Comments on Proposed CPC-1317 (top fittings) and CPC-1318 (thermal blankets)
|
|
- Alexia Gardner
- 5 years ago
- Views:
Transcription
1 American Fuel & Petrochemical Manufacturers 1667 K Street, NW Suite 700 Washington, DC September 25, office fax afpm.org Via Electronic Mail and Certified Mail Matthew Forister Director Tank Car and HazMat Safety Association of American Railroads 425 Third Street, SW; Suite 1000 Washington, DC mforister@aar.org Comments on Proposed CPC-1317 (top fittings) and CPC-1318 (thermal blankets) Dear Mr. Forister: The American Fuel & Petrochemical Manufacturers (AFPM) objects to the Association of American Railroads (AAR) unilaterally attempting to amend HM-251, the recently finalized rule governing the tank car specifications for shipments of class 3 flammable liquids, including crude oil and ethanol. 1 Specifically, the AAR Tank Car Committee has proposed Casualty Prevention Circular (CPC) 1317 and CPC 1318, which would respectively set tank car specifications for top fittings and thermal blankets. The Pipeline and Hazardous Materials Safety Administration (PHMSA) rejected these proposed tank car specifications only a few months ago in the final HM-251 rule, finding that they would add $1 billion in costs without any corresponding safety benefit. Federal law and common sense make clear that the AAR Tank Car Committee, a private entity, lacks the authority to override a federal agency s recent regulation and impose a billion dollars more in costs on the shipper community. 2 For these reasons, as more fully explained below, AFPM respectfully requests that AAR withdraw proposed CPC 1317 and CPC See Hazardous Materials: Enhanced Tank Car Standards and Operational Controls for High-Hazard Flammable Trains, 80 Fed. Reg. 26,643 (May 8, 2015). 2 Top fittings protections and thermal blankets are not the types of specifications for which standardization is required to facilitate a smooth handoff of tank cars from one railroad to another. Nor are CPC 1317 and CPC 1318 analogous to CPC 1232, a consensus standard developed among shippers, railroads and tank car owners, which began as an effort to enhance crude oil and ethanol tank car safety. PHMSA s Hazardous Materials Regulations (HMR) are the appropriate means to provide a uniform and exclusive standard for tank car specifications. 1
2 AFPM s Substantial Interest in CPC 1317 and 1318 AFPM is a national trade association of more than 400 petroleum refiners and petrochemical manufacturers throughout the United States. AFPM members operate 120 U.S. refineries comprising more than 95 percent of U.S. refining capacity. AFPM members depend upon a plentiful, affordable supply of crude oil as a feedstock for the transportation fuels and petrochemicals that they manufacture. As manufacturers, AFPM members acquire crude oils from multiple sources, with a growing proportion coming from domestic sources, including oil produced from the Bakken formation. Ethanol is also a critical commodity for refiners because the Renewable Fuel Standard ( RFS ) of the Clean Air Act requires ethanol to be blended into gasoline. Safe, reliable, and economic rail transportation of crude oil and ethanol from source to refinery plays a vital role in ensuring the efficient, economical, and continuous operation of our refining and petrochemical operations, which provides uninterrupted supplies of fuels and chemical products to a global economy. Approximately 10 percent of the crude oil processed by AFPM members arrives by rail. Rail shipments are of particular importance for the Bakken formation, where about half of crude oil reaches the market by rail. As a result of the RFS mandate, AFPM members are also impacted by the transportation of ethanol from plant to terminal, since most ethanol is transported to market by rail. In fact, for ethanol, there is no practicable alternative to rail transportation due to the geography of manufacturing and customer sites. In order to ship crude and ethanol, AFPM members lease and own tens of thousands of rail tank cars, a multi-billion dollar investment. Despite representing a significant share of tank cars in the market, AFPM is not a member of the Committee and cannot vote on CPCs or other proposals. The result is that several refiners, including Fortune 500 companies with thousands of tank cars, have no say on the decisions of the Committee. Even those AFPM members who belong to other shipper organizations on the Committee have a limited role to play: the railroads control a supermajority of votes on the Committee. The Proposed CPCs Overturn Key Aspects of HM-251 Proposed CPC 1317 would require top fittings protections for existing tank cars that undergo retrofits pursuant to HM-251. During the public comment period, AAR advocated for such a requirement, while AFPM and other shipper organizations opposed it as unnecessary in light of other safety features on tank cars. 3 PHMSA agreed with AFPM in the final HM-251 rule and chose not to include top fitting protections as part of any retrofit requirement. 4 PHMSA found that the costliness of such a retrofit is not supported with a corresponding Sept. 30, 2014). 3 Compare AAR Comments on HM-251 (filed Sept. 30, 2014) with AFPM Comments on HM-251 (filed 4 80 Fed. Reg. at 26,674. 2
3 appropriate safety benefit. 5 In particular, PHMSA has not required additional top fittings protection for retrofits because the costs of retrofitting existing cars exceed the safety benefits by $500 million to $1 billion Proposed CPC 1318 would require thermal blankets on tank cars shipping class 3 flammable liquids, undoing another integral part of HM-251. In the rulemaking process for HM- 251, AAR advocated for thermal blankets, while AFPM s position was that the thermal protection system need not specifically include a thermal blanket as long as the existing and/or retrofitted equipment (e.g., valves, insulation, etc.) allows the car to survive a 100-minute pool fire. 7 Again, PHMSA agreed with AFPM: PHMSA is not requiring a particular system, but instead is requiring that a thermal protection system meet the [100 minute pool fire] performance standard of and include a reclosing PRD for new construction of the DOT 117 specification tank car. 8 As PHMSA explained, [t]he 100-minute survival time is the existing performance standard for pressure tank cars equipped with a thermal protection system and was established to provide emergency responders with adequate time to assess a derailment, establish perimeters, and evacuate the public as needed, while also giving time to vent the hazardous material from the tank and prevent an energetic failure of the tank car. 9 We are aware no authority that would allow AAR, a private trade association, to undo a PHMSA regulation. In the CPCs at issue, AAR cites its interchange authority as a justification for imposing thermal blankets and top fittings. But Congress granted PHMSA exclusive authority to set tank car standards through the Hazardous Materials Regulations (HMR). 