October 2023 - ASLRRA Files Comments in PHMSA NPRM Requiring Train Consist Information
September 2023 - ASLRRA and NRC File Joint Comments Responding to FRA's NPRM on Certification of Signal Employees
September 2023 - ASLRRA Files Comments Responding to FRA's NPRM on Certification of Dispatchers
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.
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.
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.
Crew Size Regulations
Congress, the FRA, and state legislatures have all endeavored to place prescriptive train crew sizes on short line railroads. ASLRRA stands against a regulatory method of dictating the size of a train crew. There are no documented safety benefits tied to the size of a train crew. Requiring more crew members that is necessary shifts resources unnecessarily away from critical and needed infrastructure upgrades, with zero safety benefit.
Recently, the FRA has enacted the Train Crew Safety Requirements rule, which ASLRRA stands firmly against. Along with the American Association of Railroads (AAR), ASLRRA has filed suit to repeal this rulemaking.
Learn more about ASLRRA's position on crew size regulations.
Locomotive Emissions Rulemakings
The California Air Resources Board (CARB) has issued its Locomotive Emissions Rulemaking, which has the potential to put short lines in California out of business – by their own admission. This rulemaking will cause immediate and serious harm to short lines in California, and quickly in seventeen other states which follow California’s lead in environmental policy. The ASLRRA has filed suit in the California ‘s Eastern Circuit Court, and the action has been stayed pending the decision of the Environmental Protection Agency to grant the necessary waiver.
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.
