Emergency Order
UNITED STATES DEPARTMENT OF TRANSPORTATION
)
Petroleum Crude Oil Railroad Carriers
)

)

Docket No. DOT-OST-2014-0067

______________________________________________________________________________
EMERGENCY RESTRICTION/PROHIBITION ORDER
This notice constitutes an Emergency Restriction/Prohibition Order (Order) by the United States
Department of Transportation (DOT; Department) pursuant to 49 U.S.C. 5121(d). This Order is
issued to all railroad carriers that transport in a single train in commerce within the United
States, 1,000,000 gallons or more of UN 1267, Petroleum crude oil, Class 3,[1]sourced from the
Bakken shale formation in the Williston Basin (Bakken crude oil). By this Order, DOT is
requiring that each railroad carrier provide the State Emergency Response Commission (SERC)
for each state in which it operates trains transporting 1,000,000 gallons or more of Bakken
crude oil, notification regarding the expected movement of such trains through the counties in
the state. The notification shall identify each county, or a particular state or commonwealth’s
equivalent jurisdiction (e.g., Louisiana parishes, Alaska boroughs, Virginia independent cities)
(county), in the state through which the trains will operate.
Upon information derived from recent railroad accidents and subsequent DOT investigations, the
Secretary of Transportation (Secretary) has found that an unsafe condition or an unsafe practice
is causing or otherwise constitutes an imminent hazard to the safe transportation of hazardous
materials. Specifically, a pattern of releases and fires involving petroleum crude oil shipments
originating from the Bakken and being transported by rail constitute an imminent hazard under
49 U.S.C. 5121(d).
EFFECTIVE IMMEDIATELY ANY RAILROAD CARRIER IDENTIFIED BY THIS
ORDER:
Shall, within 30 days of the date of this Order, provide certain information in writing to the
SERC in each state in which the railroad carrier operates trains transporting 1,000,000 gallons or
more of Bakken crude oil. The contact information for each SERC is located on the U.S.
Environmental Protection Agency’s (EPA) website related to the Emergency Planning and
Community Right-to-Know Act of 1986 (ECPRA).[2] If notification is not made to a SERC
within 30 days of the date of this Order, a railroad is prohibited from operating any train
transporting 1,000,000 gallons or more of Bakken crude oil in that state until such notification is

 provided. The notification must provide information regarding the estimated volumes and
frequencies of train traffic implicated. Specifically, the notification must: (a) provide a
reasonable estimate of the number of trains implicated by this Order that are expected to travel,
per week, through each county within the state; (b) identify and describe the petroleum crude oil
expected to be transported in accordance with 49 CFR part 172, subpart C; (c) provide all
applicable emergency response information required by 49 CFR part 172, subpart G; and, (d)
identify the routes over which the material will be transported. This notification also must
identify at least one point of contact at the railroad (including name, title, phone number and
address) responsible for serving as the point of contact for SERCs and relevant emergency
responders related to the railroad’s transportation of Bakken crude oil. To ensure that the
information provided to a SERC remains reliable, railroad carriers shall update notifications
prior to making any material changes in the estimated volumes or frequencies of trains traveling
through a county. Railroad carriers must assist the SERCs as necessary to aid in the
dissemination of the information to the appropriate emergency responders in affected
counties. Copies of railroad notifications to SERCs must be made available to the DOT’s
Federal Railroad Administration (FRA) upon request. This Order does not preclude railroad
carriers from taking any additional steps to communicate with state and local emergency
responders regarding the transportation of hazardous materials or any other commodities within a
state or local jurisdiction.
This Order applies to all railroad carriers who transport 1,000,000 gallons or more of Bakken
crude oil in a single train in commerce within the United States, and its officers, directors,
employees, subcontractors, and agents. This Order is effective immediately and remains in
effect unless withdrawn in writing by the Secretary, or until it otherwise expires by operation of
regulation and/or law.
I.

