Beau D. Price BNSF Railway Company Director Locomotives & Air Brakes OOB-2 2600 Lou Menk Drive Fort Worth, TX 76131-2828 817-352-1420 Direct 817-320-4103 Cell [email protected]

VIA ELECTRONIC FILING

March 18, 2021

Karl Alexy Associate Administrator for Railroad Safety Chief Safety Officer Federal Railway Administration 1200 New Jersey Avenue, SE , DC 20590

Re: Expansion to Coal Trains under Waiver FRA-2018-0049

Dear Mr. Alexy:

BNSF Railway is requesting the expansion of FRA-2018-0049 Brake Health Effectiveness (BHE) to encompass coal trains operating over the Pikes Peak Subdivision in Colorado and across the Sandhills Subdivision of Nebraska. BNSF Railway (BNSF) has been actively reviewing the data generated under waiver FRA-2018-0049 since the beginning of the BHE waiver program in August of 2018. BNSF can report that during the waiver period, we have effectively tested more than 5,500 trains under the waiver. The cold and hot wheels (BNSF tracks by brake valve) have resulted in over 12,000 Automatic Single Car Tests (ASCT) being performed by carmen from BNSF & TTX. Over 7000 of those tests have been performed by carmen using the industry preferred “4 Pressure” test variety adding to additional brake systems components being replaced. This has driven the overall brake health improvement of trains and cars under the waiver. This testing has led to the removal of thousands of components of which the top 8 are listed below (from car repair billing records):

BNSF BHE PROGRAM COMPONENTS REPLACED

• 2934 Service Valves • 2118 Emergency Valves • 1105 Air Hose Supports Complete • 906 Retainer Valves • 853 Pipe Fitting Gaskets or Brackets • 617 Vent Valve / Vent Protectors

• 521 Truck Brake Cylinder Hoses • 513 Empty Load Devices

This current test waiver has been extremely successful in improving the braking performance of intermodal and grain cars with fewer than 5% of those cars being tested “repeating” for a cold wheel indication during the following 30-day period. The one-time repeaters were subjected to another ASCT and additional work scope with the majority being resolved with the second ASCT.

In building on the ongoing success on the intermodal trains and grain & intermodal trains BNSF would like to request the FRA safety board provide approval of the expansion initiative on the BNSF’s coal network in a two-phase program:

Coal Trains Phase 1: The Addition of the Pike’s Peak Route through Colorado w/ Detectors at Monument & Castle Rock.

Coal trains, phase 1&2, will be subject to the same requirements for training completion of all related work groups and would not be “turned on” until the training records are provided to the test waiver committee. BNSF is prepared to begin training on BHE processes (carmen, train-crews, MP&E inspectors and management) in the following locations as soon as late March and early May:

• Denver, CO • Alliance, NE • Temple, TX • Amarillo, TX

The reporting, tracking and compliance to all waiver conditions would be consistent with the existing locations and trains under the waiver that has been ongoing for nearly two years.

BNSF has installed, tested and validated the required detectors at the “Pike’s Peak Site over the last four months. These detectors were installed to continue the BHE testing in a cold weather climate

and location that allows for the testing of south bound loaded coal trains. The processes & parameters will follow the general conditions of Southern Transcom BHE Program but differ in that that the trains “cycle” and stay intact in unit train operations much like the Northern grain trains under the waiver.

• Detectors positioned to the east and west Palmer Lake, CO (specific locations in attached deck) • Minimal power braking initiated to elevate wheel temperatures for analysis at the test sites • BNSF developed algorithms identify suspected ineffective brake valves – Loaded cars with ineffective brake valves have notifications applied as a “CW” Cold Wheel – Automatic single car airbrake tests (ASCAT) conducted to address suspected ineffective brake components when the cars come back from their “cycle” as empties • Train having greater than 95% effective brakes can bypass the intermediate inspection • Trains that fail to get an effective BHE test will NOT bypass the intermediate inspection point and will be fully inspected

Coal Trains Phase 2: The Addition of the Sand Hills Route through Nebraska w/ Detectors being installed at testing sites.

Supporting Information:

The accompanying PowerPoint presentation “System BHE Performance Update & Coal Trains on Pikes Peak Expansion 3 18 2021”, identifies the location, gradients and physical plant associated with the two sets of detectors for the coal routes and identifies an example of the “EMPTY” and “LOADED” trains routes that would be covered under this expansion. This document also provides the details on BHE performance through early March 2021.

The expansion of waiver FRA-2018-0049 for unit coal trains will accomplish all the following:

• Validation of braking performance of BNSF coal trains moving south through Colorado and East through Alliance Nebraska • Improve the braking performance of individual cars identified with cold or hot wheels • Increase the testing of car brake systems with Automatic Single Car Test (ASCT) devices • Increase the removal of poor performing brake valves identified by the ASCT • Increase the removal of poor performing brake system components in addition to valves • Generate additional important data on air brake valve performance in a cold weather environment to supplement the program started with Northern grain trains

The inclusion of both coal train routes to the BHE waiver will provide additional valuable data on the relationship between valve age and braking performance in cold weather scenarios as we will now be looking at both grain and coal cars braking systems.

BNSF is prepared to begin operating Coal Trains Phase 1 immediately under the waiver as soon as approval is granted, and the training is complete for all disciplines (crew, signal, carmen & dispatchers)

which does take some time. Coal Trains Phase 2, will be ready to commence in late May or June as the detectors which are being installed go through the validation processes.

If you have any questions or require more information, please contact me at your convenience. Thank you in advance for your consideration.

Cordially,

Beau D. Price Beau D. Price Director of Locomotives & Air Brakes

CC: FRA – Charles King, Gary Fairbanks, Steve Zuiderveen, Steve Clay, FRAWaiver.gov

BNSF Railway- Matt Baldwin, Gretta Baker, Brandon Mabry, Bruno Soto, Mark Grubbs, Klint Abbott, Gary Grissom, Todd Glissman, James Tylick, Paul Duncan, Steve Pierce, Doug Jones, Paul Kuhn, Scott Meyer, Matt Garland