Virginia Chamber responds to request for comments regarding proposed rulemaking concerning trains transporting flammable liquids
September 29, 2014
Anthony Foxx, U.S. Secretary of Transportation
U.S. Department of Transportation
Pipeline and Hazardous Materials Safety Administration Docket Mgmt Systems, U.S. Dept. of Transportation
West Building, Ground Floor, Room W12-140 1200 New Jersey Avenue SE
Washington DC 20590
RE: Notice of Proposed Rulemaking: Hazardous Materials – Enhanced Tank Car Standards and Operational Controls for High-Hazard Flammable Trains
(Docket No. PHMSA-2012-0082 (HM-251))
Dear Secretary Foxx,
On behalf of the Virginia Chamber of Commerce, I am pleased to respond to the Pipeline and Hazardous Materials Safety Administration (PHMSA) request for comments regarding proposed rulemaking concerning trains transporting flammable liquids. The Virginia Chamber is the state’s largest business advocacy organization with more than 17,400 members. As the voice for business, the Chamber works in the legislative, regulatory and political arenas to act as a catalyst for enhancing Virginia’s economic competitiveness and pro-business climate. During the past eighteen months, the Chamber engaged over 7,000 business and community leaders from around the state to develop Blueprint Virginia, a comprehensive initiative to provide business leadership, direction and long-range economic development planning for Virginia.
Blueprint Virginia promotes an “all-of-the-above” energy strategy that ensures the continued availability of reliable and affordable energy for American families and businesses while also protecting the environment. To ensure a vibrant and growing economy, we need to fully utilize this country’s domestic resources to meet the growing needs of our population and business community.
The Virginia Chamber recognizes the importance of railroads, as they are vital to both commerce and job creation. Simply put, freight rail’s economic activity translates to jobs. For every one freight rail job, it supports 4.5 other jobs. That is no more evident than the many businesses and ports in Virginia that are served by rail. At 50-feet, the Virginia Port offers the deepest shipping channels in the U.S. East Coast and more than 30 international steamship lines serve the Virginia Port today. Norfolk Southern and CSX offer on-dock, double stack intermodal service to key inland markets in the Midwest , Ohio Valley and the Southeast.
I know you understand energy’s importance to the economy of Virginia and the nation as a whole.
There are huge amounts of crude oil crossing through the country via trains. In 2008, 9,500 rail-carloads of crude moved through our country compared to last year, when there were 415,000 rail-carloads. The increase in commerce is good for our economy, but it all must be done safely. The Virginia Chamber is pleased to learn that PHMSA, in collaboration with U.S. freight railroads, is working to adopt new standards for rail tanker cars and taking other steps to further enhance the safety of domestic energy transportation.
However, the Virginia Chamber is concerned about how the proposed nationwide speed restrictions on trains carrying crude oil would adversely impact the Virginia Port. Even if the new speed limits only apply to trains carrying flammable liquids, this could have a negative impact on the entire rail network, communities and businesses that rely on the Port. The Virginia Port plays a critical role to Virginia’s economy and the railroads serve an important function in attracting businesses, investments and a strong workforce. As cargo volumes moving in and out of the Virginia Port continue to rise, an unencumbered freight rail system is vital to the economic well-being of the Commonwealth.
Thank you for considering the Virginia Chamber’s comments on this important matter.
Barry E. DuVal
President and CEO
