{"operation":"document","citation":"PHMSA Guidance, 24-0111","title":"24-0111","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2025-01-02","effective_on":"2025-01-02","summary":"24-0111 Document 240111.pdf (442.87 KB) 24-0111 PDF Issued Date: Thursday, January 2, 2025","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-guidance-24-0111-549be66a.json","markdown":"https://regulus.evalyn.ai/document/phmsa-guidance-24-0111-549be66a.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-guidance-24-0111-549be66a","source_url":"https://www.phmsa.dot.gov/regulatory-compliance/phmsa-guidance/24-0111","body":"24-0111\n\nDocument\n\n 240111.pdf (442.87 KB)\n\n        24-0111 PDF\n\n          Issued Date: Thursday, January 2, 2025\n\n<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nJanuary 2, 2025\nMichael J. Rush\nSenior Vice President – Safety & Operations\nAssociation of American Railroads\n425 Third St., SW\nSuite 1000\nWashington, DC 20024\nReference No. 24-0111\nDear Mr. Rush:\nThis letter is in response to your November 14, 2024, letter requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the requirements\nfor real-time electronic train consist information adopted in the HM-263 final rule.\n1\nWe have paraphrased and answered your questions as follows:\nQ1. You ask for clarification regarding the requirement to include information on the point of\norigin and destination of the train—see § 174.26(a)(1). You seek confirmation that the\nrequirement can be met by using the city, milepost, and/or yard name to identify the point\nof origin and destination of the train traveling under a single train symbol.\nA1. Your understanding is correct. As noted in the final rule, the intent of this requirement is\nto ensure emergency responders are provided with relevant information about the point of\norigin and destination of the train which will aid in determination of the direction of\ntravel.2 Providing the city, milepost, and/or yard name of origin and destination (with\nstate, province, and country information) would comply with the requirement to provide\npoint of origin and destination information for the train.\nPlease note that for movement within the same city (such as from one yard to another in\nChicago, IL), providing only the city name for both the point of origin and destination\nwill not satisfy the requirements of § 174.26(a)(1). In this case, alternative directional\ninformation such as milepost-to-milepost or yard-to-yard information would be necessary\nto aid in determining direction of travel. For trains with the same origin and destination\npoint (i.e., a train that departs and returns to the same place), the data points should\n1 89 FR 52956 (June 24, 2024). Available for review at: https://www.govinfo.gov/content/pkg/FR-2024-06-\n24/pdf/2024-13474.pdf\n2 See pages: 89 FR 52958, 52977, and 52983.\n\n<<<PAGE 2>>>\n\ninclude directional information to indicate the direction of travel to aid emergency\nresponders—such as providing an indication that the train is heading toward, or away\nfrom, the origin/destination city, yard, and/or milepost.\nQ2. You describe the existing system of toll-free phone numbers posted throughout the rail\nsystem—e.g., located at grade crossings—that allow for a caller to utilize a prompt phone\ntree (i.e., pressing the #1 in response to a verbal prompt) to reach a railroad emergency\nresponse point of contact. You seek confirmation that such a phone system would comply\nwith the requirements of § 174.28(a) if the system routes the caller to a person that can\nrelay required train consist information in electronic form.\nA2. Your understanding is correct. A phone tree system with verbal prompts described in\nyour letter is an appropriate way to initiate communication with the railroad’s emergency\nresponse point of contact to obtain electronic train consist information. When\ndetermining compliance with the railroad emergency response point of contact\nrequirements and § 174.28(a), the focus will be on whether the Federal, State, or local\nfirst responders, emergency response officials, or law enforcement personnel seeking\nassistance were able to reach the railroad’s point of contact and receive electronic train\nconsist information such that it is immediately available for use when needed. For\ninstances where incidents occur away from a grade crossing where the toll-free phone\nnumber is likely not to be posted, other methods may be necessary to satisfy\nrequirements. As discussed in the final rule,\n3 § 174.28(a) is a performance standard, and\nother methods of compliance, such as the use of a shared electronic database system, may\nbe used to satisfy the regulations.\nHowever, please note that the system described in your letter would not fulfill the\nrequirement to provide proactive telephone notification of an incident to the primary\nPublic Safety Answering Point (PSAP)—e.g., 9-1-1 call center—responsible for the area\nwhere the incident occurred and transmit electronic train consist information to them, as\nrequired in § 174.28(b).\nQ3. You ask for confirmation that the word “authorized”—as in “authorized Federal, State,\nand local first responders, emergency response officials, and law enforcement personnel”\n(§ 174.28(a))—means a person who is tasked by an appropriate government authority\nwith responding to a hazardous materials incident.