Interstate vs Intrastate Commerce Ruling

US DOT Senior Trial Attorney has written a letter determining government views on interstate commerce vs. intrastate commerce. The ruling appears to conflict with NTC and TSI training materials which have been a standard for over 20 years. A truck was hauling anhydrous ammonia. It came in by pipe line to Indiana. It was written as intrastate transportation. It was refuted, saying it was interstate in nature. Legal said, yes it is interstate. This is not what were teaching in the classroom.......His request is to request legal to re-address the issue or change the way we teach the course. Legal said because the intent was known by the shipper before it was shipped, which made it interstate. Paul Reamey said we should advise legal that since other product was in the tank, it could just as easily be intrastate.

Urgent - Clarification is needed so procedures and training can be adjusted complying with Mr. Falks letter or opposition can be mounted to defend standing training and procedures which are currently in place.

Review the attached information concerning the various definitions of inter and intrastate commerce. Determine if CVSA feels the need to challenge the response of Senior Trial Attorney for the USDOT or comply by the ruling and revamp training to reflect the ruling.