STB Finalizes Reciprocal Switching Rule

STB

WASHINGTON –– The Surface Transportation Board (STB) on April 30 reported adopting Reciprocal Switching for Inadequate Service, STB Docket No. EP 711 (Sub-No. 2), by unanimous vote, implementing new regulations at 49 CFR part 1145, which it said “sets forth a path for shippers and receivers to petition the Board for the prescription of a reciprocal switching agreement.” The final rule “is designed to promote adequate rail service,” according to the STB. Board Member Robert Primus concurred with a separate expression, noting “I am voting for the final rule because something is better than nothing.” Frank N. Wilner, Railway Age Capitol Hill Contributing Editor, weighs in and provides a reciprocal switching “primer.”

Under the new regulations, STB reported that “eligibility for prescription of a reciprocal switching agreement will be determined in part using objective performance standards that address reliability in time of arrival, consistency in transit time, and reliability in providing first-mile and last-mile service.” The Board said it “will also consider, in determining whether to prescribe a reciprocal switching agreement, certain affirmative defenses and the practicability of a reciprocal switching agreement.” To help implement the new regulations, the STB said it will require “all Class I railroads to submit certain service data on an ongoing and standardized basis, which will be generalized and publicly accessible.” Railroads will also be required “to provide individualized, machine-readable service data to a customer upon a written request from that customer,” according to the STB.

The STB last September issued the Notice of Proposed Rulemaking (NPRM) that it said focused on “providing rail customers with access to reciprocal switching as a remedy for poor service.” It called the move “an important step in addressing the many freight rail service concerns expressed by stakeholders since 2016.”

“In the past several years, and particularly since 2021, it has become clear that many rail customers nationwide have suffered from inadequate and deteriorating rail service,” STB Chairman Martin J. Oberman said during the NPRM announcement, which the Board members issued by unanimous vote. “These problems were documented in detail in the hearings conducted by the Board in April 2022  … The Board has continued to closely monitor the state of rail service.

“For this reason, the Board has determined to focus its efforts with respect to reciprocal switching on providing relief to rail customers suffering from poor service. With the issuance of today’s [Sept. 7] NPRM, the Board is proposing that one approach to improving rail service is to afford affected shippers the opportunity to obtain a reciprocal switch to a competing Class I carrier when service falls below a standard set in the proposed rule.

“The new rule contains a distinct advantage over both the existing regulations and the proposal in the 2016 NPRM [Docket No. EP 711 (Sub-No. 1)]. The proposed new rule sets specific, objective and measurable criteria for when prescription of a reciprocal switching agreement will be warranted. This rule will bring predictability to shippers and will provide Class I carriers with notice of what is expected of them if they want to hold on to their customers who might otherwise be eligible to obtain a switching order. As a result, litigation costs to obtain a switch should be greatly reduced and petitions to obtain a switching order should be able to be litigated much more swiftly.”

The Sept. 7, 2023, release of the NPRM closed Docket No. EP 711 (Sub-No. 1) and proposed, in a new Subdocket (Docket No. EP 711 [Sub-No. 2]), a new set of regulations. The comment period closed Nov. 7, 2023.

Final Rule Details

Under the final rule (download below), “customers within a terminal area that have access to only one Class I rail carrier may petition the Board to order a reciprocal switching agreement when the customer’s rail service falls below specified levels,” according to the STB. “Board-prescribed reciprocal switching agreements will allow shippers or receivers to gain access to an additional line haul carrier, while still allowing the incumbent carrier to compete for the customer’s traffic. Reciprocal switching orders by the Board will be for a minimum of three years and a maximum of five years.” The STB reported that it “considers the new reciprocal switching rule to be a significant step in incentivizing Class I railroads to achieve and maintain higher service levels on an ongoing basis by permitting a competing line haul carrier to offer better service to win the customer’s business.”

The STB on Sept. 7, 2023, issued an NPRM that would provide for the prescription of reciprocal switching agreements with emphasis on rail service performance. At that time, STB explained that “given the recurring service problems that plague the industry, it would focus reciprocal switching reform on service-related issues. The Board received many comments from interested parties.”

STB now adopts a version of part 1145 that it said “reflects certain modifications to the proposal in the NPRM.” The final rule identifies three performance standards. According to the STB, “[i]f a rail carrier’s service to a customer falls below any of these standards, that customer may petition the Board to prescribe a reciprocal switching agreement, assuming the other parameters of the rule are met.”

