In response to a congressional mandate, this report examines the potential safety risks from the operation of freight trains longer than 7,500 ft relative to the operation of shorter freight trains. Safety issues that are called out for study include the potential for derailments and other safety-related incidents associated with in-train forces, the performance and distribution of locomotives, train braking capabilities, and crew performance and human factor issues. Other safety issues identified are the potential for loss of communication between the end-of-train device and the locomotive cab and among crew members reliant on radio systems as trains become longer and encounter differing terrains. In considering these safety issues and how they can be eliminated or controlled, the committee is charged with examining the role of locomotive electronics, signal systems, the placement of rail cars and locomotives in the train, and how crew members are trained and otherwise prepared to operate long trains. Additionally, the committee is asked to examine the impacts of increasing train length on the frequency and duration of highway-rail grade crossing blockages, the scheduling and efficient operations of passenger trains and freight trains, and greenhouse gas emissions. If supported by the study findings, the committee is asked to make recommendations, including to Congress and the Federal Railroad Administration (FRA), on steps needed to better understand and reduce any adverse effects of long trains.
In contemplating the study charge and how best to fulfill it, the study committee had to make several decisions, including about the meaning of terms in the charge and how to orient the study toward salient public policy interests. Because the impacts from freight trains do not change abruptly
when a train reaches or drops below 7,500 ft in length, the committee decided that this train length—equivalent to about 1.5 miles—was specified to signify an interest in the upper portion of the train length range, rather than to define a “long” train precisely. Furthermore, because train length is associated with changes in other variables, such as train weight (i.e., trailing tonnage) and configuration of cars within a train (i.e., train makeup)—and because these variables themselves depend on train type (e.g., manifest, unit)—the committee recognized the importance of examining train length in the context of train types and considering characteristics in addition to length.
The committee also wanted its report and recommendations to be relevant by addressing the most pressing public policy issues. In this regard, it is important to emphasize that current policy interests pertaining to long trains stem largely from recent trends within the rail industry to build and operate increasingly longer manifest trains, which haul a mix of freight in many different types of rail cars (some loaded and some empty), as opposed to unit trains, which consist of cars having similar designs and weights (usually all are loaded or all are empty). The committee’s analysis of train derailment data suggested that longer manifest trains are creating new handling and operational challenges for railroads that warrant a closer examination of industry practices and public policies to address them.
Regarding long manifest trains, four specific impacts are called out in the study charge: (1) safe operations, (2) highway-rail grade crossing blockages, (3) efficient passenger and freight train operations, and (4) greenhouse gas emissions. Here, too, the committee had to make some distinctions to ensure the study’s policy relevance. Safety is a foremost public concern, and thus it is treated extensively in the report from the standpoint of train handling and operational challenges that can arise from increasing train length, the procedures and technologies used to manage them, and implications on crew performance and training requirements. Likewise, the report gives significant attention to highway-rail grade crossings, where trains of all lengths have a direct impact on the public when they block roads and impede motor vehicle and pedestrian movements. Greenhouse gas (GHG) emissions are a major public policy concern, but on a national scale, freight trains are not intense emitters of these pollutants. The committee concluded that to estimate marginal emissions impacts from longer trains would require many uncertain assumptions about whether and by how much long freight trains are replacing shorter trains or diverting freight to or from trucks and other modes. Finally, there are secondary emissions effects caused by motor vehicles emitting GHGs when backed up behind blocked crossings. Given these complexities and uncertainties, and the low rate of GHG emissions from freight trains compared to other modes of freight transportation, this impact area is not treated to the same degree as other impacts in this report.
The report also gives varying treatment to the impacts of long manifest trains on the scheduling and operational efficiency of passenger trains and freight trains. The report pays the most attention to impacts on passenger trains operated by Amtrak. Many of Amtrak’s intercity passenger trains operate over the track of other railroads (called “host railroads”) that were relieved of their common carrier obligation to provide passenger service when Amtrak was created.1 Federal statute grants Amtrak trains dispatching preference over a host railroad’s trains,2 and thus if conflicts arise due to the increasing length of freight trains, this can be a clear public policy matter. By comparison, local and regional commuter passenger railroads negotiate track use terms with their host railroads and must therefore address operational issues related to long trains through these negotiations. Because the public policy leverage in this instance is limited, especially at the federal level, this report focuses primarily on the impacts of long trains on Amtrak’s services.
