Comment to stop LNG Transport by Rail – Delaware Riverkeeper Network

It’s Back! Trump’s PHMSA seeking Liquified Natural Gas (LNG) Transport by Rail

The Department of Transportation Pipeline and Hazardous Materials Safety Administration (PHMSA) has published an Advance Notice of Proposed Rulemaking (ANPRM) that includes a reconsideration of allowing the transportation of liquefied natural gas (LNG) by rail tank car. The Trump Administration overturned the longstanding ban on LNG by Rail (the “Trump LNG by Rail Rule”) during its first administration but the Trump LNG by Rail Rule was suspended under the Biden Administration and ultimately defeated by a court challenge to protect public safety and the environment.

Trump’s PHMSA is now resurrecting the allowance of railcar transport of LNG throughout the nation by seeking “stakeholder” input. This Advanced Notice would be followed by a proposed rulemaking if there is stakeholder response supporting the lifting of the LNG by Rail ban. The ban could then be overturned by a new rule. But we will fight to keep that from happening through our comments. Comment deadline is August 4, 2025.

Submit your comment now

We need to submit comments on the record opposing the lifting of the ban on LNG by Rail. Please go here to find out how to comment and see Talking Points to help with your comment. Comments are entered into: https://www.regulations.gov or by hard mail.

This reckless attempt to deregulate hazardous material rail transport to allow this highly flammable, explosive, and polluting fossil gas to be carried through our communities across the nation must be stopped but it won’t be unless we speak up powerfully. We know it is not safe based on PHMSA’s own analysis and the court record that led to the Court throwing out the Trump LNG by Rail Rule.

The dangers posed have not gone away, the only change is that the PHMSA is now invoking Trump’s Executive Orders to ‘‘Unleash American Energy’’ and to declare a “National Energy Emergency’’ as rational for weakening the regulations that protect us from the rail transport hazardous materials. We need only to witness the East Palestine Ohio rail catastrophe to understand what can go wrong and the tragic consequences.

The ANPRM is wide-ranging and touches on many aspects of PMHSA’s Hazardous Materials Rules. The section addressing LNG by Rail is at: III. Topics Under Consideration,B. Hazardous Materials Program Procedures (49 CFR Part 107) and Hazardous Materials Regulations (49 CFR Parts 171 Through 180) Section 24.

Please comment now to fill out the record with the facts and to counter the false narrative that there is an energy emergency that would allow public safety and environmental protection to be thrown away!

Use the suggested talking points and/or sample letter below:

Suggested Talking Points:

Commenting on PHMSA-2025-0050 focused specifically on: III. Topics Under Consideration,B. Hazardous Materials Program Procedures (49 CFR Part 107) and Hazardous Materials Regulations (49 CFR Parts 171 Through 180) Section 24.

The transport of Liquefied Natural Gas (LNG) has long been prohibited by the Pipeline and Hazardous Materials Safety Administration (PHMSA) from transport by rail car to protect public safety. PHMSA holds the mission “…to manage, and reduce, the risk to people and the environment by the transport of hazardous material by rail.”[1] The Trump Administration recklessly overturned the longstanding ban on LNG by Rail (the “Trump LNG by Rail Rule”) during its first administration but, after subsequent comprehensive analysis by PHMSA, the Trump LNG by Rail Rule was suspended under the Biden Administration and ultimately defeated by a court challenge to protect public safety and the environment. PHMSA officially repealed the Trump LNG by Rail Rule in accordance with the D.C. Circuit’s ruling on June 23, 2025 as noticed in the Federal Register.[2] LNG by rail car transport is now once again banned based on ample evidence that it cannot be done safely. It should stay that way, based on facts, not brought back for political motives, as expressed in Trumps’ Executive Orders[3] which are used as rationale for this proposed rulemaking.[4]

LNG is extremely dangerous to handle. Its transport has unique safety hazards, exposing those along rail routes to unprecedented and unjustifiable risk. LNG is highly flammable and potentially explosive. 22 LNG rail cars contain as much explosive energy as the Hiroshima bomb. Companies plan to transport LNG in “unit trains”, which consist of LNG in up to 100 cars. An accident or incident that released LNG would be catastrophic for communities and the environment.

