The STB has exclusive jurisdiction over rail transportation by G&U. G&U is a common carrier, which means that it has an obligation to provide rail transportation service upon request by a customer. G&U can be relieved of this common carrier obligation only by means of an order of the STB permitting discontinuance or abandonment of operations pursuant to 49 USC. 10903. The town could attempt to stop the activities of the railroad at the yard while a request for a declaratory order was pending at the STB by seeking an injunction from the STB or in Federal Court. In order to be successful in seeking an injunction pending a final determination on preemption, the Town would have to make a case that it is entitled to an injunction under traditional criteria applied by the STB and the courts, which would include a demonstration by the Town that it is likely to succeed on the merits, that it would suffer irreparable harm unless an injunction were granted, that the public interest would not be harmed by an injunction and that the alleged harm to the Town without an injunction outweighed the harm to the railroad by temporary cessation of its operations. The railroad would likely vigorously oppose an injunction, arguing that the criteria for an injunction could not be met and that rail transportation should be preserved pending a decision on the merits. The cost of seeking an injunction would be substantial, involving the preparation of legal briefs and testimony and participating in hearings, and the likelihood of success is not great.