Railroad Regulatory Agencies: Difference between revisions

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Regulatory authority over rail operations affects what measures, if any, can be imposed to control coal dust emissions during transit. The '''Federal Rail Administration (FRA)''' regulates rail safety under the US Department of Transportation, including track conditions, equipment standards, and operational practices. The '''Surface Transportation Board (STB)''' oversees the economic aspects of freight rail (rates, service obligations, and access) an independent adjudicatory agency.  
Rail is the most heavily relied upon form of transportation in the coal industry in the U.S. This is because trains can transport large amounts of coal over key geographic areas. The [https://www.stb.gov/ Surface Transportation Board] oversees the economic aspects of freight rail such as rates, service obligations, and access. The [https://railroads.dot.gov/ Federal Rail Administration] regulates rail safety under the [https://www.transportation.gov/ U.S. Department of Transportation], including track conditions, equipment standards, and operational practices. The [[U.S. Environmental Protection Agency (EPA)]] regulates the air emissions of new locomotives and engines, with states regulating existing and older locomotives and engines. This applies specifically to engine emissions and does not cover non-engine emissions like [[Particulate Matter and Coal Dust|fugitive dust]] from train cars, including coal-carrying railcars.


''To read about railroad companies in Hampton Roads, see: [[Railroad Companies|Railroads in Hampton Roads]]''
== Surface Transportation Board (STB) ==
 
''To read about coal terminals in Hampton Roads and how they are are regulated, see: [[Coal Terminals in the Port of Virginia]] and [[Terminal Permits]]''
 
== Surface Transportation Board ==


=== Role ===
=== Role ===
The Surface Transportation Board (STB) is an independent federal agency responsible for the economic regulation of freight railroads, including oversight of rail rates, service disputes, mergers, and access to rail infrastructure. It ensures fair competition, resolves shipper complaints, and adjudicates matters related to common carrier obligations. The STB operates as a regulatory authority that issues binding decisions on disputes and policy matters, shaping how railroads fulfill their service obligations, set rates, and provide access under federal law.
The [https://www.stb.gov/ Surface Transportation Board (STB)] is an independent federal agency responsible for the regulation of the economic aspects of freight railroads, including oversight of rail rates, service disputes, mergers, and access to rail infrastructure. The STB is supposed to ensure fair competition between railroad companies, resolve shipper complaints, and adjudicate matters related to common carrier obligations. The STB operates as a regulatory authority that issues binding decisions on disputes and policy matters, shaping how railroads fulfill their service obligations, set rates, and provide access under federal law.


It has jurisdiction over railroad rate, practice, and service issues and rail restructuring transactions, including mergers, line sales, line construction, and line abandonments.  The STB also has jurisdiction over certain passenger rail matters, the intercity bus industry, non-energy pipelines, household goods carriers’ tariffs, and rate regulation of marine freight shipping involving the United States and other U.S. territories and possessions.<ref>[https://web.archive.org/web/20250707020041/https://www.stb.gov/about-stb/ About STB.] ''Surface Transportation Board. 2025.''</ref>
The STB has jurisdiction over railroad rates, practices, service issues, and rail restructuring transactions like mergers, line sales, line construction, and line abandonments. STB oversees railroad company mergers, such as the proposed deal between [[Railroad Companies|Norfolk Southern]] and Union Pacific in 2025.<ref>Stephens, [https://web.archive.org/web/20250729130415/https://www.trains.com/trn/news-reviews/news-wire/stb-creates-merger-resources-pages-on-its-website/ STB Creates Merger Resources Pages on Its Website], July 25, 2025. </ref> The STB also has jurisdiction over certain passenger rail matters, the intercity bus industry, non-energy pipelines, carriers' tariffs on household goods, and rate regulation of marine freight shipping.<ref>[https://web.archive.org/web/20250707020041/https://www.stb.gov/about-stb/ About STB], Surface Transportation Board, 2025.</ref>


=== Relevance ===
=== Relevance ===
The FRA has recognized that coal dust from uncovered railcars can compromise track stability by contaminating the ballast, prompting mitigation requirements in certain corridors. As the agency overseeing the physical and operational safety of rail infrastructure and rolling stock, the FRA is responsible for regulating conditions of coal transport that may contribute to dust emissions along the rail route.
The STB's jurisdiction over the economic operations of freight railroads includes coal shipments to terminals in the Port of Virginia and through the [[Coal Terminals in the Port of Virginia|Dominion Terminal Associates]], [[Coal Terminals in the Port of Virginia|Kinder Morgan Bulk Terminals]], and [[Coal Terminals in the Port of Virginia|Norfolk Southern Pier 6 Terminal]]. [[Railroad Companies|CSX]] and [[Railroad Companies|Norfolk Southern]] must comply with common carrier obligations, even when their operations generate adverse effects in surrounding communities.
 