Likewise, only limited attention is given to the impacts of long manifest trains on the operations of the freight railroad themselves and the shippers that use their service. Freight railroads must account directly for the operational impacts of the choices they make about when and how to use long trains. Some of these operational impacts are described, such as on car cycle times; however, the committee is not in a position to judge the advisability of these choices or to assess ultimate impacts on shippers, especially without knowing how privately negotiated shipping rates and service contracts are affected by the use of longer trains.
The committee’s assessment, therefore, focuses on long manifest trains and concentrates on impacts on rail safety, the functioning of highway-rail grade crossings, and Amtrak passenger train service. The following is a synopsis of the report’s assessments for each impact area. Recommendations are offered on actions to address impacts the committee believes would benefit most from policy interventions.
As the length of a manifest train increases, safe handling can be more challenging to manage relative to the handling of a shorter manifest train or a unit train (a train consisting of the same general car types) of comparable length. As a general matter, manifest trains create operational challenges
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1 Rail Passenger Service Act of 1970, P.L. 91-518. The Act authorized Amtrak to assume by contract the intercity rail passenger service obligations of railroads who wished to be relieved of these obligations as common carriers.
2 P.L. 93-146, § 10(2), 87 Stat. 548.
due to the mixture of rail car types, designs, sizes, and weights. All rail cars in a train are subject to longitudinal forces that create draft and buff load conditions and to lateral forces, especially at curves. These in-train forces can lead to broken equipment, including drawbars and couplers, and cause the wheels of a car to leave the rail when negotiating curves. The magnitude of these forces will differ among cars that vary in size and weight, and the movement and mitigation of the forces will differ among cars having different drawbars and coupling devices with or without cushioning units.
Railroads must therefore pay close attention during the makeup of manifest trains to the placement of cars of different types, sizes, and weights to manage in-train forces, reduce risks of derailment, and preserve train integrity. In particular, they must make choices about the placement of light cars, short cars, heavy cars, and cars with and without cushioning devices to facilitate safe handling as well as efficient operations. They must also pay attention to the placement of locomotives for distributed power (DP), as these units help control in-train forces through adjustments to power and activation of air brakes and dynamic brakes, or they can add to the operational challenge if poorly positioned.
As the length of a manifest train increases, so too will the complexity of accounting for these in-train forces through train makeup decisions. Longer trains have more cars, possibly a greater variety of car types and sizes, and more requirements for power distributed across the train compared to shorter manifest trains. Moreover, the rail cars in a long train can be experiencing a wider range of grade and curvature conditions as the train spans more terrain. As a practical matter too, long trains can create more challenges for proper train makeup because they are so long and are constructed from blocks of rail cars that are switched to and from other trains and yards enroute. The placement of these blocks requires planning and can take time to execute. While assembling shorter trains also takes planning and time, assembling long trains can present additional challenges and opportunities for errors in car placement due to limited yard space, insufficient track lengths, and added demands on labor.
Regarding train makeup, each railroad has its own placement rules that apply to manifest trains. The Federal Railroad Administration (FRA) and Transport Canada do not prescribe train makeup practices or monitor and assess each railroad’s rules and their consistent application. Guidance for marshalling trains across the North American railroad industry is contained in the “Train Make-up Manual” by the Association of American Railroads (AAR), published in 1992,3 and the “Marshalling Guidelines for
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3 AAR (Association of American Railroads). 1992. “Train Make-up Manual.” Report No. R-802. Chicago: AAR Technical Center.
Safe Operation of Freight Trains,” published by Transport Canada in 2016.4 AAR’s “Train Make-up Manual” was one of the first industrywide train makeup manuals that was written to help railroads manage in-train forces through the control of trailing tonnage, the use of head-end and DP locomotives, and the proper placement of critical car combinations in the train. The Transport Canada marshalling guidelines improved and expanded upon the trailing tonnage method of the “Train Make-up Manual” by providing more robust in-train force limits.
