Reasonable Regulatory Environment

Our Ask:

  • Recognize the constraints of Class II and III small business freight railroads when developing regulations.


Congressional Actions

June 2022 - ASLRRA Provides Written Testimony for U.S. House T & I Hearing – Examining Rail Safety  ASLRRA advocates for the industry on Capitol Hill urging Congress and regulating bodies to advance safety rules and regulations with known safety benefits and to foster – not hinder – technology and operational practices that improve rail safety.

Regulatory Actions

August 2021 - ASLRRA responds to the FRA's August 23, 2021 information request on Part 219
ASLRRA states that the paperwork requirement for locomotive safety standards is capricious and burdensome.

Surface Transportation Board Actions

February 2022 - ASLRRA Submits Comments and Testimony to STB for EP 711 (Forced Switching) Hearing March 15 and 16. ASLRRA discusses the negative impact of forced switching on the industry.

February 2022 - ASLRRA Files Comments in Response to the Surface Transportation Board Request Regarding First-mile/last-mile Service (Ex parte 767) ASLRRA responds to the Board describing the difficulty of providing a single metric for measurement across 600 short lines, and the error of including short lines in a Class I-focused issue.

December 2021 - ASLRRA files comments on the Surface Transportation Board's Docket EP 767
ASLRRA cautions against requiring short line railroads to bear the burden of creating a metric and tracking system across 600 unique entities.

The Regulatory Flexibility Act (RFA) and the Small Business Regulatory Enforcement and Fairness Act (SBREFA) require that agencies exercise utmost care and discretion in evaluating how regulations they promulgate affect small businesses. Unfortunately, too often agencies ignore the spirit and letter of RFA and SBREFA and force small businesses into an onerous position where they must follow costly, duplicative mandates that are too burdensome to comply with – ultimately causing extreme duress and economic harm – without providing any safety or security benefit.

Laws like RFA and SBREFA should be a fundamental guidepost that agencies follow in developing regulatory measures. In no case should any agency move forward with imposing mandates without taking a thorough, well-thought look – and dialogue with organizations like ASLRRA – at what the mandate would mean for small business.

Recently, the Small Business Administration (SBA) weighed in on behalf of small business short lines in the Federal Railroad Administration’s Notice of Proposed Rulemaking on crew size mandates. Click here for more information on this regulation.

Iowa Interstate Railroad

Paducah & Louisville Railroad


Key Takeaway:

Short line railroads are small businesses as defined by the Small Business Administration — they are not megacorporations. When crafting regulations, it is imperative that agencies use deftness and precision to avoid instituting unnecessary, disproportionately burdensome compliance measures for small businesses.