The STB has authority to hear service-related complaints and to require railroads to disclose data about shipments, access, and conditions of service. These complaints can involve [[Particulate Matter and Coal Dust|coal dust]], for example, in a dispute between the Burlington Northern Sante Fe (BNSF) Railway and coal shippers in the Power River Basin in the western U.S., where [[Particulate Matter and Coal Dust|coal dust]] from coal-filled railcars contributed to two major train derailments in 2005.<ref name=":1" /><ref name=":2" /> These powers place the agency in a position to adjudicate disputes involving coal transport by rail and its impacts, potentially including community concerns about [[Particulate Matter and Coal Dust|dust]] emissions along rail corridors.<ref>[https://web.archive.org/web/20250707025811/https://railroads.dot.gov/rail-network-development/environment/environment Environment], Federal Railroad Administration, U.S. Department of Transportation, October 3, 2022.</ref>


=== Office of Environmental Analysis ===
=== Office of Environmental Analysis ===
The Office of Environmental Analysis (OEA) is responsible for directing the environmental review process in proceedings where it is necessary.  This involves conducting independent analysis of all environmental data and making environmental recommendations to the STB. In addition to NEPA, the STB’s regulations also implement other environmental statutes, such as the National Historic Preservation Act (NHPA).<ref>[https://web.archive.org/web/20250707024221/https://www.stb.gov/resources/environmental/environmental-overview/ Environmental Overview.] ''Surface Transportation Board.'' 2025.</ref> When proposed rail operations or infrastructure changes may have significant environmental impacts, the OEA evaluates them, including air quality and community health concerns.
The [https://www.stb.gov/about-stb/offices/office-of-environmental-analysis/ STB Office of Environmental Analysis (OEA)] is responsible for directing the environmental review process as related to STB's activities. This involves conducting independent analysis as related to the [https://www.epa.gov/nepa/what-national-environmental-policy-act National Environmental Policy Act (NEPA)] and the [https://web.archive.org/web/20250709033525/https://www.nps.gov/subjects/archeology/national-historic-preservation-act.htm National Historic Preservation Act (NHPA)] when proposed rail operations or rail infrastructure changes could have significant environmental impacts. This evaluation includes evaluating air quality and community health concerns.<ref>[https://web.archive.org/web/20250707024221/https://www.stb.gov/resources/environmental/environmental-overview/ Environmental Overview], Surface Transportation Board, 2025.</ref>


The last time the Office conducted an environmental review in the Hampton Roads region under NEPA was in 1998 for the acquisition of Conrail by [[Railroad Companies|Norfolk Southern and CSX]].<ref>needs source</ref> Although the OEA has authority to review environmentally significant rail proposals, it has not yet directly applied NEPA analysis to freight coal operations or their dust emissions in Hampton Roads.
The last time the OEA conducted an environmental review in the Hampton Roads region was in 1998 when [[Railroad Companies|CSX]] and [[Railroad Companies|Norfolk Southern]] agreed to acquire and split the assets of Conrail.<ref>[https://conrail.com/about-conrail/history/ Brief History of Consolidated Rail Corporation], Conrail, 2025.</ref> While the OEA has the authority to review environmentally significant rail proposals, it has not yet directly applied NEPA analysis to freight coal operations or their [[Particulate Matter and Coal Dust|dust]] emissions.


