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The Writ of Mandamus Although the proposed rule addresses many of the DOT-111 safety concerns by requiring retrofits and operational changes, the NGOs claim that the proposed four-year phase-out of legacy tank cars is a “glacial pace [that] is unacceptable.” Circuit 2004). Citing In re American Rivers , 372 F.3d 3d 413, 419 (D.C.
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