Joseph L. Lorenzini - Comments

To: Docket Management Facility January 13, 2009 US Department of Transportation Room W12-140 1200 New Jersey Ave. S.E., Washington, D.C. 20590-0001 Subject: Docket No. FRA -2008-0036 Track Safety Standards; Continuous Welded Rail (CWR) Metra submits the following comment regarding the NPRM for changes to 213.119 Continuous Welded Rail of the 49 CFR 213 Track Safety Standards. In the preamble to the rule entitled “A. Maintaining Desired Rail Installation Temperature”, it is stated: “The Working Group developed the concept of the rail neutral temperature (RNT) ‘‘safe range.’’ The lower limit of this safe range is defined as 20° F below the designated rail laying temperature (RLT) for a particular territory. Rail that has pulled apart, broken, or been cut for defect removal must be readjusted such that its neutral temperature is within the safe range. If the rail has not been so readjusted before the rail temperature exceeds a prescribed value, the railroad would either: (1) Apply a speed restriction of 25 mph, or (2) apply a speed restriction of 40 mph in conjunction with a daily inspection of the rail made during the heat of the day.” The RSAC group (rail management, FRA and labor), agreed that this measure was excessively punitive to commuter and passenger operations because commuter trains do not generate the lateral loads typically imposed in freight operations. Hunting, a significant source for imposed dynamic lateral loading, typically occurs in lightly loaded commuter cars at about 60 MPH in contrast to the typical onset of hunting in freight cars at about 40 MPH. Thus it was agreed that for passenger and commuter trains: “Rail that has pulled apart, broken, or been cut for defect removal must be readjusted such that its neutral temperature is within the safe range. If the rail has not been so readjusted before the rail temperature exceeds a prescribed value, the railroad would either: (1) Apply a speed restriction of 25 mph, or (2) apply a speed restriction reducing the speed by one class of track or operate at 40 mph, whichever was greater, in conjunction with a daily inspection of the rail made during the heat of the day.” Thus commuter railroads typical of Metra, (operating at a maximum speed of 79 MPH), would reduce speed to 60 MPH for passenger operations and inspect the location during the heat of the day or otherwise have to reduce speed to 25 MPH if the inspection could not or would not be inspected during the heat of the day. Metra respectively requests that the preamble be modified to reflect the above comment. Joseph L. Lorenzini, P.E. Chief Engineering Officer – Metra