== Federal Railroad Administration ==
== Federal Railroad Administration (FRA) ==


=== Role ===
=== Role ===
The Federal Railroad Administration (FRA) is a U.S. Department of Transportation agency responsible for enforcing rail safety regulations, overseeing railroad infrastructure, and ensuring the secure transport of hazardous materials. It develops and implements policies aimed at improving rail system reliability and safety, monitors compliance with federal standards, and collaborates with state and industry stakeholders to minimize operational risks across the national rail network.<ref>[https://web.archive.org/web/20250707021813/https://railroads.dot.gov/about-fra/communications/newsroom/fra-faqs FRA FAQs.] ''Department of Transportation Federal Railroad Administration.'' March 15, 2025.</ref>  
The Federal Railroad Administration (FRA) is a [https://www.transportation.gov/ U.S. Department of Transportation] agency responsible for enforcing rail safety regulations, overseeing railroad infrastructure, and making sure the transport of hazardous materials is secure. The FRA also develops and implements policies aimed to improve rail system reliability and safety, monitors compliance with federal standards, and collaborates with states and industries to minimize risks across the U.S. rail network.<ref>[https://web.archive.org/web/20250707021813/https://railroads.dot.gov/about-fra/communications/newsroom/fra-faqs FRA FAQs], Department of Transportation Federal Railroad Administration, March 15, 2025.</ref>  


The FRA creates, revises, and enforces regulations, as well as conducts inspections into accidents, safety audits, technical assistance, and data collection and analysis. It is also responsible for outreach to and partnerships with state and local governments and other stakeholders, and research and development into safety technologies. Additionally, the FRA promotes the development of the freight, passenger, and commuter rail network through grant programs.
The FRA creates, revises, and enforces regulations, as well as conducts inspections into accidents, safety audits, technical assistance, and data collection and analysis. For example, the FRA investigated and issued reports<ref>[[:File:RIR2510.pdf|Norfolk Southern Railway Conductor Injury]], National Transportation Safety Board, Railroad Investigation Report: RIR-25-10, July 7, 2025.</ref> and safety bulletins<ref>[[:File:FRA-SB-2024-05 Conductor Switching Injury 9.3.24.pdf|Safety Bulletin]], U.S. Department of Transportation, Federal Railroad Administration, Office of Railroad Safety, 2024-05, September 3, 2024.</ref><ref>[[:File:Safety-Bulletin 2024-06.pdf|Safety Bulletin]], U.S. Department of Transportation, Federal Railroad Administration, Office of Railroad Safety, 2024-05, September 19, 2024.</ref> on two recent serious injuries at the [[Coal Terminals in the Port of Virginia|Norfolk Southern Pier 6 Terminal]] in 2024.<ref name=":0">[https://www.trains.com/pro/regulatory/ntsb-issues-final-report-on-2024-injury-to-norfolk-southern-conductor-in-norfolk-va/ NTSB Issues Final Report on 2024 Injury to Norfolk Southern Conductor in Norfolk, Va.], ''Trains PRO'', By Trains Staff, July 15, 2025.</ref><ref>[https://www.trains.com/pro/freight/class-i/ntsb-final-report-addresses-july-2024-incident-at-ns-lamberts-point-yard/ NTSB Final Report Addresses July 2024 Incident at NS Lambert’s Point Yard], ''Trains PRO'', By Trains Staff, November 4, 2025.</ref> FRA is also responsible for outreach to and partnerships with state and local governments and other stakeholders, and research and development into safety technologies. The FRA promotes the development of the freight, passenger, and commuter rail network through grant programs.


