Docket No. PHMSA-2025-0050: Comment Opposing LNG by Rail Transport

Opposing LNG by Rail Transport

On behalf of FracTracker Alliance, we submit this comment in strong opposition to the reconsideration of regulations that would permit the transport of liquefied natural gas (LNG) by rail, as outlined in the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) advance notice of proposed rulemaking (ANPRM) titled Hazardous Materials: Mandatory Regulatory Reviews to Unleash American Energy and Improve Government Efficiency (90 Fed. Reg. 23660). [1]

FracTracker Alliance is a nonprofit organization dedicated to investigating and communicating the risks of oil, gas, and petrochemical infrastructure. Through mapping, data analysis, and community engagement, our research has documented the far-reaching public health and safety impacts of fossil fuel development across the United States. Based on these findings, we urge PHMSA to maintain the prohibition on LNG rail transport.

LNG by Rail Presents Irreducible Public Safety Risks

LNG is a cryogenic, flammable substance transported under high pressure. If released in a derailment or breach, it can form a rapidly expanding vapor cloud capable of ignition or explosion, particularly in confined environments. A 2020 analysis by the Congressional Research Service outlined the extreme volatility of LNG rail shipments and noted that an accident “poses a hazard of fire or explosion.” [2] Fire and emergency response professionals, including the International Association of Fire Chiefs, have raised concerns about the adequacy of existing training, response capacity, and regulatory safeguards to manage such an event.

PHMSA’s previous LNG-by-rail rule, finalized in 2020, was widely criticized for circumventing safety assessments and failing to adequately evaluate the consequences of a release in populated areas. The U.S. Court of Appeals for the District of Columbia Circuit subsequently vacated the rule in full, acknowledging the legal and scientific deficiencies in its formulation. [3] Reintroducing LNG rail transport under a new regulatory review process would re-open the same unresolved safety issues.

Communities and First Responders Bear the Risk

FracTracker Alliance has mapped the proximity of hazardous infrastructure—including LNG-related facilities—to residential neighborhoods, schools, and critical services. Rail corridors proposed for LNG shipments often pass through similar high-risk zones. [4,5] These communities would shoulder the frontline burden of a catastrophic release, despite having little to no input in siting or routing decisions. The siting of such infrastructure in disproportionately impacted communities further raises significant equity concerns.

Emergency response planning remains wholly inadequate for LNG derailments. According to Sierra Club et al. v. U.S. Department of Transportation et al., the amount of energy contained in 22 tank cars of LNG would be equal to that of the atomic bomb that was dropped on Hiroshima. [6] Most municipalities lack the equipment, training, or resources to manage an event of this scale. Regulatory streamlining must not come at the expense of public safety or local autonomy.

No Demonstrated Need Justifies This Risk

There is no compelling national interest in reinstating LNG rail transport. Existing infrastructure, including pipelines, trucking routes, and maritime terminals, already facilitates LNG distribution without exposing communities to rail-specific hazards. The proposed regulatory change serves no defined public need and does not reflect a rational assessment of risk. In addition, it directly contradicts PHMSA’s statutory mandate to protect people and the environment from the dangers of hazardous materials transport.

Conclusion

FracTracker Alliance urges PHMSA to maintain the prohibition on LNG-by-rail transport. The hazards are well documented and the purported benefits are unsubstantiated. If PHMSA nonetheless proceeds with reconsideration, any future rulemaking should, at a minimum, include a full Environmental Impact Statement (EIS); enforce strict limits on train length and speed; and incorporate route-specific risk modeling for densely populated and environmentally impacted communities to comply with the court’s findings in Sierra Club v. USDOT. Even so, they would not eliminate the high consequence risks inherent to transporting LNG by rail.

Notes

1. Pipeline and Hazardous Materials Safety Administration, Hazardous Materials: Mandatory Regulatory Reviews to Unleash American Energy and Improve Government Efficiency, 90 Fed. Reg. 23660, June 4, 2025,
   https://www.federalregister.gov/documents/2025/06/04/2025-10090/pipeline-safety-mandatory-regulatory-reviews-to-unleash-american-energy-and-improve-government.

2. Congressional Research Service, Rail Transportation of Liquefied Natural Gas: Safety and Regulation, R46414, updated July 20, 2020, https://crsreports.congress.gov/product/pdf/R/R46414.

3. Sierra Club et al. v. U.S. Department of Transportation et al., No. 20‑1317, U.S. Ct. App. D.C. Cir., Jan. 17, 2025, https://law.justia.com/cases/federal/appellate-courts/cadc/20-1317/20-1317-2025-01-17.html.

4. FracTracker Alliance, On the Wrong Track: Risks to Residents of the Upper Ohio River Valley from Railroad Incidents, December 7, 2023, https://www.fractracker.org/2023/12/on-the-wrong-track-risks-to-residents-of-the-upper-ohio-river-valley-from-railroad-incidents/.

5. Julia Zenkevich, “Deluzio Pushes for Rail Safety as Regulatory Tug-of-War Continues,” WESA, July 31, 2025, https://www.wesa.fm/development-transportation/2025-07-31/deluzio-rail-safety-regulation-deregulation-push-pull.

6. Sierra Club et al. v. U.S. Department of Transportation et al., No. 20‑1317, U.S. Ct. App. D.C. Cir., Jan. 17, 2025, https://law.justia.com/cases/federal/appellate-courts/cadc/20-1317/20-1317-2025-01-17.html.