February 28, 2022

Tristan Brown
Acting Administrator
Pipeline and Hazardous Materials Safety Administration
1200 New Jersey Ave., S.E.
Washington, D.C. 20590

Via regulations.gov:

RE: Docket No. PHMSA–2021–0058 (HM–264A) – Hazardous Materials:

Suspension of HMR Amendments Authorizing Transportation of Liquefied
Natural Gas by Rail
Dear Acting Administrator Brown:

The undersigned Attorneys General, as the chief legal officers of our States,
write to express our concerns with the Biden Administration’s proposed rule,
published Nov. 8, 2021, (the “Proposed Rule”) to suspend authorization to transport
liquefied natural gas (“LNG”) by rail tank cars pursuant to a final rule, which had
become final August 24, 2020, (the “2020 Rule”).1 The Pipeline and Hazardous
Materials Safety Administration’s (“PHMSA”) decision to reverse course on this
amendment to the Hazardous Materials Regulations (“HMR”) creates regulatory
uncertainty, chilling potential capital investment in the DOT–113C120W9
specification tank car, a tank car specifically designed to transport LNG.2 Moreover,
the general concern that transporting LNG by rail might result in an increase in
production of natural gas which might result in an increase in greenhouse gases
(“GHG”) is an attenuated and speculative concern untethered to the scope of
PHMSA’s regulatory purpose. Finally, PHMSA’s reasoning does not adequately

1 Hazardous Materials: Suspension of HMR Amendments Authorizing Transportation of Liquefied

Natural Gas by Rail, 86 Fed. Reg. 61,731 (Nov. 8, 2021).
2 See Marybeth Luczak, LNG by Rail: Temporary Reg Rollback Under Review, RAILWAY AGE (Jan. 10,

2022), https://www.railwayage.com/regulatory/lng-by-rail-temporary-reg-rollback-under-review/.
Page 2

explain or justify the suspension of a rule that was subject to extensive notice and
comment and thorough review of alternatives by the agency. Current geopolitical
events involving Russia’s unprovoked attack on Ukraine show with painful clarity
the need for the United States to maintain its energy independence through multiple
distribution points throughout our country. The agency should not move forward with
suspension of a rule that serves that important objective.
Natural gas is the primary energy source for electricity generation in the
United States.3 Presently, 41% of the country’s electricity is generated from natural
gas.4 Meanwhile, U.S. Greenhouse Gas (“GHG”) emissions have decreased by 11.65
percent and GHG emissions from electricity generation have decreased by 33.08
percent within same timeframe.5 The growth in U.S. gas production is a geopolitical
and economic asset, contributing to our national and global energy security.6 And as
of 2020, it appeared that PHMSA agreed, stating, ‘[t]he United States leverages
domestic technology improvements to transform American life through increased
natural gas production and energy independence.”7
For certain areas of the country, however, access to supply is limited.8 To
address the problem of getting supply to demand, American private industry stepped
in with a solution. The Association of American Railroads (“AAR”) petitioned PHMSA
for rulemaking to expand nationwide access to natural gas using rail. AAR’s position
is that “[f]or more than 80 years, freight railroads have safely transported cryogenic
liquids similar to LNG.”9 PHMSA acknowledged that there was significant interest
in transporting LNG by rail. Specifically, in the 2020 Rule, PHMSA states “[t]he
recent expansion in U.S. natural gas production has increased interest in a
programmatic approach to using appropriately the nation’s rail infrastructure to
facilitate efficient transportation of LNG.”10

3 U.S. Energy Information Administration, Electricity Data Browser: Net Generation, United States,
All Sectors, Monthly (last visited, Feb. 18, 2022), Electricity data browser - Net generation for all
sectors (eia.gov).
4 Id., (Natural Gas: 172,743 thousand megawatthours [Aug. 2021] ÷ All Fuels: 413,949 thousand

megawatthours [Aug. 2021] * 100 = 41%).