An LNG release boils furiously into a flammable vapor cloud 620 times larger than the storage container. An unignited ground-hugging vapor cloud can move far distances,^[5] and exposure to the extremely cold vapor can cause severe freeze burns. If in an enclosed space, it asphyxiates, causing death^[6].

LNG fires are hotter and burn more rapidly than fires caused by oil or gasoline, and they are extremely difficult to control. Often, these fires persist until they have exhausted all the available gas. And in an LNG-by-rail scenario, that means tens of thousands of gallons at minimum. If the released LNG is ignited, a resulting pool fire is so hot that second degree burns can occur within 5 seconds for those exposed within .69 miles and 10 seconds of exposure could be fatal.^[7] First responders across the country have not received the training or the resources required to confidently contain a fire resulting from an LNG rail incident. And even if luck provides against a fire or explosion, LNG spills can still endanger the people nearby because LNG vapor clouds displace breathable air. The recommended response for fire companies and first responders is to try to evacuate and let the fire burn. Imagine the catastrophe in a populated region and around vulnerable and essential infrastructure.

An LNG release can cause a Boiling Liquid Expanding Vapor Explosion.^[8] When the gas or vapor cloud in the container is released, because it is flammable it is likely to ignite after the BLEVE, typically causing a fireball that burns fast, hot and wide. A fuel air explosion can also occur, known as a “vapor cloud explosion”. A vapor cloud explosion is the mechanism used in a thermobaric weapon that uses air to generate a high-temperature explosion, producing a long duration blast wave.

Communities living near the major railways that would be used to transport LNG are predominantly low-income communities and communities of color, as a result of decades of systemic racism in siting and development.^[9] LNG by Rail adds to the unjust environmental burdens of those in harm’s way. This is intolerable.

LNG is too volatile and dangerous to allow its bulk transport on railroads where so many variables can lead to disaster. We saw firsthand what a rail accident involving hazardous materials could entail when a train carrying volatile vinyl chloride derailed in East Palestine, Ohio in 2023. That derailment led to several tense days where residents living in the vicinity had to be evacuated and toxic chemicals burned off into the air for fear of an explosion. And the impacts were not just local; the accident resulted in toxic chemicals spreading to sixteen nearby states.[10] The mismanaged handling of the catastrophe has been widely criticized, including by the federal government[11] and long-term health and environmental impacts continue to be studied.[12] There is no evidence that hazardous material transport of LNG would be any more safely accomplished; in fact, the volatility, flammability, and explosive nature of LNG has the potential to result in a worse catastrophic outcome.

LNG is liquefied methane, which is a greenhouse gas 86 times more powerful than carbon dioxide in heating the atmosphere on a 20-year time scale and 104 times more powerful over a 10-year period, the periods of time when scientists say we must reduce GHG emissions to address the climate crisis. Over the past decade, oil and gas infrastructure has been the primary source of methane releases. To produce LNG, more gas wells would be fracked, polluting Pennsylvania communities, and methane will be leaked or vented at every stage, exacerbating climate change and worsening climate and human health impacts already being visited on communities.