=== Relevance ===
=== Relevance ===
The STB’s jurisdiction over the economic operations of freight railroads encompasses coal shipments to terminals in Hampton Roads. Railroads engaged in this traffic must comply with common carrier obligations, even when their operations generate adverse effects in surrounding communities. The STB has authority to hear service-related complaints and to require railroads to disclose data about shipments, access, and conditions of service. These powers place the agency in a position to adjudicate disputes involving coal transport and its impacts, including community concerns about dust emissions along rail corridors. <ref>[https://web.archive.org/web/20250707025811/https://railroads.dot.gov/rail-network-development/environment/environment Environment.] ''Federal Railroad Administration, US Department of Transportation.'' 3 October 2022.</ref>
The FRA has recognized that [[Particulate Matter and Coal Dust|coal dust]] from uncovered railcars can compromise track stability and weaken and prevent water from draining from the ballast,<ref>de Place, [https://www.sightline.org/2016/05/04/coal-trains-mean-coal-dust-period/ Coal Trains Mean Coal Dust—Period], Sightline Institute, May 4, 2016.</ref> which is the material that composes the trackbed on which the railroad ties are positioned. This can destabilize the tracks<ref>Infrastructure Security & Energy Restoration, Office Of Electricity Delivery & Energy Reliability, U.S. Department Of Energy, Deliveries Of Coal From The Powder River Basin: Events & Trends 2005–2007 14, 2007.</ref> and cause train derailments, for example, in 2005, coal dust accumulation contributed to the derailment of trains on two separate occasions in the coal-mining region of the Powder River Basin.<ref name=":1">Vorhees, Railroads, [https://archive.nytimes.com/www.nytimes.com/gwire/2010/01/25/25greenwire-railroads-utilities-clash-over-dust-from-coal-55265.html?pagewanted=all Utilities Clash Over Dust From Coal Trains], ''The New York Times'', January 25, 2010.</ref> As of June 2012, there had been six major coal train derailments, causing fatalities and spilling coal and polluting the local soil and water.<ref>de Place, [https://www.sightline.org/2012/07/19/coal-goes-off-the-rails/ Coal Goes off the Rails], Sightline Daily, July 19, 2012.</ref>
Following the 2005 derailments in the Powder River Basin, BNSF, FRA, and STB investigated the effects of [[Particulate Matter and Coal Dust|coal dust]] on railroad tracks, concluding that [[Particulate Matter and Coal Dust|coal dust]] poses a serious problem for railroad safety and operations. In the case of BNSF, this created conflict over who should pay for the cleanup, the rail or coal company.<ref name=":2" /><blockquote>'''BNSF Report:''' "Coal dust poses a serious threat to the stability of the track structure and thus to the operational integrity of [the] lines"<ref name=":3">Trimming, [[:File:Fugitive Coal Dust.pdf|Derailing Powder River Basin Coal Exports: Legal Mechanisms to Regulate Fugitive Coal Dust From Rail Transportation]], ''Golden Gate University Environmental Law Journal'', 6, 2, Pacific Region Edition, 7, June 2013. </ref></blockquote><blockquote>'''STB Report:''' "Coal dust is a particularly harmful contaminant of ballast... [and] interferes with track stability to a much greater extent than other contaminants present... Even if the amount of coal dust varies."<ref name=":2">[[:File:40436.pdf|Arkansas Electric Cooperative Corporation—Petition for Declaratory Order]], Surface Transportation Board, Decision, Docket No. Fd 35305, March 2, 2011.</ref></blockquote>At least one legal scholar has argued the FRA could put a law into effect regarding the safety risks of [[Particulate Matter and Coal Dust|fugitive coal dust]] emissions, that [[Particulate Matter and Coal Dust|coal dust]] is known to weaken the ballast and destabilize the tracks, and that this law would be with the agency's statutory authority and regulatory history.<ref name=":3" /> The argument is that the FRA has been given broad authority under the [https://www.whistleblowers.gov/statutes/frsa Federal Rail Safety Act (FRSA)] to make rules for "every area of railroad safety," which includes derailments, track safety standards, and the structural integrity of the ballast. The FRA already has regulations for [[Particulate Matter and Coal Dust|coal dust]], requiring the removal from service and repair of plain bearing journal boxes containing coal dust "that can reasonably be expected to damage the bearing; or have a detrimental effect on the lubrication of the journal and bearing." The FRA also prohibits the operation of train cars with a plain bearing box that has been damaged by coal dust. Therefore, the FRA is aware of the safety hazards associated with coal dust.<ref name=":3" />
 
== Documents ==
 
* [[:File:40436.pdf|Arkansas Electric Cooperative Corporation—Petition for Declaratory Order, Surface Transportation Board, Decision, Docket No. Fd 35305, March 2, 2011]]
* [[:File:Fugitive Coal Dust.pdf|Trimming, Derailing Powder River Basin Coal Exports: Legal Mechanisms to Regulate Fugitive Coal Dust From Rail Transportation, ''Golden Gate University Environmental Law Journal'', 6, 2, Pacific Region Edition, 7, June 2013]]
* [[:File:FRA-SB-2024-05 Conductor Switching Injury 9.3.24.pdf|Safety Bulletin, U.S. Department of Transportation, Federal Railroad Administration, Office of Railroad Safety, 2024-05, September 3, 2024]]
* [[:File:Safety-Bulletin 2024-06.pdf|Safety Bulletin, U.S. Department of Transportation, Federal Railroad Administration, Office of Railroad Safety, 2024-06, September 19, 2024]]
* [[:File:RIR2510.pdf|Norfolk Southern Railway Conductor Injury, National Transportation Safety Board, Railroad Investigation Report: RIR-25-10, July 7, 2025]]