5 United States Environmental Protection Agency, Greenhouse Gas Inventory Data Explorer (last

visited, Feb. 17, 2021), https://cfpub.epa.gov/ghgdata/inventoryexplorer/#, (Emissions: 7,423 MMT

CO2 eq. [2005] to 6,558 MMT CO2 eq. [2019] equals 11.65% decrease in total GHG emissions; and
Emissions, Electricity Generation: 2400 MMT CO2 eq. [2005] to 1606 MMT CO2 eq. [2019] equals
33.08% decrease in total GHG emissions.
6 See Daniel Yergin, America Takes Pole Position on Oil and Gas, WSJ (Feb. 14, 2022),

https://www.wsj.com/articles/america-oil-and-gas-russia-lng-exports-natural-gas-producer-rising-
price-ukraine-uae-saudi-arabia-europe-energy-crisis-11644872477.
7 Hazardous Materials: Liquefied Natural Gas by Rail, 85 Fed. Reg. 44,994, 44,995 (July 24, 2020).
8 Hazardous Materials: Liquefied Natural Gas by Rail, 85 Fed. Reg. 44,994, 44,995 (July 24, 2020).
9 Press Release, Association of American Railroads, AAR Backs Legislation to Preserve LNG by Rail

Rule (Mar. 25, 2021), https://www.aar.org/news/aar-backs-legislation-to-preserve-lng-by-rail-rule/.

10 Hazardous Materials: Liquefied Natural Gas by Rail, 85 Fed. Reg. 44,994, 44,995 (July 24, 2020).
Page 3

The Proposed Rule is a response to Executive Order 13990, which directs

agencies to review Trump Administration era rules to identify “candidates for
suspension, modification, or rescission because of inconsistency with [Biden]
Administration policies to . . . prioritize environmental justice [] and reduce GHG.”11
The Proposed Rule states: “Suspension would allow consideration of additional public
comment, particularly on issue such as public and worker safety, environmental
risks, and environmental justice.”12 Additionally, the Proposed Rule’s proposed
temporary suspension “guarantees no [] transportation [of LNG in rail tank cars] will
occur before its companion rulemaking has concluded or no later than June 30,
2024.13
Indeed, suspending the 2020 rule does guarantee no transportation of LNG by
rail can occur, which appears to be the overall objective of the suspension and final
action. But a change in administrations is not an adequate basis upon which to
suspend or repeal a rule that was subjected to thorough notice and comment
procedures. PHMSA is required to provide a “detailed justification” of new facts that
contradict facts underling its prior policy.14 Here, PHMSA must give a more
“reasoned explanation” to justify suspension of a regulation.15 Furthermore, PHMSA
must “display awareness that it is changing position,” “must show that there are good
reasons for the new policy,” and “that the new policy is permissible under the
statute.”16 This requirement applies regardless of whether PHMSA’s stance has
changed because of “the inauguration of a new President and the confirmation of a
new [agency] Administrator.17 Moreover, “Without showing that the old policy is
unreasonable, for [an agency] to say that no policy is better than the old policy solely
because a new policy might be put into place in the indefinite future is as silly as it
sounds.”18 Nevertheless, when suspending or repealing a regulation based on a new
policy the agency must “provide a more detailed justification . . . when, for example,
its new policy rests upon factual findings that contradict those which underlay its
prior policy; or when its prior policy has engendered serious reliance interests that
must be taken into account.”19 PHMSA has not provided any such detailed

11 Hazardous Materials: Suspension of HMR Amendments Authorizing Transportation of Liquefied

Natural Gas by Rail, 86 Fed. Reg. 61,731, 61,734 (Nov. 8, 2021).
12 Hazardous Materials: Suspension of HMR Amendments Authorizing Transportation of Liquefied

Natural Gas by Rail, 86 Fed. Reg. 61,731, 61,736 (Nov. 8, 2021).

13 Hazardous Materials: Suspension of HMR Amendments Authorizing Transportation of Liquefied

Natural Gas by Rail, 86 Fed. Reg. 61,731, 61,732 (Nov. 8, 2021).

14 See 556 U.S. at 515.
15 F.C.C. v. Fox Television Stations, Inc., 556 U.S. 502, 515 (2009).
16 Id. at 514–15.
17 Nat'l Ass'n of Home Builders v. E.P.A., 682 F.3d 1032, 1043 (D.C. Cir. 2012).

