Clinic Submits Comments on Proposed Rulemaking Regarding Oil Spill Response Planning by Railroads

The Emmett Environmental Law & Policy Clinic, in collaboration with Earthjustice, the Sierra Club, ForestEthics, and Oil Change International submitted comments today 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 railraods carrying crude oil.

In the comments, the Clinic and other organizations urge the PHMSA to: 1) require the preparation of comprehensive OSRPs for all trains carrying crude oil; 2) provide greater specificity regarding requirements for comprehensive OSRPs; and 3) mandate that comprehensive OSRPs be provided to state, tribal, and local emergency response commissions and committees as well as the general public.

Clinic student Justin Lu (JD’16) worked on the comments with Senior Clinical Instructor and Staff Attorney, Shaun A. Goho.

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