10 And, as a federal agency, PHMSA must provide notice and an opportunity to comment before setting a standard. 11 Those substantive and procedural protections would mean little if AAR establishes the precedent that it may unilaterally void and countermand PHMSA regulations. PHMSA Precedent Prohibits AAR s Attempt to Set Tank Car Standards PHMSA has made plain that the AAR Tank Car Committee lacks authority to set tank car standards. In 2009, PHMSA rejected an AAR attempt to use the Tank Car Committee to establish tank car standards for poison by inhalation (PIH) materials. 12 In the PIH rulemaking, PHMSA rejected CPC 1178, which would have require[d] tank cars transporting anhydrous ammonia and chlorine to meet tank car design standards that are more stringent than those specified in the HMR Id. 6 PHMSA, Final Regulatory Impact Analysis [Docket No. PHMSA ] (HM-251) Hazardous Materials: Enhanced Tank Car Standards and Operational Controls for High-Hazard Flammable Trains; Final Rule Office of Hazardous Material Safety, at 148 (May 2015). 7 Compare AAR Comments, at 40 with AFPM Comments, at Fed. Reg. at 26, Id. 10 See, e.g., 49 U.S.C. 5101, 5103(b)(1)(A)(iii) U.S.C. 500, et seq. 12 See 73 Fed. Reg. 17,818(Apr. 1, 2008) (proposed rule); 74 Fed. Reg. 1,770 (2009) (final rule) Fed. Reg. at 17,
4 PHMSA began its analysis by contrasting the broad sweep of the HMR with the more limited roles of the AAR interchange rules and the Tank Car Committee. PHMSA explained that the HMR establish the packaging and mandate safety features, permissible materials and methods of construction, as well as inspection and maintenance standards for tank cars, while the AAR interchange rules govern the tender and acceptance of rail cars among carriers within the general system of railroad transportation. 14 Historically, the AAR Interchange Rules also have addressed certain subjects, such as rail tank car standards, now covered comprehensively by the HMR. 15 As to the Tank Car Committee, its authority is primarily a ministerial function, designed to ensure that plans to construct, alter, or convert tank car tanks conform to DOT regulations. 16 Moreover, PHMSA reasoned that AAR s attempt to impose more stringent PIH tank car standards through CPC 1178 breached railroads common carrier duty to ship hazardous materials: Railroads, as common carriers, are generally required to provide transportation services in a reasonable manner... Accordingly, interchange requirements, such as Casualty Prevention Circular 1178, that restrict the movement of railroad tank cars that meet DOT standards must be reasonable, and... the burden is on the railroad to establish the reasonableness of the restriction. Two of the factors... in determining the reasonableness of interchange requirements are whether there are Federal safety standards on point and whether a railroad has the ability to seek changes to these standards to meet the safety concerns of the railroad. In fact, DOT has established safety standards for tank cars carrying PIH commodities and, pursuant to this rulemaking, is proposing enhanced standards for tank-head and shell puncture resistance systems for these cars. Through participation in this rulemaking, railroads and other interested parties have the ability to influence the enhanced safety standards ultimately adopted by DOT.... There is, therefore, no reasonable basis for the railroads to implement Casualty Prevention Circular 1178 at this time. 17 PHMSA s reasoning applies equally here. The railroads had every opportunity to participate in the recently completed HM-251 rulemaking process. AAR and its members participated in numerous meetings with DOT, PHMSA and OMB during the rulemaking process, including meetings discussing thermal blankets and top fittings protections. AAR filed comments on the very issues covered in CPC 1317 and CPC 1318, top fittings and thermal blankets. PHMSA s thorough rejection of AAR s comments provides no basis for the railroads to make an end-run around the regulatory process. To the extent that AAR attempts to impose CPC 1317 and CPC 1318, it would represent a violation of the railroads common carrier obligations Id. at 17, Id. (emphasis added). 16 Id. (emphasis added) Fed. Reg. 17,825 (emphasis added). 18 E.g., Riffin v. STB, 733 F.3d 340, 346 (D.C. Cir. 2013) ( Railroads have not only a right but a statutory common carrier obligation to transport hazardous materials where the appropriate agencies have promulgated comprehensive safety regulations. ) (internal quotation marks and citations omitted). Amending HM-251 through the AAR interchange rules would also constitute an unreasonable practice and impose unlawful rules of interchange 4
5 AAR Admits that the Tank Car Committee Lacks Jurisdiction AAR s pending administrative appeal of HM-251 confirms that the Tank Car Committee lacks authority to impose CPC 1317 and CPC On June 12, 2015, AAR filed with DOT an administrative appeal of HM That appeal requests that PHMSA modify the final rule to require a thermal blanket, reiterating the arguments from AAR s earlier comments. 20 The railroads would have no need to appeal if the Committee could simply use AAR s interchange rules to modify the regulation. AAR s appeal is an admission that only PHMSA may modify the rule s specifications for tank cars such as thermal blankets. Conclusion CPC 1317 and CPC 1318 are unlawful, unreasonable and undermine the public process by which PHMSA sets tank car standards. AFPM requests that AAR withdraw the CPCs. Please contact me at if you have any questions about our comments. Sincerely, David N. Friedman Vice President Regulatory Affairs cc: Kathryn Thomson, General Counsel, DOT Vasiliki Tsaganos, Acting Chief Counsel, PHMSA Melissa Porter, Chief Counsel, FRA in violation of the Interstate Commerce Commission Termination Act. See, e.g., 49 U.S.C , 11121; North America Freight Car Association v. BNSF et al., NOR (S.T.B. filed Oct. 9, 2012) (settlement of unreasonable practice claim brought against AAR and railroads for changes made to the interchange rules). 19 AAR Appeal of HM-251 (filed June 12, 2015). 20 Id. at 3. 5
For these reasons, as more fully explained below, AFPM respectfully requests that AAR withdraw proposed CPC-1316.
