Testimony and Comments Archive


Comments to the FRA's Notice of Proposed Rulemaking

WASHINGTON, February 16, 2021 - ASLRRA joined AAR in submitting comments to the FRA’s Notice of Proposed Rulemaking on to revise 49 C.F.R. Part 236 governing the Request for Amendment process when material modifications are made to Positive Train Control systems, and to improve the existing annual reporting requirements at § 236.1029(h). ASLRRA is generally supportive of the proposal, but provided several suggestions for changes: including a fourth option of summary approval of an RFA after 45 days, the elimination of COO verification of technical requirements, changes to the requirements of Biannual and Annual Failure Reports, and other information requests.

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AAR and CSLRA in provide comments to California Air Resources Board

WASHINGTON, February 11, 2021 - ASLRRA joined AAR and CSLRA in providing comments to California Air Resources Board’s (“CARB”) October 27, 2020 Notice of Preparation of a Draft Substitute Environmental Document (“Locomotive NOP”) for its proposed In-Use Locomotive Regulation (“Proposed Rules”). The comments note issues with many aspects of the NOP, including assessment of environmental and economic impact of each of the propose changes, and the range of reasonable and feasible alternative presented (as required by CEQA).

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ASLRRA joined AAR in responding to FRA's December 11, 2020 NRPM

WASHINGTON, February 9, 2021 - ASLRRA joined AAR in responding to FRA’s December 11, 2020 NRPM to amend 49 C.F.R. Part 214. AAR and ASLRRA agree with the proposed two changes, one that removes the reference to a specific standard that can become outdated quickly, and the second that codifies a current long-standing waiver related to unmanned drone roadway maintenance machines.

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Comments in response to Federal Motor Carrier Safety Administration'

WASHINGTON, February 3, 2021 - The ASLRRA joined AAR in comments in response to Federal Motor Carrier Safety Administration’s (“FMCSA”) January 4, 2021, proposed regulatory guidance under 49 C.F.R. Part 395 governing “yard moves”. The railroads support the proposed guidance as published, concurring with the call to provide examples of yard moves in guidance, and the proposed examples of what constitutes a “yard”.

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Comments in response to Docket No. EP 704 (Sub-No. 1)

WASHINGTON, January 29, 2021 - ASLRRA filed comments in response to Docket No. EP 704 (Sub-No. 1): Review of Commodity, Boxcar and TOFC/COFC Exemptions. On September 30, 2020, the Surface Transportation Board announced that it was seeking comments concerning a new approach its Office of Economics developed for possible use considering class exemption and revocation issues. We state that, in addition to the issues already present in the 2016 proposal, the 2020 new approach is overly complicated, relies on models or assumptions for which the EO provided no basis for using, the models are internally inconsistent, the added regulatory burdens are not outweighed by any benefits, the costs and complexity of filing a petition to revoke an exemption or seek to have a commodity exempted would be exorbitant, and it relies on data not relevant to short lines.

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