FRCA Submits Reply Comments to Surface Transportation Board Supporting a Petition filed by Association of American Railroads regarding Rail Cars in Transit/Coal Dust

On Dec 17, 2019  FRCA filed a reply comment to the STB Docket FD 36369, Association of American Railroads Petition for Declaratory Order supporting AAR’s request for a Declaration from the Board that the Clean Water Act’s discharge prohibition and the National Pollutant Discharge Elimination System permitting regime is preempted by the ICC Termination Act (ICCTA) with regard to rail cars in transit.  FRCA’s filing can be read here.