American Fuel & Petrochemical Manufacturers 1667 K Street, NW Suite 700 Washington, DC 20006 October 9, 2015 Matthew Forister Director Tank Car and HazMat Safety Association of American Railroads 425 Third
More informationBEFORE THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
BEFORE THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION PETITION FOR RULEMAKING TO PHASEOUT THE USE OF TANK CARS NOT MEETING THE HM-246 SPECIFICATION TO TRANSPORT TOXIC-BY-INHALATION MATERIALS
More informationJanuary 24, Re: Small Refiner Exemptions. Dear Administrator Pruitt:
January 24, 2018 The Honorable Scott Pruitt Administrator U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W., 1101A Washington, DC 20460 Re: Small Refiner Exemptions Dear Administrator
More informationNTSB Railroad Hazardous Materials Safety Recommendations Status Presentation to the Transportation Research Board, February 4, 2016
NTSB Railroad Hazardous Materials Safety Recommendations Status Presentation to the Transportation Research Board, February 4, 2016 Paul L. Stancil Sr. Hazmat Accident Investigator 1 Outline Open NTSB
More informationPipeline and Hazardous Materials Safety Administration: Rail Regulatory Update
Pipeline and Hazardous Materials Safety Administration: Rail Regulatory Update Shane Kelley Acting Director, Standards and Rulemaking Division Wednesday, September 6, 2017 FAST Act The Fixing America s
More informationMechanical Inspections and Wheel Impact Load Detector Standards for Trains Transporting Large Amounts of Class 3 Flammable Liquids
This document is scheduled to be published in the Federal Register on 04/27/2015 and available online at http://federalregister.gov/a/2015-09612, and on FDsys.gov 4910-06-P DEPARTMENT OF TRANSPORTATION
More informationDEPARTMENT OF TRANSPORTATION. National Highway Traffic Safety Administration. [Docket No. NHTSA ; Notice 2]
This document is scheduled to be published in the Federal Register on 08/14/2014 and available online at http://federalregister.gov/a/2014-19190, and on FDsys.gov DEPARTMENT OF TRANSPORTATION National
More informationRevision to Mailing Standards for the Transport of Lithium Batteries. ACTION: Notice of prospective revision of standards; invitation to comment.
This document is scheduled to be published in the Federal Register on 02/22/2017 and available online at https://federalregister.gov/d/2017-03397, and on FDsys.gov 7710-12 POSTAL SERVICE Revision to Mailing
More informationINDIRECT LAND USE CHANGE, LOW CARBON FUEL STANDARDS, & CAP AND TRADE: The Role of Biofuels in Greenhouse Gas Regulation
INDIRECT LAND USE CHANGE, LOW CARBON FUEL STANDARDS, & CAP AND TRADE: The Role of Biofuels in Greenhouse Gas Regulation Matthew Carr Policy Director, Industrial & Environmental Section Biotechnology Industry
More informationSUMMARY: FRA is issuing this Emergency Order (EO or Order) to require that trains
This document is scheduled to be published in the Federal Register on 04/27/2015 and available online at http://federalregister.gov/a/2015-09614, and on FDsys.gov 4910-06-P DEPARTMENT OF TRANSPORTATION
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C ) ) ) ) ) ) ) ) ) ) REPLY COMMENTS OF CTIA THE WIRELESS ASSOCIATION
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of Amendment of Parts 1, 2, 22, 24, 27, 90 and 95 of the Commission s Rules to Improve Wireless Coverage Through the Use
More informationUNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION ) Salt River Project Agricultural ) Improvement and Sacramento ) Municipal Utility District ) ) Docket No. EL01-37-000 v. ) ) California
More informationDEPARTMENT OF TRANSPORTATION. Statutory Amendments Affecting Transportation of Agricultural Commodities and Farm Supplies
DEPARTMENT OF TRANSPORTATION [4910-EX-P] Federal Motor Carrier Safety Administration 49 CFR Chapter III Statutory Amendments Affecting Transportation of Agricultural Commodities and Farm Supplies AGENCY:
More information1. Ethanol Shipments by Rail Have Had an Enviable Safety Record
Rail Safety Forum: Transportation of Crude Oil and Ethanol National Transportation Safety Board Testimony of Bob Dinneen, President of the Renewable Fuels Association April 23, 2014 Good afternoon, My
More informationHOUSE BILL NO. HB0235. Sponsored by: Representative(s) Roscoe and Miller A BILL. for. AN ACT relating to motor vehicles; providing that the
0 STATE OF WYOMING LSO-0 HOUSE BILL NO. HB0 Natural gas vehicles. Sponsored by: Representative(s) Roscoe and Miller A BILL for 0 AN ACT relating to motor vehicles; providing that the department of transportation
More informationMay 10, Re: Comments Regarding Causes of Significant Trade Deficits for 2016 Indonesia
National Biodiesel Board 605 Clark Ave. PO Box 104898 Jefferson City, MO 65110-4898 (800) 841-5849 phone (573) 635-7913 fax National Biodiesel Board 1331 Pennsylvania Ave., NW Suite 505 Washington, DC
More informationBEFORE THE SURFACE TRANSPORTATION BOARD COMPLAINT. COME NOW the North America Freight Car Association ("NAFCA") 17884
BEFORE THE SURFACE TRANSPORTATION BOARD NORTH AMERICA FREIGHT CAR ASSOCIATION; AMERICAN FUEL & PETROCHEMICALS MANUFACTURERS; THE CHLORINE INSTITUTE; THE FERTILIZER INSTITUTE; AMERICAN CHEMISTRY COUNCIL;
More informationInternal Revenue Service
Internal Revenue Service Number: 201411004 Release Date: 3/14/2014 Index Number: 7704.00-00, 7704.03-00 ------------------------------------------------ --------------------------------------- --------------------------------------
More informationBEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) APPLICATION
BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Great Oaks Water Company (U-162-W for an Order establishing its authorized cost of capital for the period from July 1, 2019
More informationHours of Service of Drivers: Application for Exemption; Power and. AGENCY: Federal Motor Carrier Safety Administration (FMCSA), DOT.
