Sierra Club Asks Court to Ban Use of Legacy DOT-111 Tank Cars
The Energy Law
OCTOBER 16, 2014
The NGOs acknowledge that most “unreasonable delay cases” entail lengthier delays involving rulemaking proceedings that take years to complete, but argue that their petition is unique and different because it seeks an “emergency action” to abate an imminent hazard that cannot wait for a rulemaking because “lives are at stake.” Circuit 2004).
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