18 Pub. Citizen v. Steed, 733 F.2d 93, 102 (D.C. Cir. 1984).
19 556 U.S. at 515.
Page 4

explanations. Providing more time for notice and comment is not an adequate basis
to suspend a final rule..
I. PHMSA’S CLAIM THAT ECONOMIC UNCERTAINTY IN THE LNG INDUSTRY
WARRANTS SUSPENSION IS FLAWED.
PHMSA states that:
Uncertainties in the underlying economic dynamics
driving the potential benefits and public safety and
environmental risks considered in the LNG by Rail final
rule have increased (e.g., the quantity of LNG that will be
moved by rail, the routes involved, and whether new
transportation capacity would induce more natural gas
extraction). PHMSA believes these increased uncertainties
cast doubt on the continued validity of the balance between
potential benefits and public safety and environmental
risks underpinning the LNG by Rail final rule.20
PHMSA vaguely identifies unsubstantiated and generalized concerns about
safety and environmental risks as the reason for economic uncertainty, but this was
the subject of prior notice and comment. Its rationale further indicates the driving
factor is the change in policy views regarding use of fossil fuels and a hypothetical
fear of “induc[ing] more natural gas extraction.”21 Setting aside the question whether
it is within the proper scope of PHMSA’s authority to regulate national demand for
natural gas, the proposed rule itself is the cause of the regulatory uncertainty of
which it complains. By unilaterally suspending a rule that has undergone
considerable evaluation and keeping industry operators in a special permitting
regime, it discourages companies from making any capital investment in LNG by rail,
specifically, the DOT–113C120W9 specification tank cars that the 2020 Rule
authorized. Moreover, concerns about the safety of the tank car appear overblown.
The DOT-113C120W tank car was authorized by special permit prior to the 2020
Rule, which suggests that PHMSA’s newly-discovered concern about the same tank
car’s safety is pretextual.22
PHMSA’s true concern, fear of causing “more natural gas extraction,”
undercuts its narrative about concern for “public safety and environmental risks due
to transport of LNG by rail”23 Both are overstated and illustrate an irrational reversal
in PHSMA’s position in just over one-year’s time.

20 Hazardous Materials: Suspension of HMR Amendments Authorizing Transportation of Liquefied

Natural Gas by Rail, 86 Fed. Reg. 61,731, 61,735–36 (Nov. 8, 2021).
21 Id. at 61,736.
22 Hazardous Materials: Liquefied Natural Gas by Rail, 85 Fed. Reg. 44,994, 45,000 (July 24, 2020).
23 86 Fed. Reg. at 61,736.
Page 5

II. PHMSA’S CLAIM THAT TRANSPORTATION OF LNG BY RAIL TANK CARS

POSES “UNREASONABLE RISKS” TO PUBLIC SAFETY IS INCONSISTENT WITH
ITS PRIOR POSITION.
When it comes to risks, multiple sources conclude that it is safe to transport
LNG by rail. According to the AAR, “99.999% of all hazmat railcars reach their
destinations without an incident that releases product; in 2016, the number of train
accidents with a hazmat product release was 0.69 for every 100,000 hazmat
carloads.”24 The Railway Supply Institute (“RSI”) “agrees with and supports
PHMSA’s prior analysis that transport by rail improves safety and fuel efficiency,
and decreases emissions associated with transporting LNG when compared to
transportation by truck.”25 According to Fortis BC, a leading LNG producer, “LNG is
not flammable or explosive in its liquid form which means converting natural gas to
LNG is one of the safest ways to transport energy.”26 Furthermore, RSI notes that
“DOT-113 tank cars are specifically designed for the safe transportation of cryogenic
material like LNG and have a strong safety record in their more than (5) decades of
service.”27 And the most robust of the cryogenic tank cars and capable of transporting
various cryogenic liquids” is the DOT-113C120W9, which the 2020 Rule greenlit.28
Thus, it does not follow that a little over a year after a considered evaluation
of this very issue, PHMSA’s prior conclusions are now wrong and transporting LNG
poses “unreasonable risks.”29 Moreover, in the Proposed Rule, PHMSA credits as
justification for the suspension that “additional further data and knowledge (for
example regarding potential benefits as well as safety and environmental risk) could
make appropriate further mitigations for shipping LNG by rail tank car.”30 This,
however, is the same thing PHMSA stated in 2020 Rule. Furthermore, an agency
could always make changes to regulations should new information justify the change,
but the possibility that new data might surface always exists and does not justify
suspending a final rule. Even the Transportation Research Board (“TRB”) has stated,
“[e]nsuring the safety of LNG by rail, like all hazardous materials shipments, is an
ongoing process that will require continued monitoring and adjustment of practice

24 Paul W. Parfomak & John Frittelli, Rail Transportation of Liquified Natural Gas: Safety and
Regulation, Congressional Research Service R46414, at 11 (July 28, 2020).
25 Railway Supply Institute, Comment Letter on Notice of Proposed Rulemaking “Hazardous