This document is scheduled to be published in the Federal Register on 09/14/2017 and available online at https://federalregister.gov/d/2017-19512, and on FDsys.gov 4910-EX-P DEPARTMENT OF TRANSPORTATION
More informationEPA s New Nonroad Diesel Rule: Controlling Emissions From Diesel Engines
HULL MCGUIRE PC ATTORNEYS e-mail: info@hullmcguire.com 600 Grant Street U.S. Steel Tower, 32 nd Floor Pittsburgh, PA 15219 412-261-2600 Phone 412-261-2627 Fax www.hullmcguire.com EPA s New Nonroad Diesel
More informationDEPARTMENT OF TRANSPORTATION. Hours of Service of Drivers: Application for Exemption; STC, Inc.
This document is scheduled to be published in the Federal Register on 01/10/2018 and available online at https://federalregister.gov/d/2018-00248, and on FDsys.gov DEPARTMENT OF TRANSPORTATION [4910-EX-P]
More informationTank Car Safety and Security NextGen Project to the Present
U.S. Department of Transportation Federal Railroad Administration Tank Car Safety and Security NextGen Project to the Present 2010 Mechanical Association Railcar Technical Services Annual Conference Karl
More informationPROPOSED RULEMAKING BOARD OF COAL MINE SAFETY 25 PA CODE CHAPTER 208 PREAMBLE
PROPOSED RULEMAKING BOARD OF COAL MINE SAFETY 25 PA CODE CHAPTER 208 PREAMBLE The Board of Coal Mine Safety (Board) is proposing to add 208.72 208.84 (relating to High-Voltage Continuous Mining Machine
More informationSumitomo Rubber Industries, Ltd., Grant of Petition for Decision. AGENCY: National Highway Traffic Safety Administration (NHTSA),
This document is scheduled to be published in the Federal Register on 03/26/2018 and available online at https://federalregister.gov/d/2018-05983, and on FDsys.gov DEPARTMENT OF TRANSPORTATION National
More informationU.S. Rail Crude Oil Traffic
U.S. Rail Crude Oil Traffic Association of American Railroads November 215 Summary U.S. crude oil production has risen sharply in recent years, with much of the increased output moving by rail. In 28,
More informationROLLS-ROYCE CORPORATION (FORMERLY ALLISON ENGINE COMPANY)
Page 1 2010-19-01 ROLLS-ROYCE CORPORATION (FORMERLY ALLISON ENGINE COMPANY) Amendment 39-16429 Docket No. FAA-2009-0811; Directorate Identifier 2008-NE-41-AD PREAMBLE Effective Date (a) This airworthiness
More informationDEPARTMENT OF TRANSPORTATION
This document is scheduled to be published in the Federal Register on 10/01/2014 and available online at http://federalregister.gov/a/2014-23435, and on FDsys.gov DEPARTMENT OF TRANSPORTATION [4910-EX-P]
More information[Docket No. FAA ; Directorate Identifier 2008-SW-44-AD; Amendment ; AD ]
[Federal Register: June 12, 2009 (Volume 74, Number 112)] [Rules and Regulations] [Page 27915-27917] From the Federal Register Online via GPO Access [wais.access.gpo.gov] [DOCID:fr12jn09-6] DEPARTMENT
More informationEthanol Growth and Rail Safety
Ethanol Growth and Rail Safety Committee for a Study of Domestic Transportation of Petroleum, Natural Gas, and Ethanol February 4, 2016 Washington, DC Kelly Davis Director of Regulatory Affairs Renewable
More informationDEPARTMENT OF TRANSPORTATION. Hours of Service; Electronic Logging Devices; Limited 90-Day Waiver; Truck Renting and Leasing Association, Inc.
