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Sierra Club Asks Court to Ban Use of Legacy DOT-111 Tank Cars

The Energy Law

Circuit 2004). Likewise, while the NGOs admit that “there is no per se rule as to how long is too long, [they nonetheless claim that] ‘a reasonable time for agency action is typically counted in weeks or months, not years,’ particularly when urgent health or environmental harms are at stake, as the case here.” 3d 413, 419 (D.C.