Authority
The Secretary of Transportation has the authority to regulate the transportation of
petroleum crude oil in commerce. 49 U.S.C. 5103(b). The Secretary of Transportation has
designated petroleum crude oil, UN 1267, 3, Packing Group I, II, or III, as a hazardous material
subject to the requirements of DOT’s Hazardous Materials Regulation (HMR) (49 CFR parts
171 to 180). 49 U.S.C. 5121(d); 49 U.S.C. 5103(a). Commerce is as defined by 49 U.S.C.
5102(1) and 49 CFR 171.8, and “transportation” or “transport” are as defined by 49 U.S.C.
5102(13) and 49 CFR 171.8. A “railroad” is as defined by 49 CFR 171.8. Accordingly,
railroads that transport petroleum crude oil in commerce by rail are subject to the authority and
jurisdiction of the Secretary, including the authority to impose emergency restrictions,
prohibitions, recalls, or out-of-service orders, without notice or an opportunity for hearing, to
the extent necessary to abate the imminent hazard. 49 U.S.C. 5121(d).

II.

Background/Basis for Order
An imminent hazard, as defined by 49 U.S.C. 5102(5), constitutes the existence of a condition
relating to hazardous materials that presents a substantial likelihood that death, serious illness,
severe personal injury, or a substantial endangerment to health, property, or the environment

 may occur before the reasonably foreseeable completion date of a formal proceeding begun to
lessen the risk that death, illness, injury or endangerment.
The number and type of petroleum crude oil
railroad accidents described below that have occurred during the
last year is startling, and the quantity of petroleum crude oil
spilled as a result of those accidents is voluminous in
comparison to past precedents. Due to the volume of crude oil
currently being shipped by railroads, the demonstrated recent
propensity for rail accidents involving trains transporting
crude oil to occur, and the subsequent releases of large
quantities of crude oil into the environment and the imminent
hazard those releases present, this Order requires that
railroads take the action described above to assist emergency
responders in mitigating the effects of accidents involving
petroleum crude oil trains. Releases of petroleum crude oil,
subsequent fires, and environmental damage resulting from such
releases represent an imminent hazard as defined by 49 U.S.C.
5102(5), presenting a substantial likelihood that death, serious
illness, severe personal injury, or a substantial endangerment
to health, property, or the environment may occur.
<>A.

[3]

Shipping hazardous materials is inherently
dangerous. Transporting petroleum crude oil can be problematic
if the crude oil is released into the environment because of its
flammability. This risk of ignition is compounded in the
context of rail transportation because petroleum crude oil is
commonly shipped in unit trains that may consist of over 100
loaded tank cars. With the rising demand for rail carriage of
petroleum crude oil[4] throughout the United States, the risk of
rail incidents increases along with the increase in the volume
of crude oil shipped. There have been several significant
derailments in the U.S. and Canada over the last ten months
causing deaths and property and environmental damage that

 involved petroleum crude oil shipments. These accidents have
demonstrated the need for emergency action to address unsafe
conditions or practices in the shipment of petroleum crude oil
by rail.
Most recently, on April 30, 2014, an eastbound
CSX Transportation, Inc. (CSX) unit train consisting of 105 tank
cars loaded with petroleum crude oil derailed in Lynchburg,
Virginia. Seventeen of the train’s cars derailed, and one of
the tank cars was breached. A petroleum crude oil fire ensued,
and emergency responders evacuated approximately 350 individuals
from the immediate area. Three of the derailed tank cars
containing petroleum crude oil came to rest in the adjacent
James River, spilling up to 30,000 gallons of petroleum crude
oil into the river. The National Transportation Safety Board
(NTSB) and DOT are both investigating this accident.
On December 30, 2013, 13 cars in a westbound BNSF
Railway (BNSF) grain train derailed near Casselton, North
Dakota,
fouling an adjacent main track. At the same time, an
[5]

eastbound BNSF petroleum crude oil unit train with 106 cars was
operating on that adjacent main track. The petroleum crude oil
unit train reduced its speed but collided with the derailed car
that was fouling the main track, resulting in the derailment of
the lead locomotives and the first 21 cars of the petroleum
crude oil unit train. Eighteen of the 21 derailed tank cars
ruptured, and an estimated 400,000 gallons of petroleum crude
oil was released. The ruptured tank cars ignited, causing a
significant fire.
Approximately 1,400 people were
evacuated. Damages from the derailment have been estimated at
$8 million.
On November 8, 2013, a 90-car petroleum crude oil
train operated by Alabama & Gulf Coast Railway derailed in a
rural area near Aliceville, Alabama. The petroleum crude oil
shipment originated in North Dakota, and was bound for Walnut