\nA3. Your understanding is correct. The word “authorized” also applies to a person who is\ntasked by an appropriate government authority to investigate a hazardous materials\nincident within the jurisdiction where the incident occurred. As stated in the HM-263\nfinal rule,4 the word “authorized” in the phrase “authorized Federal, State, and local first\nresponders, emergency response officials, and law enforcement personnel” means those\npersons authorized by an appropriate authority—e.g., a town, city, county, state, tribal, or\nfederal agency—to take part in the response to, or investigation of, an accident or\n3 89 FR 52975-6.\n4 89 FR 52974.\n\n<<<PAGE 3>>>\n\nincident involving the transportation of hazardous materials by rail within the jurisdiction\nwhere the incident occurred.\nQ4. You state that railroads may not be in a position to determine whether a person is\n“authorized” to receive electronic train consist information. You ask whether railroads\nmay meet the regulatory requirement in § 174.28(a) to provide electronic train consist\ninformation to “authorized Federal, State, and local first responders, emergency response\nofficials, and law enforcement personnel” by transmitting electronic train consist\ninformation to the primary PSAP—as required by § 174.28(b)—and relying on the\nprimary PSAP to distribute the electronic train consist information to other authorized\nparties.\nA4. The answer is no. The requirements in § 174.28(a) and (b) are separate and distinct.\nSection 174.28(a) contains three requirements, specifically:\n1. Each railroad operating a train carrying hazardous materials must at all times\nmaintain in electronic form, off the train, accurate train consist information as\nrequired in § 174.26.\n2. Each railroad must make such electronic train consist information immediately\naccessible at all times to its designated emergency response point of contact such that\nthey are able to communicate train consist information to Federal, State, and local\nfirst responders, emergency response officials, and law enforcement personnel\nseeking assistance.\n3. Each railroad must also provide, using electronic communication (e.g., a software\napplication or electronic data interchange, etc.), that electronic train consist\ninformation to authorized Federal, State, and local first responders, emergency\nresponse officials, and law enforcement personnel along the train route that could be\nor are involved in the response to, or investigation of, an accident, incident, or public\nhealth or safety emergency involving the rail transportation of hazardous materials\nsuch that the information is immediately available for use at the time it is needed.\nIn determining compliance with § 174.28(a), a determination will be made as to whether\nauthorized Federal, State, and local first responders, emergency response officials, and\nlaw enforcement personnel received electronic train consist information at the time it was\nneeded to respond to an emergency situation. Sole reliance on a primary PSAP to\ndisseminate electronic train consist information to authorized Federal, State, and local\nfirst responders, emergency response officials, and law enforcement personnel creates a\nrisk that, due to miscommunications, errors, communication infrastructure failures, or\nother unforeseen circumstances, critical train consist information may not be provided to\nthose emergency responders who need it most. Railroads must be capable of providing\nelectronic train consist information to authorized Federal, State, and local first\nresponders, emergency response officials, and law enforcement personnel directly, in\naddition to the primary PSAP.\nQ5. You ask what the requirement to provide electronic train consist information to\nauthorized personnel “that could be or are involved in the response” means. You state\nthat railroads are not able to determine what organizations are involved, or may be\n\n<<<PAGE 4>>>\n\ninvolved, in the response to a rail incident involving hazardous materials, and seek\nconfirmation that a railroad may comply with this requirement by providing train consist\ninformation to the primary PSAP.\nA5. See answer A4. The intention of the phrase “that could be or are involved in the\nresponse” is to ensure that emergency response organizations responding due to mutual\naid agreements, or agencies responding to investigate the incident—sometimes from a\nlarge geographic distance from the site of the emergency—have access to electronic train\nconsist information. As stated above, evaluating compliance with this requirement will\nfocus on whether the train consist information reached authorized Federal, State, and\nlocal first responders, emergency response officials, and law enforcement personnel at\nthe time it was needed to respond to an emergency involving the transportation of\nhazardous materials by rail. For instance, if an emergency response organization that is\nresponding to a major incident due to a mutual aid agreement has not been able to receive\ntrain consist information from the incident commander due to communication issues or\nresource prioritization at the scene, the railroad must provide electronic train consist\ninformation directly to the mutual aid organization.5\nQ6. You ask for confirmation of your understanding that while there are entities that need\nelectronic train consist information immediately (e.g., the incident commander), there are\nother entities that do not need train consist information immediately. You seek\nconfirmation that a railroad may deny requests to immediately provide train consist\ninformation to certain entities it determines do not need the information immediately.