Train makeup decisions and train length must be made with ample consideration of the capabilities and performance of the crews that operate the trains. To this end, railroads have introduced engineer-assist systems to control trains by calculating the best operating profile for both lead and DP locomotives, while considering factors such as the route’s grade and curvature and the train’s length, weight, and composition. The availability of these engineer-assist systems, however, does not reduce the importance of crew readiness and performance in managing the handling requirements of long manifest trains in the varied environments and territories in which they are being used. Yardmasters and dispatchers must also account for these handling challenges when constructing and routing trains.
The operational demands of long manifest trains, therefore, require a combination of responses by railroads that includes well-designed and consistently applied train makeup rules, the deployment of appropriate technology (e.g., DP units, brakes, engineer-assist programs), and assurance of crew readiness and competency. To assess railroad claims about the effectiveness of the responses, the committee examined FRA accident records, which contain causal information that can be used to observe trends in derailments from the kinds of train handling and equipment issues characteristic of in-train forces not being adequately controlled. Having observed an increase in the rate of occurrence of these types of derailments, the committee asked the Class I railroads, through AAR, to provide data on their train operations with sufficient detail to ascertain train type and length for the purpose of more granular assessments of the derailment records. However, restrictive conditions on the data’s availability and use, including a high degree of data aggregation, and preapproval of the analytic methods to be used, foreclosed this option. Nevertheless, a review of publicly available data on train traffic indicates that the average length of manifest trains has been increasing coincidental with an increase in the rate of derailments of interest. Absent more detailed data, the committee was not able to verify
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4 Transport Canada. 2016. “Marshalling Guidelines for the Safe Operation of Freight Trains.” https://tc.canada.ca/en/rail-transportation/publications/marshalling-guidelines-safe-operation-freight-trains.
that the operational demands created by longer manifest trains are being fully controlled, and indeed the limited analyses that could be performed suggest that more targeted safety assurance measures may be needed.
The report also documents the committee’s consultations with national labor union representatives and railroad employees, who raised concerns about the amount and quality of training they receive for safely handling long manifest trains and about the challenges they face assembling the trains correctly. Concerns included the problems crew members can face maintaining communications with one another while maneuvering long trains at yards and during train inspections and repairs, which take more time to perform as train length increases. The potential for error from crew member miscommunication and fatigue was also raised as a concern when the time required to walk the train increases.
The need for railroads to address new and heightened operational challenges created by long manifest trains through systematic, multifaceted means reinforces the importance of provisions in the Rail Safety Improvement Act of 2008 that require Class I railroads to develop and faithfully implement Risk Reduction Programs (RRPs). Specifically, the act requires that each railroad establish an RRP that “systematically evaluates railroad safety risks on its system and manages those risks in order to reduce the numbers and rates of railroad accidents, incidents, injuries, and fatalities.” As written in the legislation, the provision is suggestive of congressional interest in railroads instituting the kind of safety management systems (SMSs) that are now used widely to ensure high levels of safety in numerous other transportation industries, including aviation, passenger rail, and pipelines.
In fulfillment of this legislative requirement, FRA issued a final rule in 2020 requiring Class I railroads to institute RRPs but in a streamlined fashion that does not include many of the components typical of an SMS.5 According to the rule, an RRP is acceptable if it concentrates on managing risks arising from changes involving (1) operating rules, (2) the implementation of new technology, and (3) reductions in crew staffing levels. Notably, the rule does not require a railroad to preemptively address a major change to its operations in an explicit and deliberate manner by identifying the associated hazards, analyzing the potential risks arising from those hazards, and evaluating and explaining how the risks will be managed. Consequently, whether and how railroads are identifying and controlling the hazards and risks arising from their decisions to use long manifest trains is unclear and difficult to ascertain because each railroad’s RRP is proprietary.
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5 Federal Register 85(32), February 18, 2020.
While the Railroad Safety Improvement Act requires railroads to submit the RRPs to FRA for approval, the agency interprets the law’s provisions to imply that railroads must demonstrate that they have a written plan with the requisite minimum elements; however, FRA does not verify the quality and thoroughness of the RRP’s evaluations, analyses, and promised mitigation actions. In summary, the RRP rule was written to allow streamlined safety management systems that do not obligate railroads to anticipate and account for risks arising from all major planned operational changes, including the expanded use of longer manifest trains.