There is no economic or logistical need for transporting LNG by rail car. LNG facilities in operation fulfill the market for LNG exports already; export is the primary market for LNG. The projects under construction and in process of permitting add so much more LNG that a glut of U.S. LNG could turn capital investments into stranded assets. None of these projects require LNG transport by rail car because the practice is to bring in fossil gas in a gaseous state, then liquefy it at the export terminal, loading into marine vessels for export. There is also a downside to the increase in LNG exports for domestic users. “As LNG exports have grown, consumer costs for gas have spiked as well. In early 2021, winter storm Uri caused a supply shock that sent natural gas prices from $3 to $1200 per thousand cubic feet, as a Texas freeze also slashed production. Later, the invasion of Ukraine set off a price war between domestic consumers and gas exporters, sending U.S. gas prices to their highest level in a decade”. The economic forecast for U.S. LNG exports is dim as nations turn to homegrown, sustainable and renewable sources of energy to avoid the high prices of US LNG and to obtain energy security that they can control. This forecast does not support the concept that LNG transport by rail car is needed or justified.

Thank you for speaking up on the record to stop the resurrection of the Trump LNG by Rail rule!

[1] NJDOT, Pipeline and Hazardous Materials Safety Administration, Docket No. PHMSA-2018-0025 (HM-264) RIN 2137-AF40, Hazardous Materials: Liquefied Natural Gas by Rail, NPRM Preliminary Regulatory Impact Analysis, October 2019, Executive Summary

[2]https://www.google.com/url?sa=t&source=web&rct=j&opi=89978449&url=https://www.govinfo.gov/content/pkg/FR-2025-06-23/pdf/2025-11467.pdf&ved=2ahUKEwiy9L2J8YeOAxWKFlkFHbdKNM0QFnoECBQQAQ&usg=AOvVaw2qNwDiFzc4nhDaL-ARCzga

[3] E.O. 14154,, ‘‘Unleashing American Energy’’and E.O. 14156, ‘‘Declaring a National Energy Emergency,’’ available at https://www.federalregister.gov/presidential-documents/executive-orders/donald-trump/2025

[4] https://www.govinfo.gov/content/pkg/FR-2025-06-04/html/2025-10090.htm

[5] “Immediate ignition with liquid still on the ground could cause the spill to develop into a pool fire and present a radiant heat hazard. If there is no ignition source, the LNG will vaporize rapidly forming a cold gas cloud that is initially heavier than air, mixes with ambient air, spreads and is carried downwind.” P. 10 “Methane in vapor state can be an asphyxiant when it displaces oxygen in a confined space.” P. 11. SP 20534 Special Permit to transport LNG by rail in DOT-113C120W rail tank cars. Final Environmental Assessment. Docket No. PHMSA-2019-0100. December 5, 2019. P. 10.

[6] SP 20534 Special Permit to transport LNG by rail in DOT-113C120W rail tank cars. Final Environmental Assessment. Docket No. PHMSA-2019-0100. December 5, 2019. P, 11.

[7] “The Council on Environmental Quality describes the danger: The characteristics of these fires on water, like the behavior of vapor clouds, are subject to great uncertainties and estimates of the safe distance from their intense radiant heat vary significantly. According to a recent FPC (Federal Power Commission) analysis, a generally safe distance from a 25,000-cubic-meter pool fire would be about 8,300 feet or 1.6 miles. People standing 3,600 feet away would blister in 5 seconds, and exposure for longer times-perhaps 10 seconds — would be fatal. Estimates based on Bureau of Mines figures indicate that the danger might extend farther. According to these figures, on a windless day when thermal radiation is greatest, unsheltered people at a distance of 9,600 feet, or nearly 2 miles, could suffer fatal burns.” “DELAWARE COASTAL MANAGEMENT PROGRAM AND FINAL ENVIRONMENTAL IMPACT STATEMENT”. [From the U.S. Government Printing Office, www.gpo.gov ]. U.S. DEPARTMENT OF COMMERCE, National Oceanic and Atmospheric Administration, Office of Coastal Zone Management, *41T4 O74f. UNITED STATES DEPARTMENT OF COMMERCE, The Assistant Secretary for Science and Technology, Washington, D.C. 20230, JUL 2 1979. P. 225 of PDF.

