NITL attended the May 11, 2023, meeting of the FMC’s National Shipper Advisory Committee (NSAC) where public participation and comment was requested, among other matters, on the NCAS proposed resolution regarding rail storage charges assessed on containers moving in international commerce. NITL supports the NCAS proposal which asks the FMC to address rail storage charges in its pending rulemaking in Docket No. FMC-2022-0066-0090, Demurrage and Detention Billing Requirements. Specifically, NITL supports expanding the definition of demurrage to include railroad storage charges that are assessed as part of through transportation under ocean bills of lading and requiring ocean carriers to be the billing party for such charges. This proposal would ensure that rail storage charges assessed on intermodal shipments moving in international commerce are subject to FMC oversight and the OSRA22 requirements.