\nA6. The answer is that you are correct that it would be appropriate to transmit electronic train\nconsist information via email directly to an incident commander immediately upon\nrequest. PHMSA cautions railroads that making a judgement that a specific authorized\nFederal, State, tribal, or local first responder, emergency response official, or law\nenforcement personnel does not need electronic train consist information immediately\nduring an emergency—despite a direct request for such information—could result in a\nfailure to comply with this requirement. Meanwhile, we acknowledge that repeated\nrequests for information from an organization to whom the railroad has already\nsuccessfully provided electronic train consist information could present an undue burden\non a railroad’s emergency response resources. A railroad may de-prioritize such repeated\nrequests in order to focus response resources and attention on higher priority emergency\nresponse tasks.\nQ7. You state that freight railroads often have contractual arrangements with one another that\naddress responsibilities for handling incidents when a railroad operates a train on another\nrailroad’s track and understand that these arrangements make the notification of the track\nowner unnecessary. You seek confirmation of this understanding.\nA7. The answer is that if the track owner is aware of the incident before, or at the same time\nas the railroad operating the train due to their own monitoring systems, crew reports, or\nother means, then the requirement to inform the track owner has been met. Additionally,\n5 See 89 FR 52973-52974 for further discussion on the intended recipients of train consist information.\n\n<<<PAGE 5>>>\n\nwhile § 174.28(b)(1) assigns primary responsibility for emergency notification and\nelectronic transmission of the train consist information to the railroad operating the train,\nthis responsibility may be assigned to the track owner under a contractual arrangement. In\nsuch a case, the railroad operating the train must ensure that the track owner has access to\nall the electronic train consist information for the train and the ability to fulfill all of the\nrequirements adopted in this rulemaking.\nQ8. You state that trains transporting hazardous materials can experience incidents, such as\ntrain crew medical emergencies, crossing incidents, and trespasser/pedestrian strikes\nwhere the presence of hazardous materials in the train is not relevant to emergency\nresponse. You ask whether any incident requiring response from local emergency\nresponse agencies involving a train transporting hazardous materials triggers the\nrequirement to perform the emergency notification and transmit electronic train consist\ninformation to the primary PSAP.\nA8. The answer is no. There are certain scenarios where the presence of hazardous materials\nin the train consist are not relevant to emergency response to an incident, and therefore\nprovision of electronic train consist information is not required. Examples of these types\nof incidents include (but are not limited to):\n• Medical emergencies involving the train crew.\n• Grade crossing accidents that do not involve a derailment, suspected release, or\nactual release of hazardous material.\n• Pedestrian strikes.\nWhen these types of incidents occur and involve a train transporting hazardous materials,\nwe encourage railroads to communicate the presence of hazardous materials onboard the\ntrain to the emergency responders and/or primary PSAP, and work with the parties\ninvolved to communicate any relevant information about the hazardous materials on the\ntrain if specifically requested. Please note that all derailments involving a train\ntransporting hazardous materials are subject to the requirements of this rulemaking.\n6\nQ9. You ask whether a software application used to provide access to electronic train consist\ninformation—such as AskRail®—must display the shipping paper information in the\norder as described in § 172.202(a).\nA9. The answer is no. The shipping paper information required as part of the electronic train\nconsist information—see § 174.26(a)(2)—does not need to be presented in the order\nspecified in 49 CFR Part 172 Subpart C in order to comply with the requirements of this\nrulemaking. However, we encourage the presentation of this information in an easily\nrecognizable format, such as the order of the basic description specified in § 172.202(a).