CSX and Norfolk Southern argue that filing these contract summaries is a significant burden that “outweighs any potential benefit,” according to the filing.
Norfolk Southern officials, in the filing, also pointed out that the contract information is rarely used. According to the carrier, in the past three years, these summaries, which are published on the STB’s website, “are not accessed or used very much.” On top of the public not viewing the summaries, the railroads argued that the data hasn’t been used by the board in any substantive ruling.
“Given the few times that these contract summaries have ever been accessed by anyone and the lack of reliance on them by the board or any party in any regulatory matter, they are clearly not necessary to carry out the transportation policy nor are they needed or used to protect shippers from an abuse of market power,” the carriers wrote.
Norfolk Southern said it filed 348 contract summaries in 2010, submitting 362 in 2011. The petitioners wrote that CSX filed more than 3,000 summaries between 2010 and 2012. For Norfolk Southern, the filing work involved takes up six hours per week. The carriers said they have implemented “unique electronic processes” to handle the workload.
“Maintaining such processes requires ongoing information technology support,” they wrote. “Overall, this expenditure of time and resources is substantial — especially compared to the lack of access and use of the contract summaries.”
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The day before F3. Every compliance issue you face - fraud exposure, carrier liability, FMCSA rules, cargo theft, insurance gaps - navigated by attorneys and operators defining best practices in a changing industry.
The Signal at Chattanooga Choo Choo • Chattanooga, TN Register NowThe night before F3. FreightTech100 companies honored. FreightTech 25 and Shipper of Choice winners revealed live. Cocktail reception into dinner and live music - 300 industry leaders in one purpose-built room.
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The Signal at Chattanooga Choo Choo • Chattanooga, TN Register Now