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FRA also anticipates imposing specific additional conditions on any approval to ensure the safety of the operation. These conditions would include, but may not be limited to: • Additional track geometry and internal rail flaw inspections; • A maximum speed limit of any train transporting LNG; • Pre -transport notification and training of first responders along the routes; • Minimum two -person crew size for each train transporting LNG; • A maximum number of portable tanks to be transported in any train; • Train make-up requirements; • A specifically approved schedule of LNG movements; • Recordkeeping and accident/incident reporting requirements; • Regular reports on what FEC learns (including, inspection results and acceptance criten and shipment data on a monthly basis); and • Develop and implement a system to closely monitor and respond to excessive hold times of portable tanks in transportation. As required of any railroad, FEC should expect, and cooperate with, frequent safety oversight and inspections from FRA safety officials.' f In addition, to reviewing the information provided by FEC, FRA has also undertaken significant work to study and more clearly understand the dangers and challenges of transporting LNG by rail such as: (1) information from the Alaska Railroad (ARR) demonstration; (2) Volpe research on crash survivability of LNG tanks proposed for use in rail transport; (3) LNG properties, hazards, and behaviors in accident conditions; and (4) analysis of accident data involving LNG and portable tanks transported by rail. As FRA continues to study the transportation of LNG by rail, in addition to the information outlined above, FRA may require a new detailed risk assessment and mitigation plan from FEC that incorporates the findings of FRA's research. As you may know, FRA recently approved ARR's request to transport LNG later in 2016. The FRA views ARR's approval as different from a potential FEC approval, due to the significant differences between the two states and the areas through which they would be transporting the product. For example, if ARR transports LNG it will be doing so at 40 mph through mostly unpopulated areas with few highway -rail grade crossings, whereas under FEC's proposal, trains transporting LNG will pass through highly populated areas, with more frequent crossings, while' sharing tracks with passenger trains traveling at 110 mph. If Alaska does transport LNG later in, the year, those movements will be treated as a pilot program allowing FRA to learn from those' shipments. As with FRA's own research, if FRA gathers new data from. ARR that raises 'Nothing in this letter shall be construed to alter or change any regulatory requirement FEC may have under the Federal hazardous materials regulations (49 CFR parts 171-180).