\nWe would like to take this opportunity to address frequently asked questions (FAQs) we have\nreceived on § 174.28(b) emergency notification requirement. Specifically:\n6 See 89 FR 52972 for further discussion of types of incidents and accidents requiring emergency notification.\n\n<<<PAGE 6>>>\n\nFAQ1. Can a phone call to a primary PSAP’s 10-digit administrative phone number, rather than\nthrough the 9-1-1 emergency phone call system, fulfill the requirement for the emergency\nnotification telephone call?\nA1. The answer is yes. However, in order to comply with the notification requirement in\n§ 174.28(b), the phone call must be answered by the primary PSAP. In the chaotic\naftermath of a major train derailment, calls to a PSAP’s administrative phone number\nmay go unanswered in favor of answering emergency 9-1-1 calls. We encourage railroads\nto take this into consideration and have procedures or systems in place to ensure that the\nprimary PSAP answers the emergency notification phone call.\nFAQ2. Section 174.28(b)(1) requires that a railroad forward electronic train consist information\nto the primary PSAP in a form that they are capable of readily accessing. What does this\nmean?\nA2. The answer is that the railroad must communicate with the primary PSAP during the\nemergency notification phone call, and then transmit the electronic train consist\ninformation to the primary PSAP in the format that the primary PSAP requests. This may\ninvolve an email, a fax, use of a software application, or other means that the primary\nPSAP requests. Compliance with this requirement requires the railroad to work\ncollaboratively with the primary PSAP and successfully provide them with the electronic\ntrain consist information in the requested format. We encourage railroads to continue\nbuilding strong relationships with primary PSAPs along their network to address issues of\ninformation format before an emergency situation.\nI hope this information is helpful. Please contact us if we can be of further\nassistance.\nSincerely,\nYul Brenner Baker Jr.\nActing Chief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 7>>>\n\nPatrick\n24-0111\nMichael J. Rush\nSenior Vice President\nSafety & Operations\nmrush@aar.org\n(202) 639-2503\nNovember 14, 2024\nMr. Shane Kelley\nDirector, Standards and Rulemaking Division\nPipeline and Hazardous Materials Safety Administration (PHH-10)\nU.S. Department of Transportation, East Building\n1200 New Jersey Avenue, SE.\nWashington, DC 20590-0001\nDear Mr. Kelley:\nOn June 24, 2024, PHMSA published a final rule entitled “FAST Act Requirements for Real-Time Train\nConsist Information.” 89 Fed. Reg. 52596. The final rule imposed several new requirements pertaining to\nthe generation and maintenance of electronic consist information and the provision of consist\ninformation to emergency response officials. On July 19, 2024, the Association of American railroads\n(AAR) and its Class I freight railroad members met with PHMSA and the Federal Railroad Administration\n(FRA) to seek clarification of a number of issues that arose from their review of the new regulations and\nthe explanatory text in the preamble to the final rule.1 AAR is submitting this request for interpretation\nbased on PHMSA’s suggestion during the July 19th meeting. The request for interpretation is sought\npursuant to PHMSA’s regulatory authority, as identified in 49 C.F.R. section 105.20.\nTrain Origin and Destination\nSection 174.26(a)(1) requires the train consist to include the “point of origin and destination of the\ntrain.” The regulatory text matches section 7302(a)(1)(A)(ii) of the FAST Act, in which Congress directed\nthe Secretary of the U.S. Department of Transportation to require Class I railroads to generate electronic\nconsist data that includes the point of origin and destination of the train. Pub. L. 114-94 (Dec. 4, 2015).2\nThe legislative history is silent on what is meant by “the point of origin and destination of the train.”\nTherefore, PHMSA must look to the plain meaning of the words that make up the term. FRA defines\n“train” as “one or more locomotives coupled with or without cars, except during switching service.” See\ne.g., 49 C.F.R. § 218.5. Railroads designate trains with train symbols. Neither PHMSA nor FRA regulations\ndefine the terms “point of origin” and “destination.” The Merriam-Webster dictionary defines “point of\n1 AAR is a non-profit trade association whose membership includes freight railroads that operate 83% of the line-\nhaul mileage, employ 95% of the workers, and account for 97% of the freight revenues of all railroads in the United\nStates; and passenger railroads that operate intercity passenger trains and provide commuter rail service.\n2 Section 7308 of the FAST Act was amended in 2021 by § 26003 of the Infrastructure Investment and Jobs Act\n(IIJA) to revise the legislative deadline for completing the statutory mandate, but the amendment did not affect\nthe substantive statutory mandate related to origin and destination. Pub. L. 117-58 (Nov. 15, 2021).