In the committee’s view, the heightened operational challenges and risks from increasing the length of manifest trains need to be recognized and addressed in a deliberate and systematic manner. A high-quality RRP should be expected to explain, among other things, the train makeup protocols that will be employed; the skills, readiness levels, and competencies required for crew members and how they will be met through means such as scheduling and training; and how technologies will be deployed (e.g., DP units, brakes, radio systems, engineer-assist programs) and verified for effectiveness. In turn, FRA should be expected to confirm that each railroad’s RRP does indeed cover such interests, is well reasoned and well justified, and is being faithfully followed and evaluated regularly for effectiveness.
To rectify this problematic shortcoming in the RRP rule, and to ensure that railroads are indeed being proactive in their treatment of the risks from longer trains, the committee recommends the following.
Recommendation 1: The Federal Railroad Administration should revise the Risk Reduction Program (RRP) rule to require railroads to address all major operational changes in their RRPs in an explicit and comprehensive manner. Current RRP requirements do not obligate railroads to address planned operational changes that can affect safety. To the contrary, railroads should be required—consistent with the principles of safety management systems—to identify and analyze the risks associated with all planned significant operational changes and to explain and justify the procedural, technological, and human-systems means that will be used to eliminate or reduce the risks.
Recommendation 1a: The revisions to the Risk Reduction Program (RRP) rule should be written in such a way as to make it clear to railroads that an operational change that is known to increase and add new train integrity and handling challenges, as lengthening manifest trains can do, constitutes an operational change that should be addressed in an RRP. Compliant railroads should be expected to have an RRP that is thorough in describing any operational and handling challenges, assessing their safety risks, explaining how the risks will be
managed through procedural and technological means, and describing how those risk reduction means will be monitored and assessed for effectiveness.
Recommendation 1b: The Federal Railroad Administration (FRA) should seek from Congress the resources required to hire and train a team of auditors skilled in reviewing safety management systems to regularly and critically assess the completeness and quality of each railroad’s Risk Reduction Program (RRP) and its key components. The auditors in turn should enlist FRA inspectors to verify that a railroad’s risk reduction measures are implemented in the field. For trains whose length creates new and increased operational and handling challenges, the FRA auditors and safety inspectors should expect to find that compliant railroads, at a minimum, have
The committee recognizes that individual railroads will differ in the particulars of the operational challenges and risks they face when increasing the length of trains due in part to differences in operating conditions and environments. As a result, the specific measures used by railroads to mitigate risks, as documented in their RRPs, are likely to vary. Indeed, the safety challenges introduced by longer trains are exemplary of why Congress called for a rule requiring RRPs, which can be used by FRA to ensure that railroads are addressing safety risks in a deliberate, proactive, and systematic manner, and not just following the minimum requirements in regulation.
FRA auditors will be responsible for critically reviewing the programs and plans to ensure they are well developed and well justified, consistently executed, and regularly evaluated for effectiveness; the plans should not be paper exercises implemented in a “check-the-box” manner. Through learning and experience, railroads should be expected to evolve their RRPs with risk reduction measures that are increasingly effective. It will also take time and learning for auditors to develop the knowledge and competencies required to fulfill their responsibilities for critical verification.
Recommendation 1c: To aid railroads in the development of increasingly effective measures for reducing risks associated with long trains and to aid auditors in obtaining the requisite knowledge for critically assessing a railroad’s risk reduction measures and their justifications, the Federal Railroad Administration should survey and synthesize industry protocols and best practices on train makeup, crew training, and communications capabilities pertinent to addressing the operational and handling challenges arising from increases in train length under different operating and environmental conditions.
For the reasons given above, it is the committee’s view that when any change in railroad operations, such as increasing train length, creates new or heightened challenges for safety assurance, railroads should be required to assess those challenges and respond to them in a manner that is well reasoned and well documented in an RRP verified by FRA. While some of those responses, such as establishing train makeup rules, may not be subject to the requirements of a specific FRA safety regulation, many of them will. FRA has requirements for crew training and for radio communications among crew members that are intended to be sufficiently robust to address a range of safety assurance challenges. Their applicability and robustness, however, cannot be taken as a given and should be periodically reviewed to determine if modifications are warranted to address changes in railroad operations, practices, and technologies that are introduced abruptly and that also accumulate over time.