Materials: Suspension of HMR Amendments Authorizing Transportation of Liquefied Natural Gas

by Rail” (Dec. 23, 2021), (quoting 84 Fed Reg. 56,964, 56,971 (Oct. 24, 2019).
26 The Facts About LNG Safety, FORTIS BC (last visited, Feb. 20, 2022), https://talkingenergy.ca/facts-

about-lng-safety.
27 Railway Supply Institute, Comment Letter on Notice of Proposed Rulemaking “Hazardous

Materials: Suspension of HMR Amendments Authorizing Transportation of Liquefied Natural Gas

by Rail” (Dec. 23, 2021).
28 Id.
29 Hazardous Materials: Suspension of HMR Amendments Authorizing Transportation of Liquefied

Natural Gas by Rail, 86 Fed. Reg. 61,731, 61,734 (Nov. 8, 2021).

30 Hazardous Materials: Suspension of HMR Amendments Authorizing Transportation of Liquefied

Natural Gas by Rail, 86 Fed. Reg. 61,731, 61,734 (Nov. 8, 2021), (citing 85 Fed. Reg. 44,995).
Page 6

and regulations.”31 Thus PHMSA would continue to have that responsibility and the
capacity to act should new facts actually justify a change. Ultimately, when
reconciling PHMSA’s complete reversal on transportation of LNG by rail, the facts
about safety are the same.
III. PREVENTING LNG BY RAIL HARMS THE U.S. ECONOMY AND IS
ENVIRONMENTALLY COUNTER-PRODUCTIVE.

On the 2020 presidential campaign trail, then-candidate Biden promised, “We

are going to get rid of fossil fuels.”32 President Biden took action with Executive Order
14008, which provides that “the Secretary of the Interior shall pause new oil and
natural gas leases on public lands or in offshore waters.”33 These leases, however,
arise from programs authorized by Congress under the Outer Continental Shelf
Lands Act (“OCSLA”), Gulf of Mexico Energy Security Act (“GOMESA”), and the
Mineral Leasing Act (“MLA”).34 The same day the Executive Order was signed, the
Department of Interior, Bureau of Land Management published a document stating
“HITTING PAUSE ON NEW OIL AND GAS LEASING.”35 As a result of the pause,
Leases 257 and 258 were rescinded to comply with Executive Order
14008.36 Importantly, these actions were taken without any notice or consultation
with States, even though freezing new leasing and drilling permits on federal lands
and in the Gulf of Mexico deprives Louisiana and other states of revenues from initial
lease payments, royalties, and rentals.37
In fact, the cancellation of Lease 257 caused an immediate loss of millions of
dollars earmarked for coastal recovery and restoration used to protect against
tropical storms and hurricanes.38 Therefore, President Biden’s actions to tackle
climate change ironically make Louisiana and its coast more susceptible to the
dangers of extreme weather events. The loss of revenue also deprives the federal
government of funds used for environmental projects and deprives States like Alaska,
Wyoming, New Mexico, Utah, and Colorado of revenue these states depend on for a
wide scope of programs.

In addition, the proposed rule ignores findings that transporting LNG by rail
can have positive effects on the environment. According to National Gas Intelligence,
the 2020 Rule “would allow the bulk transport of liquefied natural gas (LNG) in

31 National Academies of Sciences, Engineering, and Medicine 2021, Preparing for LNG by Rail Tank
Car: A Review of a U.S. DOT Safety Research, Testing, and Analysis Initiative. WASHINGTON, DC:
THE NATIONAL ACADEMIES PRESS 8 (2021), https://doi.org/10.17226/26221.
32 John Kartch, Joe Biden: “We Are Going To Get Rid of Fossil Fuels”, Americans for Tax Reform

(Feb. 8, 2020), https://www.atr.org/joe-biden-we-are-going-get-rid-fossil-fuels.

33 Exec. Order No. 14008, 86 Fed. Reg. 7619 (Jan. 27, 2021).
34 Louisiana v. Biden, No. 2:21-CV-00778, 2021 WL 2446010, at *2 (W.D. La. June 15, 2021), appeal

filed, No. 21-30505 (5th Cir. Aug. 17, 2021).