\n425 3rd Street SW, Suite 1000 I Washington, DC 20024 I P (202) 639-2100 I www.aar.org\n\n<<<PAGE 8>>>\n\norigin” as “the place where something comes from : the place where something originates.”3\n“Destination” is defined as “a place to which one is journeying or to which something is sent.”4 Applying\nthese definitions to the statutory text drives home the conclusion that Congress intended for railroads\nto identify the starting point and ending point of the train traveling under a single train symbol. There is\nno statutory basis for requiring railroads to provide additional information to meet the point of\norigin/destination requirement.\nThere are multiple ways in which a railroad may identify the point of origin and destination of the\ntrain. In the preamble, PHMSA provides an example where the point of origin and destination are the\nrailyard where the train was assembled and the next railyard with a scheduled stop in the direction of\ntravel. During the July 19th meeting, PHMSA and FRA indicated that it would be acceptable to identify\nthe point of origin and destination in a city-to-city format. While neither the statute nor the regulatory\ntext includes a directional component, this would address the concerns raised by the International\nAssociation of Fire Chiefs about knowing the direction of the train for over-the-road moves because it is\neasy for a first responder to assess the direction of a movement between two cities. AAR agrees with\nthe view expressed during the July 19th meeting that a city-to-city format satisfies the new regulatory\nrequirement (railroads can also include state, province, country information, where necessary). AAR\nalso reads the statutory mandate and the regulatory text to allow railroads to choose alternative point\nof origin/destination formats, such as milepost-to-milepost or yard-to-yard, as well as other alternatives.\nWe request written confirmation of this interpretation.\nMaking consist information available immediately through 1-800 numbers\nSection 174.28(a) requires train consist information to be immediately available for use by\nemergency responders at the time it is needed. Railroads have well-established emergency contact\nnumbers at every public grade crossing under the Emergency Notification System (ENS) regulations for\nthe public to use to contact the railroad to report an incident. These 1-800 numbers rely on prompt\nphone trees to ensure that the caller is quickly and effectively directed to the right person at the\nrailroad. For instance, the prompt could say, “in case of an emergency, press 1.” We understand based\non the July 19th meeting that the use of such a phone tree complies with section 174.28(a), provided\nthat such an approach routes the caller to a person who can relay the required information.\nProviding the consist to authorized federal, state, and local first responders\nSection 174.28(a) requires railroads to provide electronic train consist information to “authorized\nFederal, State, and local first responders, emergency response officials, and law enforcement\npersonnel.” AAR recognizes that this language was pulled from section 7302(a)(1)(B) of the FAST Act, as\namended by section 26003 of the IIJA, and the railroads understand the need to get information to the\n3 https://www.merriam-\nwebster.com/dictionary/point%20of%20origin#:~:text=noun%20phrase,that%20burned%20the%20building%20do\nwn\n4 https://www.merriam-webster.com/dictionary/destination\n425 3rd Street SW, Suite 1000 I Washington, DC 20024 I P (202) 639-2100 I www.aar.org\n\n<<<PAGE 9>>>\n\nproper emergency response authorities immediately. However, railroads are also concerned about train\nconsist information falling into the wrong hands.5\nThe railroads interpret “authorized” in this case as meaning someone who is tasked by an\nappropriate government authority with responding to a hazmat incident, but railroads are not\nnecessarily positioned to know if a person requesting consist information is an authorized first\nresponder. Ideally, the railroads would be able to provide the information to the National Response\nCenter (NRC) when they report an incident. This would be simple, efficient, and effective. Unfortunately,\nthe NRC only accepts telephonic notifications, which limits its efficacy in assisting with emergency\nresponse (and AAR encourages PHMSA and FRA to work with NRC to update its reporting system to\nallow for communications that include electronic train consist data). During the July 19th meeting, the\nfeedback received was that a railroad will have satisfied the regulatory requirement by providing the\nconsist information to the Public Safety Answering Point (PSAP) immediately. The PSAP can then\ndisseminate the consist information while working with Incident Command to share consist information\nas appropriate. We seek written confirmation of this interpretation.\nA related question arises with respect to what PHMSA means in section 174.28(a) when it says that\nrailroads are required to provide electronic train consist information to personnel “that could be or are\ninvolved in the response.” Railroads are not properly positioned to assess who is or could be involved in\nthe incident response. Consistent with the interpretation provided above, we understand that railroads\ncan satisfy the regulatory requirement by providing the consist information to the PSAP immediately.