This document is scheduled to be published in the Federal Register on 01/19/2018 and available online at https://federalregister.gov/d/2018-00843, and on FDsys.gov DEPARTMENT OF TRANSPORTATION [4910-EX-P]
More informationFiled with the Iowa Utilities Board on September 17, 2018, RMU STATE OF IOWA DEPARTMENT OF COMMERCE IOWA UTILITIES BOARD
STATE OF IOWA DEPARTMENT OF COMMERCE IOWA UTILITIES BOARD IN RE: DOCKET NO. RMU-2018-0100 ELECTRIC VEHICLE INFRASTRUCTURE JOINT UTILITY STAKEHOLDER COMMENTS MidAmerican Energy Company ( MidAmerican ),
More informationAgency Information Collection Activities; Proposals, Submissions, and Approvals
This document is scheduled to be published in the Federal Register on 08/22/2018 and available online at https://federalregister.gov/d/2018-18052, and on govinfo.gov DEPARTMENT OF TRANSPORTATION National
More informationDEPARTMENT OF TRANSPORTATION. National Highway Traffic Safety Administration. 49 CFR Part 571. Docket No. NHTSA RIN 2127-AL78
This document is scheduled to be published in the Federal Register on 10/30/2017 and available online at https://federalregister.gov/d/2017-23531, and on FDsys.gov DEPARTMENT OF TRANSPORTATION National
More informationPMAA Protecting and Advocating on Behalf of Petroleum Marketers on Capitol Hill
PMAA Protecting and Advocating on Behalf of Petroleum Marketers on Capitol Hill R O B U N D E RW O O D P R E S I D E N T P E T R O L E U M M A R K E T E R S A S S O C I AT I O N O F A M E R I C A ( P M
More informationMarch 11, Public Docket A U.S. Environmental Protection Agency Room M-1500, Waterside Mall 401 M Street, SW Washington, DC 20460
March 11, 1999 Public Docket A-97-50 U.S. Environmental Protection Agency Room M-1500, Waterside Mall 401 M Street, SW Washington, DC 20460 To Whom It May Concern: The State and Territorial Air Pollution
More informationUpdate: Estimated GHG Increase from Obama Administration Inaction on the 2014 RFS
Update: Estimated GHG Increase from Obama Administration Inaction on the 2014 The blend wall should not be a consideration for setting the, because the United States is using more transportation fuel in
More informationSumitomo Rubber Industries, Ltd., Receipt of Petition for. AGENCY: National Highway Traffic Safety Administration (NHTSA),
This document is scheduled to be published in the Federal Register on 09/22/2017 and available online at https://federalregister.gov/d/2017-20248, and on FDsys.gov DEPARTMENT OF TRANSPORTATION National
More informationFebruary 13, Docket No. ER ; ER Response to Request for Additional Information
California Independent System Operator Corporation The Honorable Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20426 Re: California Independent System
More informationBMW of North America, LLC, Grant of Petition for Decision of. AGENCY: National Highway Traffic Safety Administration (NHTSA),
This document is scheduled to be published in the Federal Register on 11/21/2017 and available online at https://federalregister.gov/d/2017-25168, and on FDsys.gov DEPARTMENT OF TRANSPORTATION National
More informationBrotherhood of Locomotive Engineers and Trainmen A Division of the Rail Conference International Brotherhood of Teamsters
Brotherhood of Locomotive Engineers and Trainmen A Division of the Rail Conference International Brotherhood of Teamsters NATIONAL LEGISLATIVE OFFICE 25 Louisiana Avenue, NW, Room A-704 Washington, DC
More informationApril 9, Fed. Reg. 68,094 (Nov. 4, 2010) C.F.R. Part 80, Subpart N Additional Requirements for Gasoline-Ethanol Blends.
April 9, 2019 To: U.S. Environmental Protection Agency EPA Docket Center, Office of Air and Radiation Docket 1200 Pennsylvania Avenue NW Washington, DC 20460 Re: Modifications to Fuel Regulations: Provide
More informationAdditional Letters. Item 237-6: NIST Handbook 130, Uniform Engine Fuels and Automotive Lubricants Regulation
Title of Content L&R 2013 Interim Agenda Item 237-6: NIST Handbook 130, Uniform Engine Fuels and Automotive Lubricants Regulation Additional Letters Item 237-6: NIST Handbook 130, Uniform Engine Fuels
More informationFILL UP ON FACTS: THE POINT OF OBLIGATION AMERICAN PETROLEUM INSTITUTE. CHAPTER 1 I Introduction to the RFS
FILL UP ON FACTS: CHAPTER 1 I Introduction to the RFS THE POINT OF OBLIGATION AMERICAN PETROLEUM INSTITUTE 1 THE POINT OF OBLIGATION: PASSING THE BUCK TO DISTRIBUTORS Chapter 8: Moving the Point of Obligation
More informationSeptember 2, Ms. Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C.
TEXAS EASTERN TRANSMISSION, LP Mailing Address: 5400 Westheimer Court P. O. Box 1642 Houston, TX 77056-5310 Houston, TX 77251-1642 713.627.5400 main Ms. Kimberly D. Bose, Secretary Federal Energy Regulatory
More informationUNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Regional Reliability Standards ) VAR-002-WECC-2 and VAR-501-WECC-2 ) Docket No. RD15-1-000 COMMENTS OF DOMINION RESOURCES SERVICES,
More information[Docket No. FAA ; Product Identifier 2017-NE-27-AD; Amendment 39- Airworthiness Directives; Lycoming Engines Reciprocating Engines
This document is scheduled to be published in the Federal Register on 08/10/2017 and available online at https://federalregister.gov/d/2017-16968, and on FDsys.gov [4910-13-P] DEPARTMENT OF TRANSPORTATION
More informationFuel Rating Rule Review, 16 CFR Part 306, Project No. R811005
July 2, 2014 Miriam Lederer Federal Trade Commission Office of the Secretary Room H-113 (Annex N) 600 Pennsylvania Avenue NW Washington DC 20580 RE: Fuel Rating Rule Review, 16 CFR Part 306, Project No.
More informationTo: All battery recyclers and battery collection points and related associations.