35 Biden, 2021 WL 2446010, at *16.
36 Id. at *15.
37 Id. at * 6–7; AIDEA v. Biden, 3:21-cv-00245-SLG.
38 Id.
Page 7

specialized rail tank cars in what could prove a boon for small-scale projects across
the United States.”39 The same source also indicates that “[m]oving the fuel by rail
could also help projects in certain parts of the country like those in the Permian
Basin, where producers have flared off natural gas at record rates in recent years.”40
Thus, not suspending the 2020 Rule would allow for efficient distribution of natural
gas through multiple means and can offset otherwise flared natural gas that leads to
increased GHGs and wasting the resource entirely.

IV. PHMSA’S PROPOSED RULE CONTRIBUTES TO INCREASED COSTS AT THE

PUMP AND SHIFTS DEMAND FROM DOMESTIC TO FOREIGN SOURCES TO MEET
SUPPLY.

The PHMSA, while exhibiting concern about climate change, does not address
the continuing need to supply the energy needs of this country, especially during
winter months when demand is high. Rather, as a means of regulating production or
consumption, the proposed rule appears to adopt a less efficient approach that
discourages investment in newer tank cars (special permitting) in place of a
considered transportation rule.
Notably, since President Biden took office LNG spot prices have increased
61%.41 According to the Energy Information Administration (EIA), in January 2022,
colder weather led to increased demand for natural gas used for space heating and
power generation, thus causing upward pressure on prices.42 Ultimately, “the average
American household paid about $1,000 in higher energy costs in 2021 compared to
2020,” and “households that use natural gas spent an extra $300.”43
Suspending the 2020 Rule only constricts the means by which demand can be
satisfied – which may be the actual point of this proposed rule – but it does not change
the need for fuel to heat American homes in winter. Rather, it burdens hard-working
Americans with higher costs to do so, even putting people in danger when they cannot
afford to pay their increasingly expensive bill. That problem appears to be getting
worse not better due to Russia’s unprecedented incursion into Ukraine. Indeed
Russia’s invasion of Ukraine is expected to have far-reaching implications for energy

39 Jamison Cocklin, U.S. Issues Final Rule Authorizing Widespread Transport of LNG by Rail, NGI
(June 19, 2020), https://www.naturalgasintel.com/u-s-issues-final-rule-authorizing-widespread-
transport-of-lng-by-rail/.
40 Id.
41 41 U.S. Energy Information Administration, Natural Gas, Data, Henry Hub Natural Gas Spot Price

(last visited, Feb. 18, 2022), https://www.eia.gov/dnav/ng/hist/rngwhhdm.htm, ($2.71 per Million Btu
[Jan. 21, 2021] to $4.38 per Million Btu [Feb. 3, 2022] equals increase of 61.62 %.).
42 U.S. ENERGY INFORMATION ADMINISTRATION, SHORT-TERM ENERGY OUTLOOK 2–3 (Feb. 2022),

https://www.eia.gov/outlooks/steo/pdf/steo_full.pdf.
43 Linnea Lueken & James Taylor, Biden Energy Policies Cost U.S. Households More than $1,000 in

2021, THE HEARTLAND INSTITUTE (Feb. 8, 2022), https://www.heartland.org/publications-

resources/publications/biden-energy-policies-cost-us-households-more-than-1000-in-2021.
Page 8

markets given Moscow’s role as the world’s second-largest producer of natural gas
and one of the world’s largest oil-producing nations.44

V. PHMSA’S PROPOSED RULE HAS NATIONAL SECURITY IMPLICATIONS.

Though the United States is the leading natural gas producer globally, Russia
is second with 18 percent global share.45 Nonetheless, Russia is looking to expand its
influence though construction of the NORD STREAM 2 pipeline. This pipeline is
intended to meet Europe’s growing need for natural gas and complement existing
pipelines through Belarus and Ukraine.46 Even as Russia’s actions are increasing
geopolitical tension, it continues to grow its global energy profile through this
expansion. As Russia accrues economic power, the United States is ceding it globally
with irrational energy policies that have already resulted in increased reliance on
foreign suppliers for the energy needs of our country.
The Proposed Rule, will only result in more homes in the United States being
heated by Russian natural gas rather than supplied with domestic products. In fact,
it has already happened. In 2018, “officials in Massachusetts and New Hampshire
blocked financing for the $3 billion Access Northeast Pipeline, which would have
reliably provided fuel to three New England states.”47 And yet while blocking this
pipeline, Massachusetts is offloading natural gas from Russia. This is alarming and
is nowhere addressed by PHMSA as s potential consequence of the Proposed Rule.
VI. PHMSA IS OPERATING BEYOND ITS STATUTORY AUTHORITY.
PHMSA contends, without any specific support for this change in its prior
position, that “any lost business opportunities could be offset by avoided safety and
environmental risks if the suspension reduces the transportation of LNG (i.e., if it
prevents transportation or production of LNG that would otherwise occur).”48
PHMSA admits the purpose of the Proposed Rule is not really about safe
transportation of hazardous materials in interstate commerce. Rather, it is intended
to indirectly regulate the extraction, production, and ultimately consumption of
natural gas, which is a purpose that exceeds PHMSA’s mandate under the Hazardous