1. Service Reliability: Original Estimated Time of Arrival (OETA). According to the STB, the “service reliability standard measures a Class I rail carrier’s success in delivering a shipment on time. The rail carrier success will be judged based on the estimated time of arrival that the rail carrier provided when the shipper tendered the bill of lading for shipment or, in the case of an interline move, when the incumbent rail carrier receives the shipment from a delivering carrier.” The OETA “would be compared to when the car was delivered,” STB reported. “The Board proposed in the NPRM a reliability standard of 60%, where a carrier would meet the standard if, over a period of 12 consecutive weeks, the carrier delivered at least 60% of the relevant shipments within 24 hours of the OETA.” In the final rule, the Board “adopts the service reliability standard in the NPRM with the following changes: (1) the reliability standard will increase from 60% to 70%; (2) the definition of “delivery” will be clarified for purposes of interchange; (3) the reliability standard will measure early arrivals as well as late arrivals, in each case with a 24-hour grace period; (4) the reliability standard will be clarified for cross-border traffic; and (5) the reliability standard will only apply individually to each lane of traffic to/from the petitioner’s facility.”
2. Service Consistency: Transit Time. According to the STB, the “service consistency standard measures a rail carrier’s success in maintaining, over time, the carrier’s efficiency in moving a shipment through the rail system, i.e., the time it takes for a shipment to travel from its origin to its destination.” In the NPRM, the STB proposed “that, for loaded manifest cars and loaded unit trains, a rail carrier would fail the service consistency standard if the average transit time for a shipment over a 12-week period increased by either 20% or 25% as compared to the average transit time for that shipment over the same 12-week period during the previous year.” In the final rule, the STB “adopts the service consistency standard that was proposed in the NPRM using a 20% standard.” It also “modifies the definition of delivery to better reflect custom and practice”; “clarifies how it measures transit time performance on international lanes”; “adds a three-year measure of 25% to guard against excessive cumulative increases in transit time”; “creates an absolute floor for both the one-year and three-year measure of 36 hours”; and “provides that the service reliability standard only applies to individual lanes of traffic to/from the petitioner’s facility.”
3. Inadequate Local Service: Industry Spot and Pull (ISP). ISP, the third performance standard, “measures a rail carrier’s success in performing local deliveries (‘spots’) and pick-ups (‘pulls’) of loaded railcars and unloaded private or shipper-leased railcars during the planned service window,” according to the STB. In the final rule, the federal agency “adopts the local service standard that was proposed in the NPRM using a 12-hour work window.” It also increases the local service standard to 85%; “extends the period during which a 90% standard would apply to two years when a rail carrier unilaterally reduces service”; and “clarifies how success in spotting ‘spot on arrival’ railcars will be measured”; and “clarifies that the local service standard does not apply to unit trains or intermodal traffic.”

Additionally, the STB adopts the data collection it proposed in the NPRM. All six Class I railroads, it said, must begin reporting based on the new, standardized definitions of OETA and ISP. STB also, requires Class I’s “to provide, within seven days of receiving a request from a shipper or receiver, all individualized performance records necessary for that shipper or receiver to file a petition under part 1145.” According to the STB, Part 1145 pertains to shippers and receivers “that have practical physical access to only one Class I rail carrier or its affiliated company”; that affiliated company might be a Class II (regional) or Class III (short line) railroad. Part 1145, it said, otherwise does not apply to Class II’s and Class III’s.

STB reported that it “will excuse an incumbent rail carrier’s failure to meet a performance standard if such a failure was caused by “(a) extraordinary circumstances, such as acts of God; (b) a surge in the shipper’s/receiver’s traffic of more than 20% about which the shipper/receiver did not give the incumbent rail carrier advanced notice; (c) highly unusual shipment patterns by the shipper/receiver; (d) dispatching choices of a third-party; or (e) third-party conduct outside the incumbent carrier’s reasonable control.” The federal agency said that it will also “consider, on a case-by-case basis, affirmative defenses not specified in part 1145.” The STB said it “spells out that an incumbent carrier’s intentional reduction or maintenance of its workforce at a level that itself results in a workforce shortage causing the carrier to fail specified service standards would not, on its own, be considered a defense.”