[8] “LNG tank BLEVE is possible in some transportation scenarios.” Sandia National Laboratories, “LNG Use and Safety Concerns (LNG export facility, refueling stations, marine/barge/ferry/rail/truck transport)”, Tom Blanchat, Mike Hightower, Anay Luketa. November 2014. https://www.osti.gov/servlets/purl/1367739 P. 23.

[9] E.g., https://evergreenaction.com/blog/trains-are-a-climate-solution-just-not-in-the-united-states (“More than 13 million people in the U.S. – predominantly people of color and lower-income individuals – live and work near railyards, rail lines, and ports.”).

[10] https://iopscience.iop.org/article/10.1088/1748-9326/ad52ac; https://www.theguardian.com/us-news/article/2024/jun/19/east-palestine-toxic-derailment-chemicals-spread

[11] https://www.ntsb.gov/news/press-releases/Pages/NR20240625.aspx

[12] https://factor.niehs.nih.gov/2024/3/feature/1-feature-train-derailment-research

Sample comment letter

To: U.S. Department of Transportation, PHMSA
Re: PHMSA-2025-0050 ANPRM

I am submitting this comment focused on III. Topics Under Consideration, B. Hazardous Materials Program Procedures (49 CFR Part 107) and Hazardous Materials Regulations (49 CFR Parts 171 Through 180) Section 24. I support the retention of the prohibition of the transport of LNG by rail car and urge that the ban be kept in place.

I oppose the transportation of Liquefied Natural Gas (LNG) by rail car because:

