LNG, thus making the Special Permit obsolete.
Another important consideration is liability.
The Special Permit places all of the liability on the shipper
(Energy Transport Solutions, LLC. Doral, FL, one of 71 different subsidiaries of New Fortress Energy)
Whereas, once the DOT-113 becomes an approved package for LNG, the
liability shifts to the railroad operator.
Hope this is helpful,
BH
--
William Huston: WilliamAHuston@gmail.com
Binghamton NY
I was asked to do some research and find interesting objections to PHMSA's LNG by Rail Rulemaking presently before PHMSA, such as comments made by big environmental groups. I put some files up on Dropbox and gave links below to browse online, or to download the entire set.
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There are the two related dockets:
- LNG by Rail Special Permit PHMSA-2019-0100
(CLOSED, SP has been issued)
This is given for completeness only. This SP docket concerns LNG
by Rail also, but is unrelated to the Notice of Proposed Rulemaking (NPRM).
- LNG by Rail NPRM PHMSA-2018-0025
This is the docket I was harvesting for comments.
FYI, Here is the Notice of Proposed Rulemaking.
Here is the petition for the rule made by the American Association of Railroads.
I'm not sure if this is all of the big groups, but this should
give you a good idea of the top objections.
Right now, here's what's there:
- 350 dot org, PSR, et. all. joint comments, w/comments on the Special Permit
- DRN
- EarthJustice joint comments, w/attachments
- National Assoc of State Fire Marshalls
- NTSB
- DCS
https://www.dropbox.com/sh/gwv6v7tupqdehjk/AADA2gBev2deyH4-MjeM9vW3a?dl=0
Download these all at once: (recommended from a desktop computer)
https://www.dropbox.com/sh/gwv6v7tupqdehjk/AADA2gBev2deyH4-MjeM9vW3a?dl=1
I find reading these like a crash course in learning about the issue.
Commentary on the Special Permit
The only reason the Special Permit is needed, is because there is
presently no US DOT approved package for transporting LNG by rail.
Thus, a SP is needed to actually transport LNG by rail by EXEMPTING THE OPERATOR
from complying with the law regarding approved packages for HAZMAT.
My friend Ron Barton (NYS DOT, retired) says this SP has very restrictive permit
conditions, which will be very costly for the operator to implement.
He says (in his expert opinion) it will be very unlikely this SP will ever be used, for multiple reasons.
Another concern is the lack of the railcars. Ron told me this, and then this appeared confirming:
"PHMSA said moving LNG by rail would be no different than other flammable cryogenic liquids already authorized for bulk rail transport. NTSB, however, found very few DOT-113 cars (405), commonly used for cryogenic ethylene service, are available. Even fewer (67) exist that meet the specifications PHMSA is considering for LNG transportation."
https://www.naturalgasintel.com/articles/120760-ntsb-sounds-alarm-on-proposal-to-authorize-lng-by-rail-across-us
IF PHMSA adopts these proposed rules, the legal effect will be to make
the DOT-113 variant railcar an approved package for LNG, thus making the Special Permit obsolete.
Another important consideration is liability.
The Special Permit places all of the liability on the shipper
(Energy Transport Solutions, LLC. Doral, FL, one of 71 different subsidiaries of New Fortress Energy)
Whereas, once the DOT-113 becomes an approved package for LNG, the
liability shifts to the railroad operator.
Hope this is helpful,
BH
--
William Huston: WilliamAHuston@gmail.com
Binghamton NY
Public Service Mapping /
Videography / Research /
Education / Safety Advocacy
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