To Whom it May Concern,
I would like to take this opportunity to respond to some of the points raised in Lora Jo Foo’s “No Coal in Oakland” document dated June 2, 2016, addressed to Claudia Cappio, Assistant City Administrator.
Ms. Foo refers to a TLS press conference on May 23, 2016 where Jerry Bridges was asked whether TLS was doing testing to be sure no coal dust escaped the rail cars. Jerry Bridges mistakenly responded “the FRA last year approved these rail car covers for the transportation of coal.” Unfortunately he had confused some information that Ecofab had provided for him. The approval for the cover system that Ecofab received was from the Department of Transportation (DOT) and not the FRA. The FRA is one of 10 agencies within the Department of Transportation (DOT), but is not an authority charged with making the aforementioned approvals. In fact, the Ecofab Cover System has not been approved for covering coal because there is no approval required for coal which as we know travels uncovered. In 1994 however, the DOT determined that the Ecofab Cover System met the criteria for a closed transport vehicle as specified in “Title 49 CFR 173.403 (c )”. This approval was sought after and achieved by an Ecofab customer who had Low Level Radioactive (LLW) waste, with material of all sizes and shapes from demolished building structures down to particulate as fine as coal dust.
When Jerry Bridges claimed that a proven technology exists for rail car covers, Ecofab’s history supports his statement. Ecofab has provided covers for many commodities over its 40+ year tenure serving customers who ship by rail. Many of these commodities are significantly toxic or radioactive, yet in the billions of miles traveled there has never been an incident of dusting reported or radioactive material exposed to the environment or to the public. One would think that a system with a history of over 40 years and literally billions of car miles moving toxic dust successfully is anything but a “mirage” as Ms. Foo describes Bridges’ assertion.
Further concerns that Ms. Foo has shared are those of cover performance in snow ice and rain. Ecofab covers in North America have travelled more than a billion miles in each of -40 degrees temperature, snow, ice, and rain. In addition they have travelled in the extreme heat in Mexico, South America and Australia without deformation or twisting. A properly fastened Ecofab cover has proven to be secure in high winds. These covers have proven to be a safe and reliable system for over 40 years providing an important link in the movement of bulk materials by rail.
Thank you for your time,
VP Marketing & Sales
Ecofab Maintenance Ltd.