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., January 10, 2025 – ASLRRA has filed joint comments with the Association of American Railroads (AAR) in response to the Federal Railroad Administration’s (FRA) notice of proposed rulemaking (NPRM) amending the Federal Railroad Safety regulations that address temporary situations where positive train control (PTC) technology is not enabled.
In their comments, ASLRRA and AAR note that they support a rulemaking that would offer necessary and logical relief for operations occurring under unplanned system outages. However, the associations oppose some recommended changes considered unduly burdensome, such as requiring railroads to limit operations to restricted speeds after 24 hours of an unplanned PTC outage, and note that other processes outlined in the rulemaking are impermissibly vague and burdensome.
Washington, D.C., January 14, 2025 – ASLRRA, the Association of American Railroads (AAR) and the American Public Transportation Association (APTA) submitted joint comments in response to the Occupational Safety and Health Administration’s (OSHA) notice of proposed rulemaking (NPRM) concerning workplace heat injury and illness prevention.
The associations ask OSHA to exclude railroads from the proposed rule for several reasons. First, they point out that railroads are subject to Federal Railroad Administration regulations concerning worker safety, and in addition to those rules being comprehensive, OSHA’s authority to regulate ends when another federal agency, like FRA, regulates in the same area. The comments also say OSHA’s rule does not consider the unique nature of the railroad operational environment and imposes overly burdensome and unnecessary requirements.
Washington, D.C., January 7, 2025 – ASLRRA has filed joint comments with the Association of American Railroads (AAR) in response to the Federal Railroad Administration’s (FRA) notice of proposed rulemaking (NPRM) concerning track geometry measurement system (TGMS) inspections. The Associations call on the FRA to withdraw or substantially modify the proposed rule because it imposes arbitrary and unjustified requirements, some of which would be impossible to satisfy. ASLRRA and AAR ask the agency to consider proposing a performance-based TGMS rule, such as that proposed by the industry in 2022, that would promote safety and encourage innovation by pairing a TGMS requirement with reduced visual inspections; providing a more reasonable and balanced approach to the required frequency of inspections and time for remediation; and allowing railroads to implement TGMS without the addition of the costs and inefficiencies that would be imposed by the current proposed rule.
