The National Grain & Feed Assn. (NGFA) has submitted a statement to the Surface Transportation Board (STB) again calling on the agency to develop a new streamlined and cost-effective method for grain and other agricultural shippers to challenge unreasonable rail rates.
NGFA submitted the statement in response to an STB proposal to improve and expedite its existing freight rail rate review process.
"The NGFA consistently has supported the STB's efforts to improve and streamline the procedures used to evaluate formal rail rate complaints," the statement said, referencing NGFA's extensive 2014 proposal of a new, innovative, objective and inexpensive rate challenge methodology. "The NGFA again urges the STB to redouble its efforts to develop and implement meaningful changes to its current rate-reasonableness standards and methodologies that have rendered futile the pursue of rate-reasonableness challenges by grain and other agricultural shippers."
No rate challenge has been filed by an agricultural shipper in nearly 40 years, NGFA added.
In its statement, NGFA commended STB for several of its proposed procedures designed to expedite rate cases, which the association said also could be applied to a new process for challenging unreasonable grain rail rates if STB ultimately creates one.
The STB-proposed concepts supported by NGFA would involve limiting the length of final briefs in rate cases to no more than 30 pages. However, NGFA did recommend that STB evaluate the need for or length of closing briefs on a case-by-case basis to determine whether to dispense with filing final briefs or even shorter page limits depending upon the case and issues involved.
NGFA also supports appointing a staff liaison at STB to be the point of contact to provide technical advice to parties involved in a specific rate case in an effort to reduce the number of issues brought to the full agency for resolution.
Last, NGFA said it backs staggering the filing of public and highly confidential versions of filings three days apart, as well as adoption of standardized markings to designate confidential, highly confidential and sensitive security information.