In prescribing a reciprocal switching agreement, the STB said it “shall prescribe a minimum term of three years and may prescribe a longer term of service up to five years when circumstances warrant a longer prescription (rather than the two to four years that was proposed).” The incumbent rail carrier, it noted, “may petition the Board to terminate the prescription at the end of the prescribed term if the incumbent rail carrier is able to demonstrate that its service for similar traffic met all three performance standards for the most recent 12-week period prior to the filing of the petition to terminate (rather than the prior 24-week period that was proposed).” If the petition to terminate is denied, the STB said it “will extend the prescription for up to the same period as the initial prescription.” If the incumbent carrier “does not file a petition for termination, the prescribed agreement will automatically renew at the end of its term for the same period as the initial prescription,” the STB noted.

For traffic “that is moved under a transportation contract pursuant to 49 U.S.C. 10709,” the STB said it “will not prescribe a reciprocal switching agreement under part 1145 based on the incumbent carriers’ performance occurring during the term of the contract.” The STB said it “determines that use of contract performance data as the basis to prescribe a reciprocal switching agreement under the rule would be inconsistent with the statutory limitations imposed by section 10709.”

Finally, the STB reported that it “will not prescribe a reciprocal switching agreement under part 1145 for movements of exempt commodities”; rather, “a shipper or receiver would need to obtain partial revocation of the exemption before filing a petition under part 1145.” The STB clarified that it will not rely on “pre-revocation performance” as the basis for a prescription of a reciprocal switching agreement under the rule. “Recognizing the potential hardship this process might cause, the Board will prioritize petitions for partial revocation,” it said. “The Board also intends to explore, at a later date, whether it should partially revoke exemptions on its own initiative to allow for reciprocal switching petitions, as is currently the case for the boxcar exemption.”

“In choosing to focus reciprocal switching reform on service issues at this time,” the STB said that it “has not foreclosed further consideration of additional reforms geared toward increasing competitive options.” Additionally, “even with the adoption of part 1145, shippers may still pursue access to an alternate rail carrier under parts 1144 and 1147, and advocate for continued development, including, as appropriate, development by the Board of adjudicatory policies and the appropriate application of those rules in individual cases,” according to the STB.

The STB’s decision will be effective 120 days from the date of publication in the Federal Register.

President Joe Biden’s National Economic Council commented: “This unanimous rule will help keep our supply chains moving on time and lower the cost of shipping goods for thousands of businesses across the country from farmers to manufacturers. In turn, businesses who depend on freight rail should pass savings on to consumers and give them a better deal.” — Lael Brainard, National Economic Advisor

Oberman: Reciprocal Switching Rule ‘Has Broken New Ground’

“Nearly 40 years ago, the ICC, by rule and by subsequent decisions, established what was perceived as a high bar for the issuance of a reciprocal switching order,” STB Chairman Martin J. Oberman said in a statement April 30, less than two weeks before he retires. “Indeed, no reciprocal switching orders have been issued since before 1985, and none have even been sought since 1989. The rail network of 1985 is a far cry from that of today, and significant change is overdue.

“Today, by unanimous vote, the Board took a crucial step to lifting these decades old barriers to reciprocal switching for captive shippers. The rule adopted today has broken new ground in the effort to provide competitive options in an extraordinarily consolidated rail industry.

“Given the repeated episodes of severe service deterioration in recent years, and the continuing impediments to robust and consistent rail service despite the recent improvements accomplished by Class I carriers, the Board has chosen to focus on making reciprocal switching available to shippers who have suffered service problems over an extended period of time.

“First, although limited to consideration of reciprocal switching petitions, for the first time, the Board has set easy to measure, objective service standards for carriers: maintaining 70% or better on-time performance, not increasing transit time by more than 20% year over year, or maintaining at least 85% success on “industry spot and pull” (effectively measuring first mile-last mile service).

“[T]he new rule underscores that the railroad’s intentional reduction of its workforce levels and/or equipment availability (particularly locomotives) will not excuse resulting poor service when the Board is considering a reciprocal switching petition.”

—STB Chairman Martin J. Oberman

“Second, for the first time, the Board is mandating that these three service metrics be maintained on a standardized basis across all Class Is, permitting both rail customers and the Board to accurately measure service across the industry and quickly assess Class I carrier performance. Of equal importance, the carriers must make each shipper’s performance data readily available to the shipper on request.

“Third, while the Board is allowing for a carrier whose service has fallen below a standard to prove that the failure was for certain reasons beyond its control, the new rule underscores that the railroad’s intentional reduction of its workforce levels and/or equipment availability (particularly locomotives) will not excuse resulting poor service when the Board is considering a reciprocal switching petition.

