Reciprocal Switching Comments Submitted 2142022

This testimony is presented in two parts. Part I challenges railroad arguments that the record is stale and needs updating by demonstrating that, if anything, developments over the past five years have strengthened the case for reciprocal switching. Part II responds to multiple topics that rail industry stakeholders have raised in ex parte meetings and their utter failure to rebut the facts and testimony presented in response to their objections to reciprocal switching. To minimize repetition of their previously submitted opening and reply comments in response to the Notice of Proposed Rulemaking,¹ the Coalition Associations have attached, as Exhibit 1, a single-page summary of their key arguments with cross-references to the opening and reply comments of The Shipper Coalition for Railroad Competition where the Board will find a detailed discussion.²

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¹ Reciprocal Switching, Docket No. EP 711 (Sub-No. 1), slip op. (served July 27, 2016)
(“2016 NPRM”).

² The summary in Exhibit 1 also was distributed as a hand-out at each of the ex parte meetings between members of the Coalition Associations and individual Board members.