Letters to Washington
| December 20, 2023

Letter to Surface Transportation Board on STB's Notice of Proposed Rulemaking in “Reciprocal Switching for Inadequate Service” Board Action

National Stone, Sand & Gravel Association (NSSGA) submits these Reply Comments in response to the Surface Transportation Board’s (STB or the Board) Notice of Proposed Rulemaking (NPRM) in “Reciprocal Switching for Inadequate Service,” Board action that focuses on providing rail customers with access to reciprocal switching as a remedy for poor service, based around three measures of carrier success or failure, namely: (1) service reliability; (2) service consistency; and (3) adequacy of local service. In its opening comments, NSSGA expressed its enthusiasm for the Board’s action in this docket to hold rail carriers accountable, to provide rail shippers some measure of relief from poorly performing incumbent rail carriers, and to enforce, in the Board’s own words, “unambiguous, uniform standards…consistently applied across Class I rail carriers and their affiliated companies.” NSSGA continues to support this critical action and the NPRM as a whole, subject to the modifications NSSGA advanced in its Opening Comments. With that in mind, however, NSSGA feels compelled to address some of the arguments advanced by rail carriers through the Association of American Railroads (AAR), whose own opening comments and arguments contained therein NSSGA views as contrary to the central aims of this proposed rule.