U.S. Department 1200 New Jersey Avenue, SE of Transportation Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration April 3, 2009 To: All battery recyclers and battery collection
More informationCity of Washington, Kansas Electric Department. Net Metering Policy & Procedure For Customer-Owned Renewable Energy Resources
Ordinance No. 743 Exhibit A City of Washington, Kansas Electric Department Net Metering Policy & Procedure For Customer-Owned Renewable Energy Resources Page 1 of 7 1. INTRODUCTION The provisions of this
More informationComments of the. Ad-Hoc HAV Data Access Coalition. To the. U.S. Department of Transportation. Federal Moto Carrier Safety Administration s
Comments of the Ad-Hoc HAV Data Access Coalition To the U.S. Department of Transportation Federal Moto Carrier Safety Administration s Request for Comments Concerning Federal Motor Carrier Safety Regulations
More informationRe: Further Notice of Proposed Rulemaking, 45 C.F.R. 1627, Subgrants and Membership Fees or Dues
Sent by e-mail to: SubgrantRulemaking@lsc.gov June 10, 2016 Stefanie K. Davis Assistant General Counsel Legal Services Corporation 3333 K Street NW Washington, D.C. 20007 Re: Further Notice of Proposed
More informationDEPARTMENT OF TRANSPORTATION. Parts and Accessories Necessary for Safe Operation; Grant of Exemption For HELP Inc.
This document is scheduled to be published in the Federal Register on 06/22/2015 and available online at http://federalregister.gov/a/2015-15159, and on FDsys.gov DEPARTMENT OF TRANSPORTATION [4910-EX-P]
More informationDEPARTMENT OF TRANSPORTATION. Commercial Driver s License Standards: Application for Exemption; CRST Expedited (CRST)
This document is scheduled to be published in the Federal Register on 01/05/2016 and available online at http://federalregister.gov/a/2015-33136, and on FDsys.gov DEPARTMENT OF TRANSPORTATION [4910-EX-P]
More informationU.S. Rail Crude Oil Traffic
U.S. Rail Crude Oil Traffic Association of American Railroads May 217 Summary U.S. crude oil production has risen sharply in recent years, with much of the increased output moving by rail. In 28, U.S.
More informationAirworthiness Directive
Airworthiness Directive Federal Register Information Header Information DEPARTMENT OF TRANSPORTATION Federal Aviation Administration 14 CFR Part 39 [61 FR 63704 NO. 232 12/02/96] Docket No. 96-ANE-31;
More informationPUBLIC Law, Chapter 539 LD 1535, item 1, 124th Maine State Legislature An Act To Create a Smart Grid Policy in the State
PLEASE NOTE: Legislative Information cannot perform research, provide legal advice, or interpret Maine law. For legal assistance, please contact a qualified attorney. Emergency preamble. Whereas, acts
More informationCONTACT: Rasto Brezny Executive Director Manufacturers of Emission Controls Association 2200 Wilson Boulevard Suite 310 Arlington, VA Tel.
WRITTEN COMMENTS OF THE MANUFACTURERS OF EMISSION CONTROLS ASSOCIATION ON CALIFORNIA AIR RESOURCES BOARD S PROPOSED AMENDMENTS TO CALIFORNIA EMISSION CONTROL SYSTEM WARRANTY REGULATIONS AND MAINTENANCE
More informationToyota Motor North America, Inc. Grant of Petition for Temporary Exemption from an Electrical Safety Requirement of FMVSS No. 305
This document is scheduled to be published in the Federal Register on 01/02/2015 and available online at http://federalregister.gov/a/2014-30749, and on FDsys.gov DEPARTMENT OF TRANSPORTATION National
More informationControl and Prohibition of Air Pollution from Diesel-Powered Motor Vehicles. (Diesel Powered Motor Vehicle Inspection and Maintenance Program)
ENVIRONMENTAL PROTECTION ENVIRONMENTAL REGULATION OFFICE OF AIR QUALITY MANAGEMENT Control and Prohibition of Air Pollution from Diesel-Powered Motor Vehicles (Diesel Powered Motor Vehicle Inspection and
More information1. Thank you for the opportunity to comment on the Low Emissions Economy Issues Paper ( Issues Paper ).
20 September 2017 Low-emissions economy inquiry New Zealand Productivity Commission PO Box 8036 The Terrace Wellington 6143 info@productivity.govt.nz Dear Commission members, Re: Orion submission on Low
More informationDANIEL LEUCKX. Recent and proposed legislative developments. PLATTS, Middle Distillates 4 th Annual Conference. Policy Executive, EUROPIA
DANIEL LEUCKX Policy Executive, EUROPIA Recent and proposed legislative developments PLATTS, Middle Distillates 4 th Annual Conference Agenda 1) About EUROPIA & CONCAWE 2) Recent and proposed legislative
More informationP.L. 2007, c.348 Approved January 13, 2008
P.L. 2007, c.348 Approved January 13, 2008 INTRODUCED JUNE 11, 2007 ASSEMBLY, No. 4314 STATE OF NEW JERSEY 212th LEGISLATURE Sponsored by: Assemblyman JOHN S. WISNIEWSKI District 19 (Middlesex) Assemblyman
More informationCity of, Kansas Electric Department. Net Metering Policy & Procedures for Customer-Owned Renewable Energy Resources
Ordinance No. Exhibit A ----------------------------------------- City of, Kansas Electric Department Net Metering Policy & Procedures for Customer-Owned Renewable Energy Resources -------------------------------------
More informationDEPARTMENT OF TRANSPORTATION. Commercial Driver s License Standards: Application for Exemption; Daimler Trucks North America (Daimler)
This document is scheduled to be published in the Federal Register on 08/17/2017 and available online at https://federalregister.gov/d/2017-17393, and on FDsys.gov DEPARTMENT OF TRANSPORTATION [4910-EX-P]
More informationDepartment of Transportation. National Highway Traffic Safety Administration. [Docket No. NHTSA ; Notice 2]
This document is scheduled to be published in the Federal Register on 06/27/2013 and available online at http://federalregister.gov/a/2013-15470, and on FDsys.gov Department of Transportation National
More informationThe Municipal Perspective on CBR (and Other Flammable Hazmat)
Northwestern University Transportation Center Business Advisory Council (BAC) April 21, 2015 The Municipal Perspective on CBR (and Other Flammable Hazmat) Karen Darch Village President, Barrington, Illinois
More informationElectronic On-Board Recorders and Hours of Service Supporting Documents. AGENCY: Federal Motor Carrier Safety Administration (FMCSA), DOT.