\nThe PSAP can then disseminate the consist information, as it determines to be necessary and\nappropriate, to personnel “that could be or are involved in the response.” The railroads seek written\nconfirmation of this interpretation.\nLastly, section 174.28(a) requires railroads to provide electronic train consist information to\n“authorized [] first responders, emergency response officials, and law enforcement personnel along the\ntrain route that could be or are involved in the response to, or investigation of, an accident, incident, or\npublic health or safety emergency involving the rail transportation of hazardous materials such that the\ninformation is immediately available for use at the time it is needed.” As we understand the\nrequirement, it is appropriate for railroads to provide the train consist information via email or other\nelectronic communication method in a timely manner consistent with the need for the information. For\nexample, if Incident Command requests the consist information to assist in the incident response, we\nunderstand that the consist needs to be provided right away. However, there may be other requestors\nwho ask for the train consist information in response to an incident where it is important to provide the\ninformation, but they may not need the information immediately. The reason for raising this issue is\nbecause if a railroad official is receiving repeated requests for train consist information from different\nentities and he or she is required to provide it immediately in every instance, doing so would distract\nthat official from focusing on the response and negatively impact safety. We seek written confirmation\nof this interpretation.\n5 PHMSA seems to share that concern, as evidenced by section 174.28(d).\n425 3rd Street SW, Suite 1000 I Washington, DC 20024 I P (202) 639-2100 I www.aar.org\n\n<<<PAGE 10>>>\n\nNotification to track owners\nSection 174.28(b)(1) states that the railroad transporting hazardous materials must separately notify\nthe track owner of a hazardous materials incident if it is operating over another railroad’s track. Our\nunderstanding is that this provision was added to address concerns from passenger railroads that have\nfreight railroads operating over track owned by the passenger line. Many freight railroads have existing\ncontracts with other freight railroads that address the handling of incidents, and there is no evidence\nthat these agreements present a safety concern for the operating railroad or the track owner. Where\nthese agreements exist there would not be a safety need to notify the track owner in the event of an\nincident. We understand that PHMSA concurs with that such existing track agreements address the\nconcerns underlying the track owner notification requirement and request written confirmation that it is\nacceptable to follow the existing track agreement in such circumstances.\nTypes of incidents triggering notification requirement\nSection 174.28(b) establishes a notification requirement when a train transporting hazardous\nmaterials is involved in an incident, but it is not clear what types of incidents will trigger the notification\nrequirement. Railroads interface daily with local PSAPs. In some instances, railroads require an\nemergency response where there is a presence of hazardous materials in the consist, but the presence\nof the hazardous materials is irrelevant to the specific need for an emergency response (e.g., employee\nmedical issues, crossing incidents, trespasser/pedestrian strikes). There is not a safety justification—and\nit would be highly burdensome—for the notification requirement to be triggered just because an\nincident involves a train that happens to have hazardous materials on it. We read the notification\nrequirement as being triggered when an emergency response directly involves the potential release of\nhazardous material in the train consist or the emergency response is activated because of the presence\nof a hazardous material in the train consist. We seek written confirmation on this point.\nUse of AskRail\nPHMSA implies that railroads will use the AskRail application to comply with many of the\nrequirements in HM-263. However, there would need to be significant modifications to AskRail to make\nit compliant with the requirements of 49 C.F.R. Part 172, which requires a specific order to the basic\nshipping description. AskRail could be modified to include the additional items required in HM-263—\nsuch as the point of origin/destination pair and 24-hour emergency number—that are currently not\ndisplayed in AskRail, thereby meeting the intent of HM-263, but not the required order of Part 172,\nwithout major cost, programming, and time. We understand based on the July 19th meeting that\nproviding the required information of HM-263 but not in the regulatory order of Part 172 meets the\nintent of the regulation and would be compliant.\n425 3rd Street SW, Suite 1000 I Washington, DC 20024 I P (202) 639-2100 I www.aar.org\n\n<<<PAGE 11>>>\n\nAAR would be happy to discuss the issues raised in this letter, should that be desired. Thank you for\nconsidering our request for clarification.\nSincerely,\n425 3rd Street SW, Suite 1000 I Washington, DC 20024 I P (202) 639-2100 I www.aar.org","truncated":false,"body_characters":30547}