“Finally, to assure commercial practicality for both the shipper and the potentially competing railroad, reciprocal switching orders will be for a minimum of three years and a maximum of five years, and can be renewed if the incumbent carrier fails to show that its service performance can meet the service standards, or simply chooses not to seek a termination of the switching order.

“Under this rule, even when a shipper has obtained a reciprocal switching order from the Board, the incumbent carrier is more than free to continue to compete to retain that shipper’s business by improving its performance behavior and trying to keep the shipper from choosing—that is, “switching to”—the competing railroad. This competition between the incumbent and alternate carrier is central to the operation of the rule. It allows the introduction of competition to incentivize better rail service.

“In my view, the most significant advantage to the new pragmatic approach will be the ease and speed of bringing and obtaining a switching order from the Board. Compared to existing rules and earlier reform proposals, the litigation process under the new rule will be much cheaper and faster. Rather than attempting to apply subjective and largely ill-defined criteria to a switching petition, the threshold for success under the new rule will be an easily ascertainable measure, e.g., either the carrier has provided an average of 70% or better on time performance over a 12-week period or it did not. The numbers will tell the story. The framework here—both the objective service standards and the potential carrier defenses—holds down needless litigation costs and delay.

“After making sure that this initial approach is, in fact, being utilized by eligible shippers and is working effectively to accomplish its goals, the Board can use what it has learned from this rule to explore additional opportunities to expand competitive access.”

—STB Chairman Martin J. Oberman

“For these reasons, I am confident that shippers who are suffering service below the rule’s standards and who are otherwise eligible will have relatively little trouble in obtaining switching orders under this rule.

“The new rule has been enacted after very careful consideration and deliberation by the Board, including the review of 57 comments by stakeholders amounting to over a thousand pages. After decades with no Board-ordered reciprocal switching and steadfast opposition by the rail industry to any change, the Board has chosen an incremental, but nevertheless concrete and substantive change to the competitive landscape. The Board chose this approach rather than trying to impose a sweeping reform in one fell swoop on an industry which doesn’t always adapt well to rapid change.

“Under this approach, the Board and stakeholders will have the opportunity to employ reciprocal switching in limited and controlled circumstances with objective measurements to evaluate its success. After making sure that this initial approach is, in fact, being utilized by eligible shippers and is working effectively to accomplish its goals, the Board can use what it has learned from this rule to explore additional opportunities to expand competitive access.

“Some stakeholders had urged the Board to pursue a more far-reaching reform of the limitations to reciprocal switching—in particular, by making reciprocal switching applicable to traffic moving under contract. I am sympathetic to that desire. Much of traffic moves under contract, and very few contracts contain service standards. However, the Board is prohibited by statute from applying the new rule to contract traffic. Had the Board attempted to do so, it would almost certainly have resulted in a court challenge that might have undermined the entire effort.

“What is important to understand is that even though the new rule is limited to common carrier traffic, the institution of standardized performance standards is intended to, and I am confident will, incentivize Class I railroads to meet these standards in order to avoid being subject to reciprocal switching orders. And because of the network nature of rail traffic, particularly with one train often carrying both common carrier and contract traffic, improvements in Class Is’ attention to meeting the new service standards should benefit many more shippers than just those who can petition for a reciprocal switch.

“Since joining the Board more than five years ago, it has been apparent to me that a lack of competition in the rail industry has allowed monopolistic practices to cause not only an increase in rail prices but a severe deterioration in the quality of rail service. That deterioration in service quality has been a real depressant on the nation’s economy and threatens our ability to compete in the international market. Less rail service also hampers the effort to control greenhouse gases since rail is so much more environmentally friendly than trucking.

“The new reciprocal switching rule provides access to competition where there was none. And most importantly, we are allowing competition between carriers to be the driving force for better service, rather than heavy handed dictates by the Board. Indeed, the approach of the new rule furthers the transportation policy mandated by Congress in the Staggers Act—“to ensure the development . . .of effective competition among rail carriers” and to “minimize the need for Federal regulatory control.”

“I hope that the Class I carriers will heed the call of this rule and not only improve their service levels but maintain them consistently over time. If they do, they will be fulfilling their critical obligations to both their customers and the public, while at the same time minimizing the need for the Board to enact even more far-reaching regulatory requirements.”