 Hill, Florida, to be transported by a regional pipeline to a
refinery in Saraland, Alabama. Twenty-six cars derailed,
resulting in eleven cars impinged by a crude oil pool fire. An
undetermined amount of petroleum crude oil escaped from derailed
cars and found its way into wetlands area nearby the derailment
site. Clean up costs are estimated at $3.9 million.
On July 6, 2013, a catastrophic railroad accident involving a U.S. railroad company
occurred in Lac-Mégantic, Quebec, Canada, when an unattended freight train transporting
petroleum crude oil rolled down a descending grade and subsequently derailed.[6] The
subsequent fires, along with other effects of the accident, resulted in the confirmed deaths
of 47 individuals. In addition, the derailment caused extensive damage to the town center,
a release of hazardous materials that will require substantial clean-up costs, and the
evacuation of approximately 2,000 people from the surrounding area.
B. DOT Actions and Investigations
In the wake of these and other events, PHMSA and
FRA have taken a number of steps to increase the safety of
petroleum crude oil shipments by rail. Following the LacMégantic derailment, FRA issued Emergency Order No. 28 (EO 28),
which established certain securement requirements for unattended
trains and rail equipment, including petroleum crude oil unit
trains. EO 28 remains in effect until further notice by
FRA. In addition, on August 7, 2013, PHMSA and FRA issued
Safety Advisory 2013-06, which made a number of safety-related
recommendations to railroads and hazardous materials offerors
operating in the United States, including the recommendation
that offerors evaluate their processes to ensure that hazardous
materials are properly classed and described in accordance with
the HMR, and the recommendation that offerors and carriers
conduct reviews of their safety and security plans. On August
27-28, 2013, FRA and PHMSA held a public meeting with industry
stakeholders to solicit input on a comprehensive review of
safety regulations contained in 49 CFR part 174 applicable to
the safe transportation of hazardous materials by rail.

PHMSA

 and FRA have initiated a rulemaking (RIN 2137-AF07) to address
comments received as a result of the public meeting.
On August 29, 2013, FRA convened an emergency session of the Railroad Safety Advisory
Committee (RSAC). RSAC is a group composed of railroad industry, labor, and
governmental representatives who develop recommendations on new regulatory standards
and other rail safety programs. During the emergency meeting, RSAC established three
collaborative working groups to formulate new rulemaking recommendations regarding
hazardous materials transportation by rail, appropriate train crew sizes, and train
securement procedures. Each of these working groups has met on a regular basis and has
now finished with its work. DOT has initiated rulemaking proceedings as appropriate to
codify in Federal regulation certain of the items discussed by the working groups.
On September 6, 2013, PHMSA issued an Advanced
Notice of Proposed Rulemaking (ANPRM (HM-251); 78 FR 54849) to
solicit comments on petitions for rulemaking and NTSB
recommendations related to rail hazmat safety, including
regulations for DOT specification tank cars most commonly used
to move crude oil by rail. The comment period closed on
December 5, 2013, and PHMSA received nearly 150 substantive
comments representing over 150,000 stakeholders. PHMSA, in
cooperation with FRA, has developed a comprehensive Notice of
Proposed Rulemaking (NPRM). The NPRM is titled: PHMSA-2012-0082
(HM-251; RIN 2137-AE91): Hazardous Materials: Enhanced Tank Car
Standards and Operational Controls for High-Hazard Flammable
Trains. The NPRM is under review by the Office of Management and
Budget pursuant to Executive Order 12866. (See
http://www.reginfo.gov/public).
PHMSA and FRA issued a supplementary safety advisory, Safety Advisory 2013-07,
on November 20, 2013, to emphasize the importance of proper characterization,
classification, and selection of a packing group for Class 3 materials (flammable liquids,
including petroleum crude oil), and to reinforce the need to follow the Federal hazardous
materials regulations for safety and security planning. On January 2, 2014, PHMSA issued
a Safety Alert, which warned of crude oil variability and emphasized that unprocessed
crude oil may affect the integrity of packaging or present additional hazards related to
corrosivity, sulfur content, and dissolved gas content. Further, noting that mined natural
resources, such as crude oil, may have widely variable chemical compositions and
properties, the Safety Alert noted that crude oil being transported from the Bakken region
of North Dakota may be more flammable than traditional heavy crude oil.

