Over the last week there have been eight new comments posted
to the
docket for the liquified natural gas by rail special permit being
proposed by DOT’s Pipeline and Hazardous Material Safety Administration
(PHMSA). This week’s comments were all provided by private citizens and all
opposed the issuance of the special permit based upon their expressed concerns
about the safety of shipping LNG by rail.
When we see early multiple comments from private citizens on
a rulemaking docket, it is easy to suggest that there is an organized letter
writing campaign involved. Many environmental or chemical safety advocacy
groups have employed these types of campaigns in the past. It does not appear
that this is a typical organized campaign; there is no commonality of language
or phrases and there is no reference to a prepared statement or counter proposal.
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