Primus: STB Rule ‘Likely to Have Far Less Benefit Than it Intends’

STB Member Robert Primus concurred with a separate expression.

“The final rule adopted today is unlikely to accomplish what the Board set out to do under the statute’s authorization of reciprocal switching that is ‘practicable and in the public interest,’” Primus wrote. “And, despite my urging, the Board is not taking action to improve access to the statute’s other prong, addressing reciprocal switching that is ‘necessary to provide competitive rail service’ … I am voting for the final rule because something is better than nothing. But there is far less ‘something’ here than I had hoped there would be. This final rule relies on service performance standards, which the incumbent carrier must fail during a 12-week period before a petitioner can seek a reciprocal switching order. The NPRM requested comment as to whether the Board may consider performance data based on service provided under a contract. NPRM, 88 FR at 63909. In this way, the NPRM left open the possibility that a petitioner would already know, before taking any steps towards filing its petition (aside from requesting the data), that 12 weeks of data are available to demonstrate failure under one of the performance standards.

“The same is not true, however, with respect to the final rule. A large proportion of rail traffic moves under contract, and the final rule establishes that the Board will not prescribe a reciprocal switching agreement under part 1145 based on performance that occurs during the term of a contract … In other words, a customer receiving substandard service under a contract cannot seek relief under part 1145. A prospective petitioner would instead need to shift from transportation under a contract to transportation under a tariff and then receive 12 weeks of substandard service before it could seek relief. Changing from contract to tariff transportation is something that rail customers generally prefer to avoid, as tariff rates can be substantially higher than contract rates …

“A would-be petitioner under the final rule could incur this ‘tariff premium’ indefinitely; 11 weeks into the customer’s payment of tariff rates, for example, the carrier’s average performance for the period could move above the threshold before falling again. Depending on the magnitude of this blip in the data, the 12-week period could effectively begin again. Rather than incurring the costs of tariff transportation indefinitely—before knowing whether a reciprocal switching petition is even a possibility—I expect contract customers will simply avoid trying to use part 1145.

“Contrary to an assertion in the decision above, the final rule therefore does not provide most rail customers with a reasonably predictable and efficient path toward a prescription under section 11102(c). I also do not share the optimism reflected in the decision’s expectation that part 1145 will be a significant step in incentivizing Class I railroads through competition to achieve and maintain higher service levels on an ongoing basis.”

— Robert Primus, STB Member

“The decision opines that, ‘if the rule can achieve its objectives with respect to common carrier traffic, this would make it worthwhile.’ As the decision acknowledges, however, only a small percentage of traffic moves in common carrier service. And part 1145 does not even apply to all common carrier traffic; the traffic must also be non-exempt, among other requirements. Because the decision ‘clarifies that [the Board] will not rely on pre-revocation performance as the basis for a prescription of a reciprocal switching agreement under this rule,” customers whose transportation is exempt will face obstacles similar to those of contract customers should they wish to seek reciprocal switching. Such a customer would need to obtain partial revocation of the exemption—litigation that may be costly and time-consuming in itself, given the Board’s statement that ‘parties would be allowed to present counterbalancing evidence to demonstrate why partial revocation would not be warranted’—before potentially usable performance data even begins to accrue. Similar to contract customers, a customer who litigates and wins a partial revocation would do so unaware of whether it would ever become eligible to file a petition attempting to obtain reciprocal switching.

“I disagree with the conclusion that aiming so low is worthwhile, given that the Board could have implemented the public interest prong without the deterrent effect I have described … And that is not to mention the fact that the Board is ‘choosing to focus reciprocal switching reform on service issues at this time,’ while deferring to some uncertain future date any action on the competitive rail service prong …

“Contrary to an assertion in the decision above, the final rule therefore does not provide most rail customers with a reasonably predictable and efficient path toward a prescription under section 11102(c). I also do not share the optimism reflected in the decision’s expectation that part 1145 will be a significant step in incentivizing Class I railroads through competition to achieve and maintain higher service levels on an ongoing basis. Rather, the Board’s action is likely to have far less benefit than it intends.

“This is a missed opportunity. Almost 13 years after the National Industrial Transportation League filed its petition for rulemaking with regard to reciprocal switching, the Board is adopting rules that do nothing with respect to the statute’s competitive rail service prong and may not do very much under the public interest prong. We should do more, we should do better, and we should do it without letting another decade pass.”