The transport of Liquefied Natural Gas (LNG) has long been prohibited by the Pipeline and Hazardous Materials Safety Administration (PHMSA) from transport by rail car to protect public safety. PHMSA holds the mission “…to manage, and reduce, the risk to people and the environment by the transport of hazardous material by rail.”^[1] The Trump Administration recklessly overturned the longstanding ban on LNG by Rail (the “Trump LNG by Rail Rule”) during its first administration but, after subsequent comprehensive analysis by PHMSA, the Trump LNG by Rail Rule was suspended under the Biden Administration and ultimately defeated by a court challenge to protect public safety and the environment. PHMSA officially repealed the Trump LNG by Rail Rule in accordance with the D.C. Circuit’s ruling on June 23, 2025 as noticed in the Federal Register.^[2] LNG by rail car transport is now once again banned based on ample evidence that it cannot be done safely. It should stay that way, based on facts, not brought back for political motives, as expressed in Trumps’ Executive Orders^[3] which are used as rationale for this proposed rulemaking.^[4]
LNG is extremely dangerous to handle. Its transport has unique safety hazards, exposing those along rail routes to unprecedented and unjustifiable risk. LNG is highly flammable and potentially explosive. 22 LNG rail cars contain as much explosive energy as the Hiroshima bomb. Companies plan to transport LNG in “unit trains”, which consist of LNG in up to 100 cars. An accident or incident that released LNG would be catastrophic for communities and the environment.
An LNG release boils furiously into a flammable vapor cloud 620 times larger than the storage container. An unignited ground-hugging vapor cloud can move far distances,^[5] and exposure to the extremely cold vapor can cause severe freeze burns. If in an enclosed space, it asphyxiates, causing death^[6].
LNG fires are hotter and burn more rapidly than fires caused by oil or gasoline, and they are extremely difficult to control. Often, these fires persist until they have exhausted all the available gas. And in an LNG-by-rail scenario, that means tens of thousands of gallons at minimum. If the released LNG is ignited, a resulting pool fire is so hot that second degree burns can occur within 5 seconds for those exposed within .69 miles and 10 seconds of exposure could be fatal.^[7] First responders across the country have not received the training or the resources required to confidently contain a fire resulting from an LNG rail incident. And even if luck provides against a fire or explosion, LNG spills can still endanger the people nearby because LNG vapor clouds displace breathable air. The recommended response for fire companies and first responders is to try to evacuate and let the fire burn. Imagine the catastrophe in a populated region and around vulnerable and essential infrastructure.
An LNG release can cause a Boiling Liquid Expanding Vapor Explosion.^[8] When the gas or vapor cloud in the container is released, because it is flammable it is likely to ignite after the BLEVE, typically causing a fireball that burns fast, hot and wide. A fuel air explosion can also occur, known as a “vapor cloud explosion”. A vapor cloud explosion is the mechanism used in a thermobaric weapon that uses air to generate a high-temperature explosion, producing a long duration blast wave.
Communities living near the major railways that would be used to transport LNG are predominantly low-income communities and communities of color, as a result of decades of systemic racism in siting and development.^[9] LNG by Rail adds to the unjust environmental burdens of those in harm’s way. This is intolerable.
LNG is too volatile and dangerous to allow its bulk transport on railroads where so many variables can lead to disaster. We saw firsthand what a rail accident involving hazardous materials could entail when a train carrying volatile vinyl chloride derailed in East Palestine, Ohio in 2023. That derailment led to several tense days where residents living in the vicinity had to be evacuated and toxic chemicals burned off into the air for fear of an explosion. And the impacts were not just local; the accident resulted in toxic chemicals spreading to sixteen nearby states.^[10] The mismanaged handling of the catastrophe has been widely criticized, including by the federal government^[11] and long-term health and environmental impacts continue to be studied.^[12] There is no evidence that hazardous material transport of LNG would be any more safely accomplished; in fact, the volatility, flammability, and explosive nature of LNG has the potential to result in a worse catastrophic outcome.
LNG is liquefied methane, which is a greenhouse gas 86 times more powerful than carbon dioxide in heating the atmosphere on a 20-year time scale and 104 times more powerful over a 10-year period, the periods of time when scientists say we must reduce GHG emissions to address the climate crisis. Over the past decade, oil and gas infrastructure has been the primary source of methane releases. To produce LNG, more gas wells would be fracked, polluting Pennsylvania communities, and methane will be leaked or vented at every stage, exacerbating climate change and worsening climate and human health impacts already being visited on communities.
There is no economic or logistical need for transporting LNG by rail car. LNG facilities in operation fulfill the market for LNG exports already; export is the primary market for LNG. The projects under construction and in process of permitting add so much more LNG that a glut of U.S. LNG could turn capital investments into stranded assets. None of these projects require LNG transport by rail car because the practice is to bring in fossil gas in a gaseous state, then liquefy it at the export terminal, loading into marine vessels for export. There is also a downside to the increase in LNG exports for domestic users. “As LNG exports have grown, consumer costs for gas have spiked as well. In early 2021, winter storm Uri caused a supply shock that sent natural gas prices from $3 to $1200 per thousand cubic feet, as a Texas freeze also slashed production. Later, the invasion of Ukraine set off a price war between domestic consumers and gas exporters, sending U.S. gas prices to their highest level in a decade”.[13] The economic forecast for U.S. LNG exports is dim as nations turn to homegrown, sustainable and renewable sources of energy to avoid the high prices of US LNG and to obtain energy security that they can control. This forecast does not support the concept that LNG transport by rail car is needed or justified.

[4] https://www.govinfo.gov/content/pkg/FR-2025-06-04/html/2025-10090.htm

[6] SP 20534 Special Permit to transport LNG by rail in DOT-113C120W rail tank cars. Final Environmental Assessment. Docket No. PHMSA-2019-0100. December 5, 2019. P, 11.

[10] https://iopscience.iop.org/article/10.1088/1748-9326/ad52ac; https://www.theguardian.com/us-news/article/2024/jun/19/east-palestine-toxic-derailment-chemicals-spread

[11] https://www.ntsb.gov/news/press-releases/Pages/NR20240625.aspx

[12] https://factor.niehs.nih.gov/2024/3/feature/1-feature-train-derailment-research

[13] https://ieefa.org/resources/even-lng-pause-ends-doe-still-needs-update-costs-and-consequences-export-surge