 On January 16, 2014, the Secretary met with
members of the rail and the petroleum industries in a Call to
Action to address the risks associated with the transportation
of crude oil by rail. As a result, on February 21, 2014, the
Secretary of Transportation sent a letter to the President and
Chief Executive Officer at the AAR requesting that he and his
members subscribe to voluntary actions to improve the safe
transportation of crude oil by rail. These include: speed
restrictions, braking signal propagation systems, routing
analyses, additional track and rail integrity inspections, more
frequent mechanical inspections, development of an emergency
response inventory, funding for emergency responder training,
and continued communication with communities about the hazards
of crude oil being transported by rail. To date, all Class I
railroads have subscribed to the voluntary actions and several
more have expressed their intent to sign.
On February 25, 2014, DOT issued an Emergency
Order requiring all shippers to test product from the Bakken to
ensure the proper classification of crude oil in accordance with
the HMR before it is transported by rail, while also prohibiting
the transportation of crude oil in the lowest-strength packing
group. That Emergency Order was issued, in part, out of
concerns over proper classification and packaging of petroleum
crude oil that are under investigation as part of DOT’s
Operation Classification, also known as the “Bakken Blitz.” On
March 6, 2014, DOT issued an amended emergency order replacing
the February 25 Emergency Order.[7] The Amended Emergency Order
is still in effect.
Notwithstanding the above DOT actions, in light
of continued risks associated with petroleum crude oil shipments
by rail, the further actions described in this Order are
necessary to eliminate unsafe conditions and practices that
create an imminent hazard to public health and safety and the
environment.

 <>C.[8] This is a reasonable threshold when considering that
the aforementioned incidents all involved trains consisting of
more than 70 railroad tank cars carrying petroleum crude oil, or
well above the Order’s threshold of 1,000,000 gallons or more of
petroleum crude oil being transported in a single train. In
setting this threshold quantity of 1,000,000 gallons, DOT has
also relied on a Federal Water Pollution Control Act mandate for
regulations requiring a comprehensive spill response plan to be
prepared by an owner or operator of an onshore facility.[9] For
purposes of addressing an imminent hazard, that threshold amount
of petroleum crude oil also ensures DOT is assisting local
emergency responders to be prepared for the type of accidents
that have been occurring regularly, and represent the greatest
risks to public safety and the environment with regard to the
transportation of Bakken crude oil. Further, this threshold
amount of Bakken crude oil ensures that DOT is not unnecessarily
imposing safety-related burdens on lesser risks that have not,
to date, proven to represent the same safety and environmental
concerns.
DOT has determined that SERCs are the most
appropriate point of contact to convey written notifications
regarding the transportation of trains transporting large
quantities of Bakken crude oil. Each state has a designated
SERC in accordance with the requirements of the ECPRA, which was
created to help local entities plan for emergencies involving
hazardous substances.[10] Generally, SERCs are responsible for
supervising and coordinating with the local emergency planning
committees (LEPC) in states, and are best situated to convey
information regarding hazardous materials shipments to LEPC’s
and state and local emergency response agencies. This Order
requires that railroad carriers, to the extent reasonably
practicable, assist SERCs as necessary in responding to any
requests for information from local emergency response agencies
regarding the volume and frequency of train traffic implicated
by this Order within that agency’s jurisdiction.