== References ==
== References ==

Latest revision as of 20:08, 2 February 2026

Rail is the most heavily relied upon form of transportation in the coal industry in the U.S. This is because trains can transport large amounts of coal over key geographic areas. The Surface Transportation Board oversees the economic aspects of freight rail such as rates, service obligations, and access. The Federal Rail Administration regulates rail safety under the U.S. Department of Transportation, including track conditions, equipment standards, and operational practices. The U.S. Environmental Protection Agency (EPA) regulates the air emissions of new locomotives and engines, with states regulating existing and older locomotives and engines. This applies specifically to engine emissions and does not cover non-engine emissions like fugitive dust from train cars, including coal-carrying railcars.

Surface Transportation Board (STB)

Role

The Surface Transportation Board (STB) is an independent federal agency responsible for the regulation of the economic aspects of freight railroads, including oversight of rail rates, service disputes, mergers, and access to rail infrastructure. The STB is supposed to ensure fair competition between railroad companies, resolve shipper complaints, and adjudicate matters related to common carrier obligations. The STB operates as a regulatory authority that issues binding decisions on disputes and policy matters, shaping how railroads fulfill their service obligations, set rates, and provide access under federal law.

The STB has jurisdiction over railroad rates, practices, service issues, and rail restructuring transactions like mergers, line sales, line construction, and line abandonments. STB oversees railroad company mergers, such as the proposed deal between Norfolk Southern and Union Pacific in 2025.[1] The STB also has jurisdiction over certain passenger rail matters, the intercity bus industry, non-energy pipelines, carriers' tariffs on household goods, and rate regulation of marine freight shipping.[2]

Relevance

The STB's jurisdiction over the economic operations of freight railroads includes coal shipments to terminals in the Port of Virginia and through the Dominion Terminal Associates, Kinder Morgan Bulk Terminals, and Norfolk Southern Pier 6 Terminal. CSX and Norfolk Southern must comply with common carrier obligations, even when their operations generate adverse effects in surrounding communities.

The STB has authority to hear service-related complaints and to require railroads to disclose data about shipments, access, and conditions of service. These complaints can involve coal dust, for example, in a dispute between the Burlington Northern Sante Fe (BNSF) Railway and coal shippers in the Power River Basin in the western U.S., where coal dust from coal-filled railcars contributed to two major train derailments in 2005.[3][4] These powers place the agency in a position to adjudicate disputes involving coal transport by rail and its impacts, potentially including community concerns about dust emissions along rail corridors.[5]

Office of Environmental Analysis

The STB Office of Environmental Analysis (OEA) is responsible for directing the environmental review process as related to STB's activities. This involves conducting independent analysis as related to the National Environmental Policy Act (NEPA) and the National Historic Preservation Act (NHPA) when proposed rail operations or rail infrastructure changes could have significant environmental impacts. This evaluation includes evaluating air quality and community health concerns.[6]

The last time the OEA conducted an environmental review in the Hampton Roads region was in 1998 when CSX and Norfolk Southern agreed to acquire and split the assets of Conrail.[7] While the OEA has the authority to review environmentally significant rail proposals, it has not yet directly applied NEPA analysis to freight coal operations or their dust emissions.

Federal Railroad Administration (FRA)

Role

The Federal Railroad Administration (FRA) is a U.S. Department of Transportation agency responsible for enforcing rail safety regulations, overseeing railroad infrastructure, and making sure the transport of hazardous materials is secure. The FRA also develops and implements policies aimed to improve rail system reliability and safety, monitors compliance with federal standards, and collaborates with states and industries to minimize risks across the U.S. rail network.[8]

The FRA creates, revises, and enforces regulations, as well as conducts inspections into accidents, safety audits, technical assistance, and data collection and analysis. For example, the FRA investigated and issued reports[9] and safety bulletins[10][11] on two recent serious injuries at the Norfolk Southern Pier 6 Terminal in 2024.[12][13] FRA is also responsible for outreach to and partnerships with state and local governments and other stakeholders, and research and development into safety technologies. The FRA promotes the development of the freight, passenger, and commuter rail network through grant programs.

