Experts from ASLRRA’s staff represent the short line industry, and particularly our members, testifying before a variety of Congressional and Regulatory bodies. We are engaged in topics such as rail technology trends, economic impact of rail, increases in truck size and weight, regulations and compliance issues, customer service, interchange challenges, safety and tax policies such as the short line tax credit. Below you will find recent written testimonies given by ASLRRA on behalf of our members.
Washington, D.C., June 17, 2026 — ASLRRA filed comments in response to the Surface Transportation Board's ("STB" or "Board") Advance Notice of Proposed Rulemaking in Docket No. EP 790 evaluating whether it should revise its rules governing "replies to replies" ("rebuttals") in Board proceedings. After evaluating the three proposals presented in the ANPRM, ASLRRA is supportive of the third option proposed by the Board, that it should amend 49 CFR § 1104.13 to allow rebuttals but limited to matters raised on reply, and require that they be submitted within a certain timeframe. This is consistent with other federal agency proceedings, and it preserves procedural efficiency by avoiding superfluous additional briefing. Moreover, ASLRRA recommends that in the interest of efficiency, the Board should not allow surrebuttals.
Washington, D.C., May 29, 2026 — ASLRRA filed comments in response to targeted revisions to EP 782 governing ex parte communications proposed by the Surface Transportation Board (STB). ASLRRA supports STB’s proposals including regulatory language clearly stating that routine status inquiries and procedural communications, and technical and clarifying communications do not constitute prohibited ex parte communications. Allowing ex parte communications with STB staff subject to the public record during informal rulemaking processes and a flexible end date for ex parte meetings on a case-by-case basis to accommodate complexities on a rulemaking were also welcomed.
STB Docket No. EP 779 – Permitting Reform - Environmental Review Process
Washington, D.C., April 24, 2026 — The American Short Line and Regional Railroad Association (ASLRRA) filed comments in support of the Surface Transportation Board’s proposal to clarify, update, and streamline its environmental regulations implementing NEPA. ASLRRA endorses the Board’s efforts to align its rules with recent statutory amendments, CEQ regulatory changes, and case law, and views the proposed reallocations of authority to the Office of Environmental Analysis as a meaningful step toward more efficient decision?making. ASLRRA generally supports the expansion of categorical exclusions, incorporation of statutory deadlines and page limits, elimination of draft EAs and EISs, and the establishment of clearer procedures for environmental reviews, including in emergency situations. From the short line railroad perspective, these changes could significantly reduce time and compliance costs, freeing limited resources for infrastructure investment.
ASLRRA raises two targeted issues for the Board to address in a final rule: (1) clarification of whether the proposed exemption for “purely procedural” actions is intended to align with the existing “ministerial” exemption, and (2) consideration of whether reduced agency workload from streamlined reviews could justify lower filing fees for projects that are categorically excluded or subject to abbreviated environmental review. Overall, ASLRRA concludes that streamlined permitting reform is critical to enabling timely, cost?effective infrastructure development while maintaining reasonable environmental protections.
Washington, D.C., March 10, 2026 – ASLRRA has filed comments in response to the Surface Transportation Board’s (STB) notice of proposed rulemaking (NPRM) to repeal Part 1144, its regulations concerning intramodal rail competition.
Repealing the rule would allow the STB to consider the prescription of through routes, through rates and reciprocal switching agreements on a case-by-case basis under applicable statutory standards.
ASLRRA’s comments share the short line railroad perspective on intramodal rail competition. The Association urges the STB to provide guidance on how it would approach judgement of cases according to the rule, especially if the ruling could have an impact on a short line railroad.
While ASLRRA does not oppose the removal of Part 1144, and submits that doing so may increase competition, it does have concerns for potential inadvertent negative impacts to short line railroads, as a loss of revenue from a single shipper could have a significant adverse effect on a small railroad than a large Class I railroad.
Washington, D.C., January 5, 2026 – ASLRRA and the Association of American Railroads (AAR) filed joint comments in response to the Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers' proposed rule to update the definition of Waters of the United States (WOTUS), EPA-HQ-OW-2025-0322; FRL-11132.1-01-OW. The Associations support the proposed revision to the definition, emphasizing the need for regulatory clarity and predictability for the regulated industry. The comments also urged the agencies to categorically exclude railroad right-of-way drainage ditches from the definition of WOTUS. Furthermore, to avoid uncertainty, the Associations urge the Agencies to exclude "wet season" from the definition of "relatively permanent."