Wilner Commentary

Railway Age Capitol Hill Contributing Editor Frank N. Wilner, author of “Railroads & Economic Regulation” that details the history of railroad-shipper conflicts, said of the final rule:

“The significance is that following decades of dithering, regulators finalized a meaningful rule on competitive access. For the first time, observable rail service standards are established; captive shippers gain insight into their individualized service records; and the STB will collect on-time performance and first/last mile standardized data.

“The rule allows captive shippers demonstrating poor service reliability under three STB-established standards—on-time performance, transit time and first/last mile success in spotting and pulling cars—to petition the agency for access to a second, competing railroad through a physical interchange at any yard used to collect, classify and distribute freight cars. There is no maximum distance limiting the remedy.

“Thus, the trigger for relief is service failure and not rate abuse as many shippers also sought. The Board, however, has other rate methodologies benefiting shippers, including Final Offer Rate Review currently under judicial appeal.

“Especially notable is that the rule—forever contentious politically and among stakeholders—gained five-vote unanimity that speaks forcefully of this Board’s collegial approach to economic regulation. There most assuredly was compromise at every intersection during drafting. It is a pragmatic approach creating space to do more in the future, should events warrant.

“And what a distinct and positive difference from not too awfully long ago when the New York Times reported how the agency had ‘become entrapped in bitter internal battles and a source of great embarrassment to the White House, which watched the [regulators it nominated] bicker publicly.’”

Industry Response

The Association of American Railroads on April 30 released the following statement on the STB action: “While we review this lengthy and complex final rule, it is important to note that from the outset, railroads have been clear about the risks of expanded switching and the resulting slippery slope toward unjustified market intervention. In the proposed rule, the STB was prudent to reject previous proposals that amounted to open access. As we review the impacts of this new rule, it remains true that the well-functioning freight market will almost always achieve better outcomes than bureaucratic mandates. As such, railroads will continue to invest billions each year to enhance safety and service for the benefit of our vast mix of customers.”

Reciprocal Switching Primer

Frank N. Wilner also provided Railway Age with the following background on reciprocal switching:

“Reciprocal Switching describes a practice by which a railroad with physical access to a shipper facility switches cars to or from that facility on behalf of a second railroad lacking physical access, with the second railroad paying a per-car fee for the switching. Reciprocal Switching can be voluntary, in that it is an arm’s length agreement between two railroads, or it can be required by regulators as a remedy where the railroad with physical access is found to be abusing its market power by extracting unreasonable terms or rendering inadequate service.

“A 2015 congressionally funded study by the Transportation Research Board (Modernizing Freight Rail Regulation) characterized Reciprocal Switching as ‘allowing other railroads to market the host railroad’s terminal as if it were their own.’

“Reciprocal Switching should NOT be confused with Terminal Trackage Rights, the latter allowing the entry by one or more railroads (locomotives and crew) into the terminal area of a competing railroad from an unspecified ‘reasonable distance’ outside of the terminal.

“NOR should Terminal Trackage Rights be confused with ‘Overhead Trackage Rights,’ the latter allowing for main line track sharing following a derailment or flooding—or for commercial reasons. In instances of Overhead Trackage Rights, the tenant does not serve the host railroad’s customers. If the two cannot agree on compensation,

“The 1980 Staggers Rail Act authorized the former Interstate Commerce Commission (STB since Jan. 1, 1996) to impose a remedy of Reciprocal Switching to enhance competition at sole-served shipper facilities. 

“By law, the remedy must be ‘practicable and in the public interest, or where such agreements are necessary to provide competitive rail service.’ The maximum distance to or from the shipper facility and a practical junction point with the second railroad was not defined by statute, although the National Industrial Transportation League has recommended up to 30 miles between a junction point and the shipper facility.”

Further Reading

• ‘Poor Service’ Drives STB’s Proposed Reciprocal Switching Rule
• Rail Stakeholders Weigh in on Reciprocal Switching Proposal
• STB and Reciprocal Switching: Abject Regulatory Failure
• STB to AAR on Reciprocal Switching: 15 More Days to Comment
• POINT/COUNTERPOINT: STB EP 711, ‘Reciprocal Switching for Inadequate Service’
• A Primer on Reciprocal Switching
• AAR to STB: Reciprocal Switching a ‘Wealth Transfer to More-Profitable Entities’
• STB to AAR: Sorry, No Extension
• STB proposes “forced access” regulations
• Shippers ask STB to deliver a free lunch