The evidence in this report about the added challenges that train crews face when operating and handling manifest trains as they increase in length, including difficulties maintaining radio communications while inspecting and riding equipment, suggests that the time is right for FRA to also take a closer look at the coverage and adequacy of the regulations, FRA standards, industry guidance, and railroad operating procedures and practices
for crew training and radio communications. With these interests in mind, the committee recommends the following.
Recommendation 2: The Federal Railroad Administration should stand up separate working groups under the Railroad Safety Advisory Committee that are tasked with evaluating and providing advice on the following:
2a. Methods and technologies that can be implemented to improve the capabilities, competencies, and training that train crews and other railroad employees require for the safe operation, assembly, and inspection of trains as they become longer; and
2b. Technological means and performance standards for ensuring that train crew members have the capability to communicate, including while inspecting and riding equipment, in a manner that can be continuously maintained and does not create personal safety hazards.
As is typical of Railroad Safety Advisory Committee (RSAC) activities, the working groups should include representatives from railroads and labor organizations and have other members who possess the appropriate technical expertise and representation of interests needed for objective and thorough evaluations that can support consensus advice to FRA and the industry about regulations, standards, and guidance. When evaluating crew competency and training requirements for safely managing the operational challenges associated with increasing train length, the working group should consider, for instance, whether existing training standards, guidance, and practices are sufficient for scenarios involving the handling of long trains, taking into account considerations such as variabilities in terrain and track geometries, in-train forces arising from different train makeups, and conditions that can occur during emergencies. A review of how visual- and motion-based simulator technologies could provide additional realism for training could be part of this effort, informed by their uses in other domains such as aviation and maritime transportation. Likewise, it would behoove the working group on radio communications to evaluate the adequacy of existing regulations, standards, technologies, and practices for ensuring uninterrupted radio communications among crew members operating long trains under different contexts and to consider options for addressing any inadequacies through enhancements in practice and technologies.
RSAC working groups will often recommend changes to FRA regulations and industry standards. While such advice may be forthcoming from the RSAC activities recommended here, the results from the evaluations should inform railroads directly as they address the challenges of long trains in their RRPs.
Trains frequently block pedestrian and motor vehicle traffic as they travel through, and sometimes stand idle in, highway-rail grade crossings. To the extent that the trend toward longer freight trains leads to fewer trains in the aggregate, one would expect potentially fewer blocked crossings. However, a transiting longer train will block a single crossing for a longer period than a shorter train and is more likely to block multiple crossings at the same time. Train transit times through crossings may be slowed further by speed restrictions that all freight trains must abide by but that will impact long trains over a greater distance and for a longer time. It is not clear whether a long train is more likely than a short train to be stationary on a grade crossing for a longer period; however, when trains are being assembled and disassembled in rail yards, longer trains, due to their length, are more likely to exceed the capacity of rail yards built for shorter trains operated in the past and therefore spill out from yards to block grade crossings in the vicinity of the facility.
Apart from the logical inference that a long train will take more time than a short train to transit a grade crossing simply because of its added length, the evidence to suggest that long trains block grade crossings more often, whether idle or moving, is largely anecdotal. The committee heard from leaders of communities impacted by chronic grade-crossing blockages who maintain that train length is a factor in both the frequency and duration of blockages. Some of the communities are in proximity to rail yards where trains frequently stand idle for long periods awaiting entry to the yard and where train assembly and disassembly operations can lead to trains moving back and forth over one or more crossings multiple times. The community leaders complained about the resulting increased response time for emergency responders and the lengthy and recurrent delays incurred by motorists and pedestrians. Examples of interrupted access to neighborhoods, schools, and recreational facilities were given along with instances where impeded pedestrians, including students, maneuvered through stopped trains at considerable personal risk. Such problems are also reported on a regular basis by the media and in a database maintained by FRA for the public to report blocked crossings.6
While state and local laws once gave communities leverage with railroads in seeking remedies to chronic blocked crossings, federal preemption, upheld in the courts based on the Constitution’s interstate commerce clause, has eliminated this leverage. Today, there are no federal laws or regulations pertaining to blocked crossings to replace the vacated state and local laws.