This document is scheduled to be published in the Federal Register on 04/02/2012 and available online at http://federalregister.gov/a/2012-07899, and on FDsys.gov DEPARTMENT OF TRANSPORTATION 4910-EX-P
More informationDEPARTMENT OF TRANSPORTATION. Hours of Service; Electronic Logging Devices; Limited 90-Day Waiver for the Transportation of Agricultural Commodities
This document is scheduled to be published in the Federal Register on 12/20/2017 and available online at https://federalregister.gov/d/2017-27311, and on FDsys.gov 3 DEPARTMENT OF TRANSPORTATION [4910-EX-P]
More informationCrude Oil by Rail Ron Hynes FRA Office of Safety Director, Office of Technical Oversight
Spill Control Association of America Crude Oil by Rail Ron Hynes FRA Office of Safety Director, Office of Technical Oversight Number 1 Priority is Safety Rail Transportation Has Never Been Safer 2 1 Hazardous
More informationThank you, Chairman Shimkus and Ranking Member Tonko. I appreciate the opportunity to
Thank you, Chairman Shimkus and Ranking Member Tonko. I appreciate the opportunity to testify today on behalf of the National Corn Growers Association (NCGA). NCGA represents nearly 40,000 dues-paying
More informationTaxis and Accessible Services Division Medallion Reform Background May 1, 2018
Introduction: Taxis and Accessible Services Division Medallion Reform Background May 1, 2018 SFMTA s Taxis and Accessible Services Division is responsible for the regulation of the private businesses that
More information[Docket No. FAA ; Directorate Identifier 2016-NE-09-AD] Airworthiness Directives; Pratt & Whitney Division Turbofan Engines
This document is scheduled to be published in the Federal Register on 04/20/2016 and available online at http://federalregister.gov/a/2016-09122, and on FDsys.gov [4910-13-P] DEPARTMENT OF TRANSPORTATION
More informationJoint Operating Procedures for First Nations Consultation on Energy Resource Activities
Joint Operating Procedures for First Nations Consultation on Energy Resource Activities October 31, 2018 Contents Revision History... iv Definitions of Key Terms... v 1 Background... 1 2 Roles and Responsibilities...
More informationFMCSA Regulatory Update: National Registry, Electronic Logging Devices and Other Significant Activities
FMCSA Regulatory Update: National Registry, Electronic Logging Devices and Other Significant Activities Chuck Horan Director, Carrier, Driver and Vehicle Safety Standards September, 2015 National Registry
More informationRe: Comments on EPA s E15 Misfueling Rule (40 CFR Part 80 on November 4, 2010)
January 3, 2011 Environmental Working Group 1436 U. St., N.W. Suite 100 Washington, DC 20009 Air and Radiation Docket Docket ID No. EPA HQ OAR 2010 0448 Environmental Protection Agency Mailcode: 6102T
More informationUNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Electric Storage Participation in ) Markets Operated by Regional ) Docket Nos. RM16-23; AD16-20 Transmission Organizations and )
More informationDEPARTMENT OF TRANSPORTATION. National Highway Traffic Safety Administration. [Docket No. NHTSA ; Notice 2]
This document is scheduled to be published in the Federal Register on 12/30/2014 and available online at http://federalregister.gov/a/2014-30487, and on FDsys.gov DEPARTMENT OF TRANSPORTATION National
More informationDEPARTMENT OF TRANSPORTATION
This document is scheduled to be published in the Federal Register on 08/28/2012 and available online at http://federalregister.gov/a/2012-20756, and on FDsys.gov DEPARTMENT OF TRANSPORTATION [910-EX-P]
More informationFederal And New York Tax Incentives For Alternative Fuels
Federal And New York Tax Incentives For Alternative Fuels NE Sun Grant Regional Feedstock Summit November 13, 2007 Statler Hotel at Cornell University Ithaca, New York 14853 Presented by: Gerald F. Stack
More informationDEPARTMENT OF TRANSPORTATION. National Highway Traffic Safety Administration. [Docket No. NHTSA ]
This document is scheduled to be published in the Federal Register on 06/28/2013 and available online at http://federalregister.gov/a/2013-15534, and on FDsys.gov DEPARTMENT OF TRANSPORTATION National
More informationASSEMBLY, No STATE OF NEW JERSEY. 218th LEGISLATURE PRE-FILED FOR INTRODUCTION IN THE 2018 SESSION
ASSEMBLY, No. STATE OF NEW JERSEY th LEGISLATURE PRE-FILED FOR INTRODUCTION IN THE 0 SESSION Sponsored by: Assemblyman JAMES J. KENNEDY District (Middlesex, Somerset and Union) Assemblywoman NANCY J. PINKIN
More informationHours of Service (HOS) of Drivers; U.S. Department of Energy (DOE); Application for Renewal of Exemption
This document is scheduled to be published in the Federal Register on 03/27/2015 and available online at http://federalregister.gov/a/2015-07060, and on FDsys.gov DEPARTMENT OF TRANSPORTATION Federal Motor
