GAO: USDOT relied on limited data in ECP analysis

The U.S. Government Accountability Office (GAO) recommends that the U.S. Department of Transportation (USDOT) acknowledge uncertainty in its revised economic analysis of electronically controlled pneumatic (ECP) brakes, and collect data on railroads' use of the systems, according to a report issued yesterday.

ECP brakes issue electronic signals to simultaneously apply and release brakes throughout the length of a train instead of each car applying brakes individually. They offer the potential to shorten stopping distances, improve train handling, and reduce brake shoe and wheel wear.

The federal Fixing America's Surface Transportation (FAST) Act required the GAO to test ECP brakes and re-evaluate USDOT's economic analysis supporting the requirement of ECP braking systems on certain trains hauling flammable liquids.

In supporting its May 2015 rule, the USDOT estimated the potential business benefits of using the brakes to include reduced fuel consumption, reduced wear on wheels and improved operational efficiency.

Industry stakeholders — such as the Association of American Railroads (AAR) — have claimed that the USDOT overestimated the benefits. Seven of 10 experts the GAO interviewed who commented on such benefits said that the department's estimates of business benefits, such as reduced fuel consumption, were based on experiences that may not be representative, the report stated.

Regarding improved operational efficiency, the GAO found that while industry stakeholders stated that poor reliability of ECP brakes will greatly limit any such benefits, only two out of five railroads provided GAO extensive quantifiable data to support such claims.

The USDOT's use of limited data adds uncertainty to the estimates that the department didn't always acknowledge in its rule and supporting analysis, the GAO found.

"GAO recommends that DOT acknowledge uncertainty in its revised economic analysis of ECP brakes, collect data from railroads on their use of ECP brakes, and publish additional information about ECP brake modeling," the report stated.

The USDOT disagreed with the recommendations, stating that the GAO didn't provide sufficient evidence.

"GAO believes it had sufficient evidence and stands by its recommendations," according to the report.

In response to the study, the AAR called on the USDOT to withdraw its ECP rule.

"The GAO's conclusions validate the freight rail industry's position that the DOT had negligible data or testing results to justify the mandating of ECP brakes," said AAR President and Chief Executive Officer Edward Hamberger in a press release.

Hamberger said the freight rail industry supports the GAO's recommendations directing the DOT to be more transparent by publishing information allowing a third party to fully assess and replicate the analysis, to conduct additional studies on all aspects of ECP braking, and to create a data-collection plan involving the railroads and operational experiences using ECP brakes.