Robert T. Opal

October 28, 2002

This note will serve as the comments of Union Pacific Railroad Company.

Union Pacific strongly supports the comments being submitted by the Association of American Railroads in this proceeding. We wish to particularly emphasize the importance of adequate flangeway gaps where pedestrian access routes cross railroad tracks at grade. It is essential that a flangeway gap of 3 inches be provided for railroad tracks over which freight equipment operates, as currently proposed in section 1103.7. Railroad equipment is held on its tracks by flanges on the inside of the wheels. In order for the flanges to work properly, there must be adequate space on the inside face of the rails for the wheel flanges to freely pass. If a flangeway is too narrow, it can lift the wheel flanges above the top of the rail, causing the wheels to leave the tracks. Any requirement for narrow flangeways thus creates a serious and potentially catastrophic risk of derailment.

We are not aware of any "gap filler" devices or materials that would permit a narrower gap than proposed in Section 1103.7. It should be appreciated that, in order for a "gap filler" technology to be employed, it must expand to the necessary flangeway width 100% of the time, for all railroad equipment, at all speeds and in all conditions of weather. One failure could easily result in a catastrophic train accident. Perhaps there may someday be a technology or material that meets this requirement. However, there is nothing available now or in the foreseeable future.

Thank you for your consideration of these comments.

Robert T. Opal
General Commerce Counsel
Union Pacific Railroad Company