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Accordingly, FRA and the Federal Highway Administration, as well as state and local jurisdictions, do not possess direct means to compel railroads to limit the frequency and duration of blocked crossings. State and local governments can make public investments in grade separations, sometimes with federal aid, or they can choose to close some low-volume crossings to motor vehicle and pedestrian traffic. However, both options can be expensive to the public and/or disruptive such that they are not applicable to many instances where blocked crossings are problematic.
The absence of network-level data from grade-crossing monitoring systems and reliance on anecdotal reports makes it difficult to assess trends in blocked crossings, including impacts from long trains. Inasmuch as frequent and lengthy blocked crossings are a general concern of railroad operations, such monitoring and data gathering would be valuable for finding solutions to blockages that are especially problematic. In short, the committee cannot confirm whether a trend toward long trains is positively or negatively impacting the frequency and duration of blocked grade crossings. However, what is clear is that operating long trains is not necessarily a solution for resolving chronic blocked crossings and may be making the problem worse in some locations. For this reason, the committee recommends the following.
Recommendation 3: Congress should authorize and direct the Federal Railroad Administration to obtain data on an ongoing basis from railroads on blocked highway-rail grade crossings. The railroads should be obligated to deploy automated means for efficiently collecting and reporting the data on a regular and expeditious basis. Data collection should focus first on crossings with gates and other active warning devices that are indicative of higher traffic locations where blockages are likely to be the most disruptive; then data collection should expand to more public highway-rail grade crossings. Individual blockage incidents that exceed defined thresholds of duration should be prioritized for reporting, such as when a crossing is occupied for more than 10 minutes.
Recommendation 3a: The Federal Railroad Administration (FRA) should use these grade-crossing reports to gain a better understanding of the incidence, magnitude, and scope of the blockage problem. For this purpose, FRA should make the reports available to states and their transportation agencies, regional and metropolitan planning organizations, local communities, and the public through means such as portals and other self-service data retrieval tools. FRA should seek from these stakeholders contextual information about problem sites experiencing frequent and lengthy blockages such as by requesting data
on the affected roadway’s traffic volumes, emergency response activity, and significance for accessing neighborhoods, schools, hospitals, and other essential facilities and services during times when crossings were blocked.
Recommendation 3b: Informed by the reports of blockages, the Federal Railroad Administration, should negotiate with the railroads individually and collectively to find solutions to the most problematic blockage sites, reduce the incidence and severity of the problem generally, and determine whether the trend toward increasing train length is creating special problems such as more blocked crossings near rail yards that require targeted remedies.
Recommendation 3c: Congress should give the Federal Railroad Administration authority to impose financial penalties on railroads for problematic blocked crossings. The penalties should be sufficient in magnitude to prompt good faith negotiations to resolve problematic crossing blockages.
The report considers the impacts of longer freight trains on the passenger trains operated by Amtrak. Many of Amtrak’s intercity passenger trains operate over the track of other railroads (called “host railroads”) that were relieved of their common carrier obligation to provide passenger service when Amtrak was created. Federal statute grants Amtrak trains preference over a host railroad’s trains, and thus if operational conflicts arise due to the increasing length of freight trains, this can be a clear public policy matter.
Amtrak maintains and has marshaled evidence that it incurs lengthy service delays when its passenger trains meet or follow freight trains that are too long to pass using available sidings on mainline single-track route segments. A host railroad that is aware of a mismatch between the length of freight trains being operated and the infrastructure available on the route to accommodate the passenger trains operated by Amtrak would seem to conflict with the latter’s statutory right to run ahead of freight trains. To address this problem, the committee recommends the following.
Recommendation 4: Congress should direct and empower the Federal Railroad Administration (FRA) to enforce the performance of host freight railroads in giving preference to Amtrak passenger trains on single-track route segments where there is a mismatch between the length of freight trains being operated and the infrastructure available
on the route segment to accommodate them without delaying Amtrak trains. Under these circumstances, when an Amtrak train experiences delays because of an inability to meet or pass a freight train, the host railroad should be subject to financial penalties. The penalties should be substantial and certain enough to deter this practice and to motivate solutions, including the rightsizing of freight trains to sidings and investments by host railroads in longer sidings. This FRA function would need to be allied with the Surface Transportation Board’s jurisdiction over railroad practices and service.