Comments on PHMSA’s Advanced Notice of Proposed Rulemaking for Oil Spill Response Plans for High-Hazard Flammable Trains
On September 30, 2014, the Clinic, in collaboration with Earthjustice, the Sierra Club, ForestEthics, and Oil Change International submitted comments on an Advanced Notice of Proposed Rulemaking issued by the Pipeline and Hazardous Materials Safety Administration (PHMSA) of the U.S. Department of Transportation (DOT) on potential revisions to its rules establishing the threshold for comprehensive oil spill response planning (OSRPs) by railroads carrying crude oil.