Public Comment To The PHMSA Urging The Authorization To Transport LNG By Rail As A Standard Cargo

ANRP Submitted the Following Comment in Support of the Proposed Federal Rule to Authorize the Transportation of Liquified Natural Gas by Rail

23 December,

Submitted 23.DECEMBER.2019 To
Docket #PHMSA-2018-0025 9 (HM-264)

Dear Administrators,

Atlantic Northeast Rails & Ports serves to inform the railroad logistics industry and policy makers in the northeast United States, as a primary source of current information on regional rail and port activity.

On behalf of our readership at large, Atlantic Northeast Rails and Ports calls upon the PHMSA to allow the transportation of LNG by rail, subject to appropriate safety regulation. The transportation of LNG by rail will: 1. Increase the public safety on the roads, 2. Reduce the risk of wintertime public energy security failures in the northeast region; and 3. Accelerate LNG’s adoption by industry as a replacement for prevalent, “dirtier” industrial fuels.

1. Allowing LNG transportation by rail would reduce a hazard on the public roads

One effect of the decades-long public investment in highways has been to transfer all manner of legal loads – from the most innocuous to the most dangerous cargoes – off of private, controlled railroad rights-of-way, and on to the public roads, alongside millions of daily commuters, schoolbuses, vacationing families, etc. Today, LNG is legally transported by truck, but not by rail despite the fact that, of the ten states with the highest road accident rates, five are New England states {}

Railroads have demonstrated that, in congested regions, they are a safer mode for heavy freight than trucks. Railroads have further demonstrated that they can safely transport LNG in Alaska and Florida as locomotive fuel. A rail shipper recently received special PHSMA permission to ship LNG in unit train consists over state lines. Railroads in Canada, Europe, and Japan transport LNG as a regular cargo.

2. Allowing LNG transportation by rail would prevent potential winter energy shortages in the northeastern U.S.

In 2000, 34% of New England’s electricity was sourced from coal and fuel oil. By 2018, that percentage was down to two per cent {ISO New England}. Natural gas accounts for most of the replacement fuel.

A drawback to coal and oil displacement is the lack of stored fuel available in case of system surge and/or failure. Coal and oil can be stored indefinitely on-site, serving as an immediate supply of stable, ready fuel against contingencies. Currently, nearly all natural gas is delivered to generator stations via pipes. In the case of a flow interruption, the “supply” in the pipeline runs out very quickly — as happened this past January in Rhode Island, when an upstream glitch left 9000 households were left with no gas in the dead of winter. Political opposition to new pipeline projects has increased the secular risk of inadequate gas transmission capacity.

Allowing LNG to be delivered by rail substantially mitigates these risks. Large quantities of LNG can be both efficiently delivered in railcars, and indefinitely stored on-site at generating stations. Empty cars can be efficiently replaced using well-established logistic patterns.

3. Allowing LNG transportation by rail would accelerate the adoption of low-GHG natural gas by industry sites that still rely on oil and coal.

Even today, there remain coal-fired generator and industrial plants that cannot readily access the gas pipeline infrastructure. The Merrimack Station in Bow, NH relies on coal to fulfill its role of meet peak seasonal demand. It is separated from the nearest pipeline by distance and the Merrimack River. But it does have an extensive internal rail network, thanks to its historic reliance on unit train coal deliveries. The site can safely store dozens of rail cars, and could develop its coal yard to hold many more. Allowing LNG transportation by rail would allow Merrimack Station, and other sites like it, to convert quickly and cheaply to natural gas fueling.

When we will achieve zero GHG emissions from energy production is a question no one can legitimately answer. But the answer to the question of when we will be able to start cutting fossil fuel emissions is, right now — by converting our traditional power generation plants from dirtier coal and oil to cleaner natural gas. To achieve that requires the capacity, safety, and flexibility of rail-delivered LNG. We urge that the Administration quickly approve the US DOT’s effort to implement rules allowing the regular transportation of Liquified Natural Gas by rail throughout the United States.

For society to function through the energy transition — indeed, to survive it — we must continue burning fossil fuels until we can match the emergency reliability of traditional fuels. Until then, we must transport transition fuels such as LNG in the safest possible manner.


Joshua Davidson
Atlantic Northeast Rails & Ports