Relevance

The FRA has recognized that coal dust from uncovered railcars can compromise track stability and weaken and prevent water from draining from the ballast,[14] which is the material that composes the trackbed on which the railroad ties are positioned. This can destabilize the tracks[15] and cause train derailments, for example, in 2005, coal dust accumulation contributed to the derailment of trains on two separate occasions in the coal-mining region of the Powder River Basin.[3] As of June 2012, there had been six major coal train derailments, causing fatalities and spilling coal and polluting the local soil and water.[16]

Following the 2005 derailments in the Powder River Basin, BNSF, FRA, and STB investigated the effects of coal dust on railroad tracks, concluding that coal dust poses a serious problem for railroad safety and operations. In the case of BNSF, this created conflict over who should pay for the cleanup, the rail or coal company.[4]

BNSF Report: "Coal dust poses a serious threat to the stability of the track structure and thus to the operational integrity of [the] lines"[17]

STB Report: "Coal dust is a particularly harmful contaminant of ballast... [and] interferes with track stability to a much greater extent than other contaminants present... Even if the amount of coal dust varies."[4]

At least one legal scholar has argued the FRA could put a law into effect regarding the safety risks of fugitive coal dust emissions, that coal dust is known to weaken the ballast and destabilize the tracks, and that this law would be with the agency's statutory authority and regulatory history.[17] The argument is that the FRA has been given broad authority under the Federal Rail Safety Act (FRSA) to make rules for "every area of railroad safety," which includes derailments, track safety standards, and the structural integrity of the ballast. The FRA already has regulations for coal dust, requiring the removal from service and repair of plain bearing journal boxes containing coal dust "that can reasonably be expected to damage the bearing; or have a detrimental effect on the lubrication of the journal and bearing." The FRA also prohibits the operation of train cars with a plain bearing box that has been damaged by coal dust. Therefore, the FRA is aware of the safety hazards associated with coal dust.[17]

Documents

References

  1. ↑ Stephens, STB Creates Merger Resources Pages on Its Website, July 25, 2025.
  2. ↑ About STB, Surface Transportation Board, 2025.
  3. ↑ 3.0 3.1 Vorhees, Railroads, Utilities Clash Over Dust From Coal Trains, The New York Times, January 25, 2010.
  4. ↑ 4.0 4.1 4.2 Arkansas Electric Cooperative Corporation—Petition for Declaratory Order, Surface Transportation Board, Decision, Docket No. Fd 35305, March 2, 2011.
  5. ↑ Environment, Federal Railroad Administration, U.S. Department of Transportation, October 3, 2022.
  6. ↑ Environmental Overview, Surface Transportation Board, 2025.
  7. ↑ Brief History of Consolidated Rail Corporation, Conrail, 2025.
  8. ↑ FRA FAQs, Department of Transportation Federal Railroad Administration, March 15, 2025.
  9. ↑ Norfolk Southern Railway Conductor Injury, National Transportation Safety Board, Railroad Investigation Report: RIR-25-10, July 7, 2025.
  10. ↑ Safety Bulletin, U.S. Department of Transportation, Federal Railroad Administration, Office of Railroad Safety, 2024-05, September 3, 2024.
  11. ↑ Safety Bulletin, U.S. Department of Transportation, Federal Railroad Administration, Office of Railroad Safety, 2024-05, September 19, 2024.
  12. ↑ NTSB Issues Final Report on 2024 Injury to Norfolk Southern Conductor in Norfolk, Va., Trains PRO, By Trains Staff, July 15, 2025.
  13. ↑ NTSB Final Report Addresses July 2024 Incident at NS Lambert’s Point Yard, Trains PRO, By Trains Staff, November 4, 2025.
  14. ↑ de Place, Coal Trains Mean Coal Dust—Period, Sightline Institute, May 4, 2016.
  15. ↑ Infrastructure Security & Energy Restoration, Office Of Electricity Delivery & Energy Reliability, U.S. Department Of Energy, Deliveries Of Coal From The Powder River Basin: Events & Trends 2005–2007 14, 2007.
  16. ↑ de Place, Coal Goes off the Rails, Sightline Daily, July 19, 2012.
  17. ↑ 17.0 17.1 17.2 Trimming, Derailing Powder River Basin Coal Exports: Legal Mechanisms to Regulate Fugitive Coal Dust From Rail Transportation, Golden Gate University Environmental Law Journal, 6, 2, Pacific Region Edition, 7, June 2013.
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