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 Washington, 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.