44 Sam Meredith, Joanna Tan, Abigail Ng, Oil surges above $100 for the first time since 2014, before
paring gains, CNBC (Feb. 23, 2022), https://www.cnbc.com/2022/02/24/oil-prices-jump-as-russia-
launches-attack-on-ukraine.html (last accessed Feb. 25, 2022).
45 International Energy Agency, The Role of Critical Minerals in Clean Energy Transitions, Share of

Top Three Producing Countries in Extraction of Selected Minerals and Fossil Fuels, 2019 (2021),
https://www.iea.org/reports/the-role-of-critical-minerals-in-clean-energy-transitions/the-state-of-play.
46 David McHugh, Explainer: What’s Russia’s Nord Stream 2 Pipeline to Europe?, AP NEWS (Feb. 8.

2022), https://apnews.com/article/russia-ukraine-nord-stream-2-oil-pipeline-
779970ee17f6fa9d0fa2996e45cbeab9.
47 Drew Johnson, Why Is Russian Gas in Boston Harbor?, WSJ (Mar. 12, 2018),

https://www.wsj.com/articles/why-is-russian-gas-in-boston-harbor-1520897637.
48 Hazardous Materials: Suspension of HMR Amendments Authorizing Transportation of Liquefied

Natural Gas by Rail, 86 Fed. Reg. 61,731, 61,738 (Nov. 8, 2021).

Page 9

Materials Transportation Act (HMTA).49 Importantly in Utility Air Regulatory Group

(“UARG”) v. EPA, the Supreme Court stated:
When an agency claims to discover in a long-extant statute
an unheralded power to regulate “a significant portion of
the American economy,” we typically greet its
announcement with a measure of skepticism. We expect
Congress to speak clearly if it wishes to assign to an agency
decisions of vast “economic and political significance.50
In short, if Congress intended the PHMSA to regulate natural gas extraction,
production, or consumption, it has to clearly and expressly say so.51 Instead, it was
directed to regulate transportation. Thus, these broader energy policy objectives
exceed its statutory authority.

III. CONCLUSION
For the foregoing reasons, the undersigned Attorney Generals submit that
PHMSA should not proceed with a final rule to suspend or withdraw the 2020 Rule,
which established an efficient and safe mechanism for transporting LNG by rail. .

Sincerely,

Jeff Landry
Louisiana Attorney General

Steve Marshall Austin Knudsen

Alabama Attorney General  Montana Attorney General
 
 
 

49 49 U.S.C. § 5101–27 (2022).

50 Id. at 324 (2014) (quoting Brown & Williamson, 529 U.S., at 159).
51 See id.
Page 10

Treg Taylor Doug Peterson

Alaska Attorney General Nebraska Attorney General

Mark Brnovich John M. Formella

Arizona Attorney General New Hampshire Attorney General

Leslie Rutledge Dave Yost

Arkansas Attorney General Ohio Attorney General

Ashley Moody John O’Connor

Florida Attorney General Oklahoma Attorney General
 

Chris Carr Alan Wilson

Georgia Attorney General South Carolina Attorney General

   
   
Page 11

Lawrence Wasden Jason Ravnsborg

Idaho Attorney General South Dakota Attorney General

Todd Rokita Ken Paxton

Indiana Attorney General Texas Attorney General
   

Derek Schmidt Sean D. Reyes

Kansas Attorney General   Utah Attorney General
 

Daniel Cameron Jason S. Miyares

Kentucky Attorney General  Virginia Attorney General
 

Lynn Fitch Patrick Morrisey

Mississippi Attorney General West Virginia Attorney General

Eric S. Schmitt Bridget Hill

Missouri Attorney General Wyoming Attorney General