 Written notification containing the required information to states in which trains affected
by this Order operate must be made within 30 days of the effective date of this Order. If
initial notification is not made to a SERC within 30 days of the date of this Order, a
railroad is prohibited from operating any train transporting 1,000,000 gallons or more of
Bakken crude oil through that state until such notification is provided. This notification
must reflect the expected volume and frequency of train traffic implicated in each county in
a particular state, with updated notifications required to be made when there is a material
change in the volume of those trains. DOT is aware that the nature of freight railroad
operations does not make it possible in many instances to estimate the exact number of
trains implicated by this Order that will travel over a particular route in a specified time
period. Thus, this Order requires that railroads make a reasonable estimate as to the
number of implicated trains expected to travel through a county per week, and to update
the notification whenever a significant increase or decrease in that estimated number
occurs. For purposes of complying with the requirements of this Order, DOT considers
any increase or decrease of twenty-five percent or more in the number of implicated trains
per week to be a material change. In making these notifications to SERCs, railroads must
identify that Bakken crude oil is the commodity involved, and convey the applicable
petroleum crude oil emergency response information that is required by 49 CFR part 172,
subpart G in the notice. The railroad’s notice to the SERCs must identify the routes over
which the material will be transported through each affected county in a state. The above
requirements will enable SERCs, and accordingly, state and local emergency responders, to
have a reasonable expectation of the petroleum crude oil train traffic, and prepare
accordingly for the possibility of an accident involving a train transporting a large quantity
of Bakken crude oil.
In addition, railroads must also identify at least one point of contact (including name, title,
phone number and address) at the railroad responsible for serving as the railroad’s point
of contact for state and local emergency response agencies on issues related to the
transportation of Bakken crude oil through their jurisdictions. This point of contact must
be communicated in the notice to the SERCs so that a jurisdiction may contact the railroad
to obtain information regarding the transportation of large quantities of Bakken crude oil
via rail. Copies of the written notification to SERCs must be made available upon request
to FRA. FRA will audit railroad compliance with this Order by reviewing the notices that
railroads provide to SERCs to ensure the accuracy of those notices, and also to ensure that
state and local emergency responders are able to communicate with the railroad contact
identified in the written notification when necessary.
Nothing in this Order precludes railroad carriers from taking any additional steps to
communicate with state and local emergency responders regarding the transportation of
hazardous commodities within a state or local jurisdiction. If a railroad carrier has existing
methods of communications with first responders along affected routes, DOT encourages
railroads carrier to also continue to utilize those existing methods of communication.
To further enhance emergency response efforts, DOT is also recommending that railroads
continue to commit resources to develop specialized crude oil by rail training and tuition
assistance program for local first responders. Through the Transportation Community

 Awareness and Emergency Response (TRANSCAER®) program[11] and other initiatives,
the railroad and hazardous materials shipping industries collaborate and cooperate with
communities through which hazardous materials are transported. For example, in
accordance with Association of American Railroads (AAR) Circular OT-55-N, railroads
are to assist in implementing TRANSCAER’s outreach program to improve community
awareness, emergency planning and incident response for the transportation of hazardous
materials. The same industry standard provides for the disclosure of certain commodity
flow data upon request to local emergency response agencies and planning groups.
In response to the Secretary’s recent “Call to Action,” the rail and shipping industries have
renewed their commitment to the TRANSCAER® program and have agreed to conduct
additional outreach and training to local emergency responders in jurisdictions through
which crude oil is transported in large quantities.[12] At the same time, industry has
committed to providing additional funding for emergency response resources for local
emergency responders, and to continued communication with communities about the
hazards of crude oil being transported by rail. DOT views these efforts as supporting the
emergency response capability planning requirement.
D. Remedial Action
Within 30 days of this Order, to abate this imminent hazard, each affected railroad
carrier shall, within 30 days of the date of this Order, notify the SERC in each state in
which the railroad carrier operates trains transporting 1,000,000 gallons or more of
Bakken crude oil. The contact information for each SERC is on the U.S. EPA’s website
related to the ECPRA as discussed above. If notification is not made to a SERC within 30
days of the date of this Order, a railroad is prohibited from operating any train
transporting 1,000,000 gallons or more of Bakken crude oil in that State until such
notification is provided. This notification must provide information regarding the
estimated volumes and frequencies of train traffic implicated. Specifically, this notification
must: (a) provide a reasonable estimate of the number of trains implicated by this Order
that are expected to travel, per week, through each county within the state; (b) identify and
describe the petroleum crude oil being transported in accordance with 49 CFR part 172,
subpart C; (c) provide all applicable emergency response information required by 49 CFR
part 172, subpart G; and, (d) identify the route over which the material will be
transported. This notification also must identify at least one point of contact at the railroad
(including name, title, phone number and address) responsible for serving as the point of
contact for SERCs and local emergency responders related to the railroad’s transportation
of Bakken crude oil. To ensure that the information provided to a SERC remains reliable,
railroad carriers shall update notifications prior to making any material changes – defined
as any increase or decrease of twenty-five percent or more – in the estimated number of
trains per week transporting 1,000,000 gallons or more of Bakken crude oil through local
communities. Railroad carriers must assist the SERCs as necessary in disseminating the
information to local emergency responders in affected counties. Copies of railroad
notifications to SERCs must be made available to the FRA upon request.