More informationSTATE OF NEW JERSEY. SENATE, No th LEGISLATURE. Sponsored by: Senator BOB SMITH District 17 (Middlesex and Somerset)
SENATE, No. STATE OF NEW JERSEY th LEGISLATURE INTRODUCED JUNE, 0 Sponsored by: Senator BOB SMITH District (Middlesex and Somerset) SYNOPSIS Revises Franchise Practices Act. CURRENT VERSION OF TEXT As
More informationLYCOMING ENGINES AND TELEDYNE CONTINENTAL MOTORS
Page 1 011-13-03 LYCOMING ENGINES AND TELEDYNE CONTINENTAL MOTORS (TYPE CERTIFICATE PREVIOUSLY HELD BY TEXTRON LYCOMING) AND TELEDYNE CONTINENTAL MOTORS (TCM) TURBOCHARGED RECIPROCATING ENGINES Amendment
More informationDEPARTMENT OF TRANSPORTATION. Commercial Driver s License Standards: Application for Renewal of Exemption; Daimler Trucks North America (Daimler)
This document is scheduled to be published in the Federal Register on 04/16/2015 and available online at http://federalregister.gov/a/2015-08726, and on FDsys.gov DEPARTMENT OF TRANSPORTATION [4910-EX-P]
More informationUNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION ) ) ) )
UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION The Nevada Hydro Company, Inc. Docket No. EL18-131-000 SOUTHERN CALIFORNIA EDISON COMPANY'S COMMENTS AND PROTEST TO THE NEVADA HYDRO
More informationFEDERAL MOTOR CARRIER SAFETY ADMINISTRATION
FEDERAL MOTOR CARRIER SAFETY ADMINISTRATION Regulatory 2016/17 Federal Regulations (Items in red text indicate a change of status or new item) November 22, 2017 Key s on IANA Policy Issues The Unified
More informationUNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Essential Reliability Services and the ) Evolving Bulk-Power System ) Docket No. RM16-6-000 Primary Frequency Response ) COMMENTS
More informationOutline. Purpose. TDG Regulatory Update
TDG Regulatory Update COSTHA Conference, April 2015 Benoit Turcotte Director, Regulatory Affairs Branch Transportation of Dangerous Goods Directorate RDIMS: 10567947 Purpose To provide an update on recent
More informationFiled with the Iowa Utilities Board on July 27, 2018, TF STATE OF IOWA DEPARTMENT OF COMMERCE IOWA UTILITIES BOARD
STATE OF IOWA DEPARTMENT OF COMMERCE IOWA UTILITIES BOARD IN RE: : : Iowa 80 Truckstop, Inc. and : DOCKET NO. DRU- Truckstops of Iowa, Inc., : : : PETITION FOR DECLARATORY ORDER Iowa 80 Truckstop, Inc.,
More informationThe World Has Changed Hazmat Shipping Requirements
The World Has Changed Hazmat Shipping Requirements Southwest Association of Rail Shippers February 27, 2014 James H. Rader Senior Vice President, Watco Compliance Services 2 North America s industrial
More informationCHAPTER 12 TOW TRUCKS
CHAPTER 12 TOW TRUCKS SOURCE: Chapter 12 added by P.L. 23-144:3 (Jan. 2, 1997). 12101 Definitions. 12102. Business Requirements. 12103. Department of Revenue and Taxation Duties. 12104. Notice Requirements.
More informationThe material incorporated by reference may be examined also at any state publications library.
BASIS, PURPOSE AND STATUTORY AUTHORITY The basis and purpose of these rules is to provide minimum requirements for the regulation of motor vehicle safety, hours of service of drivers, and qualification
More informationPREPARED REBUTTAL TESTIMONY OF BETH MUSICH SOUTHERN CALIFORNIA GAS COMPANY AND SAN DIEGO GAS & ELECTRIC COMPANY
Application No: A.14-06-021 Exhibit No.: Witness: Beth Musich Application of Southern California Gas Company (U 904 G) and San Diego Gas & Electric Company (U 902 G) for Low Operational Flow Order and
More informationUnderstanding Berea s Wholesale Electric Power Purchase Contracts. Mr. LaFontaine has asked for answers to several questions about Berea s
1 LaFontaine and KyMEA - AMP contracts Understanding Berea s Wholesale Electric Power Purchase Contracts Mr. LaFontaine has asked for answers to several questions about Berea s wholesale electric power
More informationFederal Motor Vehicle Safety Standards; Tire Selection and Rims
This document is scheduled to be published in the Federal Register on 11/09/2016 and available online at https://federalregister.gov/d/2016-27051, and on FDsys.gov DEPARTMENT OF TRANSPORTATION National
More informationDEPARTMENT OF TRANSPORTATION
This document is scheduled to be published in the Federal Register on 01/19/2018 and available online at https://federalregister.gov/d/2018-00842, and on FDsys.gov DEPARTMENT OF TRANSPORTATION [4910-EX-P]
More informationPRATT AND WHITNEY CANADA CORP.
Page 1 2010-17-06 PRATT AND WHITNEY CANADA CORP. (FORMERLY PRATT & WHITNEY CANADA, INC.) Amendment 39-16398 Docket No. FAA-2010-0245; DIRECTORATE IDENTIFIER 2010-NE-15-AD. PREAMBLE Effective Date (a) This
More informationTransportation and Transfer
Participant Guide Module 4 Transportation and Transfer Module Objective Upon completion of this module, participants should be able to describe how ethanol-blended fuels are transported and transferred
More information