# PUBLIC COMMENT ON PROPOSED REGULATIONS: Hazardous Materials: Modernizing Regulations To Facilitate Transportation of Hazardous Materials Integral to Spacecraft Components and Payloads

**Submitted by the Center for Federal Accountability (CFA)**  
**Document Number:** 2026-01758

## Executive Summary

The Center for Federal Accountability submits this draft comment to support timely public record participation while full model-backed legal analysis is queued. This draft identifies baseline accountability concerns and preserves key issues for agency consideration before the close of comments.

## Table of Authorities (to be finalized)

- Administrative Procedure Act (5 U.S.C. 551 et seq.)
- Agency enabling statute and implementing regulations (rule-specific citations to be finalized)

## Key Concerns

- The agency should clearly identify statutory authority for each material requirement in the proposal.
- The agency should provide transparent cost, burden, and implementation assumptions with reproducible methodology.
- The agency should address foreseeable operational risks and unintended consequences for regulated parties and the public.

## Preliminary Analysis

This preliminary draft is generated from the available Federal Register text excerpt below and is intended to preserve issues for the rulemaking record. A full model-backed CFA legal analysis can be substituted in a subsequent revision.

> Federal Register, Volume 91 Issue 19 (Thursday, January 29, 2026) [Federal Register Volume 91, Number 19 (Thursday, January 29, 2026)] [Proposed Rules] [Pages 3860-3862] From the Federal Register Online via the Government Publishing Office [ www.gpo.gov ] [FR Doc No: 2026-01758] ======================================================================= ----------------------------------------------------------------------- DEPARTMENT OF TRANSPORTATION Pipeline and Hazardous Materials Safety Administration 49 CFR Parts 106, 107, 171, 172, 173, 174, 175, 176, 177, 178, 179, and 180 [Docket No. PHMSA-2024-0065 (HM-267)] RIN 2137-AF69 Hazardous Materials: Modernizing Regulations To Facilitate Transportation of Hazardous Materials Integral to Spacecraft Components and Payloads AGENCY: Pipeline and Hazardous Materials Safety Administration (PHMSA), Department of Transportation (DOT). ACTION: Advance notice of proposed rulemaking (ANPRM). ----------------------------------------------------------------------- SUMMARY: PHMSA is publishing this ANPRM to solicit feedback on streamlining and modernizing the Agency's regulations as they relate to the transportation of hazardous materials integral to spacecraft payloads or components. DATES: Comments must be received by April 29, 2026. However, PHMSA will consider late-filed comments to the extent possible. ADDRESSES: You may submit comments identified by the docket number PHMSA-2024-0065 (HM-267) by any of the following methods: Federal e-Rulemaking Portal: http://www.regulations.gov . Follow the online instructions for submitting comments. Fax: 202-493-2251. Mail: Docket Management System, U.S. Department of Transportation, Dockets Operations, M-30, Ground Floor, Room W12-140, 1200 New Jersey Avenue SE, Washington, DC 20590. Hand Delivery: U.S. Department of Transportation, Docket Operations, M-30, Ground Floor, Room W12-140 in the West Building, 1200 New Jersey Avenue SE, Washington, DC 20590, between 9 a.m. and 5 p.m., Monday through Friday, except Federal holidays. Instructions: All submissions must include the agency name and docket number (PHMSA-2024-0065) or RIN 2137-AF69 for this ANPRM at the beginning of the comment.…

## CFA Recommendations

1. Publish a clear crosswalk from each proposed requirement to its statutory basis.
2. Expand and disclose the quantitative assumptions used in cost-benefit analysis.
3. Provide implementation alternatives and phase-in options to reduce compliance risk.
4. Extend or reopen comment if substantial updates are made after publication.

## CFA Contact

Center for Federal Accountability (CFA)  
8401 Mayland Dr # 7387  
Richmond, VA 23294  
policy@federalaccountability.com | https://www.federalaccountability.com/

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_Generated via cursor provider fallback at 2026-03-23T21:03:32.440143+00:00._