 E. Rescission of Order
This Order remains in effect until the Secretary determines that an imminent hazard no
longer exits or a change in applicable statute or Federal regulation occurs that supersedes
the requirements of the Order, in which case the Secretary will issue a Rescission Order.
F. Failure to Comply
Any railroad carrier or person failing to comply with this Emergency Order is subject to
civil penalties of up to $175,000 for each violation or for each day it is found to be in
violation (49 U.S.C. 5123). A person willfully or recklessly violating this Emergency
Order is also subject to criminal prosecution, which may result in fines under title 18,
imprisonment of up to ten years, or both (49 U.S.C. 5124).
G. Right to Review
Pursuant to 49 U.S.C. 5121(d)(3) and in accordance with section 554 of the Administrative
Procedure Act (APA), 5 U.S.C. 500 et seq, a review of this action may be filed. Any petition
seeking relief must be filed within 20 calendar days of the date of this order (49 U.S.C. §
5121 (d)(3)), and addressed to: Office of the General Counsel, U.S. Department of
Transportation, 1200 New Jersey Avenue, S.E., Washington, DC 20590. Please include the
docket number of this Emergency Order in your petition, and state the material facts at
issue which you believe disputes the existence of an imminent hazard and must include all
evidence and exhibits to be considered. The petition must also state the relief
sought. Within 30 days from the date the petition for review is filed, the Secretary must
approve or deny the relief in writing; or find that the imminent hazard continues to exist,
and extend the original Emergency Order. In response to a petition for review, the
Secretary may grant the requested relief in whole or in part; or may order other relief as
justice may require (including the immediate assignment of the case to the Office of
Hearings for a formal hearing on the record.
III.

Paperwork Reduction Act
The Paperwork Reduction Act of 1995 (44 U.S.C. 3507(d)) requires that DOT consider the
impact of paperwork and other information collection burdens imposed on the
public. DOT has determined that this Emergency Order imposes new information
collection requirements. FRA will be publishing a Paperwork Reduction Act notice for
comment, following publication of this order.

IV.

Emergency Contact Officials
If you have any questions concerning this Emergency Order, you should contact the U.S.
Department of Transportation at (202) 493-6245.

 Dated: May 7, 2014

_______________________________________
Anthony R. Foxx
Secretary of Transportation

[1] As described by 49 CFR 172.101.
[2] http://www2.epa.gov/epcra/state-emergency-response-commissions-contacts.
[3] See Association of American Railroads’ (AAR) December 2013 paper “Moving Crude
Oil by Rail”, available online at: https://www.aar.org/keyissues/Documents/BackgroundPapers/Crude-oil-by-rail.pdf[external link].
[4] In 2011 there were 65,751 originations of tank car loads of crude oil. In 2012, there were
233,811 originations. Id.
[5] This derailment currently is being investigated by the National Transportation Safety
Board (NTSB), and information regarding this incident can be found at the NTSB
website. Seehttp://www.ntsb.gov/doclib/reports/2014/Casselton_ND_Preliminary.pdf.
[6] This derailment currently is being investigated by the Transportation Safety Board of
Canada and information regarding this incident can be found at the TSB website. See
http://www.bst-tsb.gc.ca/eng/enquetesinvestigations/rail/2013/R13D0054/R13D0054.asp[external link].
[7] The Amended Emergency Order addressed shipments already in transportation at the
time of the emergency order’s
issuance. http://www.dot.gov/sites/dot.gov/files/docs/Amended%20Emergency%20Order
%20030614.pdf.

 [8] This approximation assumes that the tank cars would not be entirely filled to capacity.
[9] See 40 CFR 112.20. The Federal Water Pollution Control Act, as amended by the Oil
Pollution Act of 1990, directs the President, at section 311(j)(1)(C) (33 U.S.C. 1321(j)(1)(C))
and section 311(j)(5) (33 U.S.C. 1321(j)(5)), respectively, to issue regulations “establishing
procedures, methods, and equipment and other requirements for equipment to prevent
discharges of oil and hazardous substances from vessels and from onshore facilities and
offshore facilities, and to contain such discharges.”
[10] http://www2.epa.gov/epcra.
[11] www.transcaer.com[external link]
[12] See February 21, 2014 letter from Secretary Anthony Foxx to President and Chief
Executive Officer of the Association of American Railroads Ed
Hamberger. http://www.dot.gov/briefing-room/letter-association-american-railroads
Updated: Wednesday, May 7, 2014