Stop LNG by Rail, President Biden and Secretary Buttigieg

The Department of Transportation (DOT) and President Biden are being petitioned by the public to stop the authorization of the bulk transportation of liquefied natural gas (LNG) in rail cars on the nation’s railways. Based on public safety and health concerns, in 2021 DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA) proposed federal rulemaking (the “Suspension Rule” RIN 2137–AF55)[1] to suspend the Trump Administration’s 2020 federal rule that lifted the long-standing ban on LNG transport by rail. Public comments and technical submissions to PHMSA during the public comment period provide broad and compelling support for the Suspension Rule and explain why the Trump era LNG rule endangers millions of Americans. The petition calls on PHMSA to first, immediately adopt the Suspension Rule and second, that PHMSA reinstate the permanent ban through federal rulemaking. Lastly, the petition insists that Special Permits for LNG rail transport be denied, including Special Permit DOT-SP 20534 for the proposed Gibbstown/Wyalusing LNG Export Project.[2]

Prior to the Trump Rule, a Special Permit (Special Permit DOT-SP 20534), was issued in December 2019 for transport of LNG by rail car from Wyalusing, PA to Gibbstown, NJ for a proposed LNG export terminal on the Delaware River. It expired but PHMSA is currently considering an application for its extension. This is the first and only use in the nation of DOT 113C120W tank cars to transport LNG, which were designed 50 years ago and never used for LNG and it is the only permit to allow daily “unit-train” volumes of LNG over enormous distances (approximately 200 miles). The trains cut through many communities of color and low-income populations already overburdened with environmental injustices, including Scranton, Wilkes Barre, Reading, Allentown, and Philadelphia in Pennsylvania and Camden and other southern municipalities in New Jersey.

Transporting LNG in rail cars poses unique hazards. If there is a container breach, such as in a derailment, the super-cooled (-260 degrees F) liquid methane is released as a vapor cloud that is 600-620 times greater than the volume of the contained liquid, causing freeze burns and robbing oxygen from the air for those in proximity, which can be deadly[3]. The vapor cloud can travel miles very quickly. PHMSA’s Environmental Assessment[4] issued in 2019 describes the response to a broken cryogenic tank car as very difficult for first responders and fire companies and risks catastrophe due to the great potential for explosions and large fires. If the highly flammable gas is ignited, it burns so hot the fire cannot be extinguished and must be allowed to burn out, requiring emergency evacuations for up to two miles. A bomb-like explosion known as a BLEVE or Boiling Liquid Expanding Vapor Explosion can occur with catastrophic impacts. These dangers are amplified in densely populated communities where high-speed and complete evacuation is practically impossible. These public safety hazards are the foundation for the longstanding ban on LNG transport by rail car.

The National Academies of Sciences, Engineering, and Medicine’s Transportation Research Board (“TRB”), the agency that is charged with conducting LNG by rail research, advises that “quantitative risk analyses” have not been done and need to be performed, and that, prior to any LNG by rail activities, a safety assurance initiative be put in place and further investigation be conducted of the safety performance of the railcars that are proposed to be used (DOT-113C120W9.16). Clearly, there is no assurance that adding LNG to our railways is, by any equitable measure, safe or warranted.

The recent push to increase the export of LNG by rail due to the Ukraine crisis has heightened community concerns that the desires of the gas and oil industry will overwhelm government’s responsibility to protect the public and replace dirty fracked gas with truly clean, renewable energy. Public safety and environmental health must come first.

LNG is liquefied methane. Methane is a greenhouse gas (GHG) 86 times more powerful than carbon dioxide in heating the atmosphere on a 20-year time scale and 104 times more powerful over a 10-year period, the periods of time when scientists say we must reduce GHG emissions to address the climate crisis. Methane leaks and/or is vented in all phases of the LNG production process, including processing, storage, transport, transloading and use. In light of the high global warming potential of methane, the Biden administration has pledged to slash methane emissions. Pushing LNG onto train tracks, enabling LNG production, and stepping up gas extraction and transportation will exacerbate climate change and undercut our collective climate goals to prevent the earth’s warming.

LNG transport by railcar recklessly endangers the public and risks catastrophe such as the disastrous train derailment in East Palestine, Ohio in February. The public health and environmental impacts from the resulting inextinguishable fires and release of vinyl chloride and other highly toxic chemicals to the air, water, and soil will not be fully calculated for some time. However, the resulting state of emergency requiring evacuation of the community, the raging fires and plumes of polluted smoke, the fish kills, and the exposure of people to hazardous pollutants is testimony that high hazard derailments do occur and the consequences can be tragic. We don’t need to add more flammable hazardous materials to the dangers our communities and environment already face from high-risk rail car transport.