NITL EP711 Comments Submitted to FMC

The Coalition Associations hereby submit these Reply Comments in response to the Notice of Proposed Rulemaking (“NPRM”) served in this docket by the Surface Transportation Board (“STB” or “Board”) on September 7, 2023. These Reply Comments respond to the opening comments of the Association of American Railroads (“AAR”) and the six Class I railroads.2 The reciprocal switching statute at 49 U.S.C. § 11102(c) contains two alternative standards for prescribing reciprocal switching. The first is “practicable and in the public interest” 1The “Coalition Associations” are the American Chemistry Council (“ACC”), The Fertilizer Institute (“TFI”), and The National Industrial Transportation League (“NITL”).

Click here to read the comments.