Rail Transportation Contracts Under 49 U.S.C. 10709, 416-419 [E8-31398]
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Federal Register / Vol. 74, No. 3 / Tuesday, January 6, 2009 / Proposed Rules
with industry owners and operators.
The Coast Guard believes that in many
industries, owners and operators are
more aware of safety requirements and
do more to make sure their employees
follow those requirements when they
must document their compliance with
those requirements.
4. Rig No. 12 report. The Coast Guard
devotes significant resources to studying
the causes of accidents that result in
serious property losses, injury, or death,
so that similar accidents can be avoided
in the future. Lessons learned from
tragedy make special demands on us to
give them serious consideration and to
implement them if possible. In the
docket for this rulemaking at https://
www.Regulations.gov, we are placing
the formal investigation report into a
commercial diving death at Cliff’s
Drilling Rig No. 12 in 1996. The report
includes 13 recommendations and the
Coast Guard is considering adopting
most of these, in some cases with
modifications.
5. Regulatory priorities. We have
indicated our interest in industry
standards, third-party audits,
compliance documentation, and the Rig
No. 12 report recommendations. In
addition, we invite you to comment on
overall regulatory approaches or on
specific regulatory requirements that
you believe should be a priority for this
rulemaking. We are also inviting
comments on current industry practices
and changes in circumstances from
conditions existing in 1998.
6. Costs and Benefits. We request
comments on the costs and benefits of
regulatory revisions suggested by the
commenters. Providing us with specific
information on the costs and benefits of
regulatory suggestions will assist us
with fully evaluating the merits of such
suggestions. We are especially
interested in information providing data
on the cost of regulatory suggestions on
small entities, and State, local, and
tribal governments.
Dated: December 22, 2008.
Brian M. Salerno,
Assistant Commandant for Marine Safety,
Security and Stewardship, U.S. Coast Guard.
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DEPARTMENT OF TRANSPORTATION
Surface Transportation Board
49 CFR Part 1301
[STB Ex Parte No. 676]
Rail Transportation Contracts Under 49
U.S.C. 10709
Surface Transportation Board.
Notice of proposed rule.
AGENCY:
ACTION:
SUMMARY: The Surface Transportation
Board (Board or STB) proposes to
amend its rules to provide that where an
agreement for rail carriage contains the
disclosure statement to be set forth in
this new rule, the Board will not find
jurisdiction over a dispute involving the
rate or service under the agreement and
will treat that agreement as a rail
transportation contract governed by 49
U.S.C. 10709; and conversely where an
agreement for rail carriage fails to
contain the disclosure statement, the
Board will find jurisdiction over a
dispute involving the rate or service
under the agreement, absent clear and
convincing evidence that the parties
intended to enter into a rail
transportation contract governed by 49
U.S.C. 10709; and the shipper was made
aware that it could request service
under a common carrier tariff rate that
would be subject to STB jurisdiction.
DATES: Comments on this proposal are
due by February 5, 2009. Reply
comments are due by March 9, 2009.
ADDRESSES: Comments may be
submitted either via the Board’s e-filing
format or in the traditional paper
format. Any person using e-filing should
attach a document and otherwise
comply with the instructions at the E–
FILING link on the Board’s Web site, at
https://www.stb.dot.gov. Any person
submitting a filing in the traditional
paper format should send an original
and 10 copies to: Surface Transportation
Board, Attn.: STB Ex Parte No. 676, 395
E Street, SW., Washington, DC 20423–
0001.
Copies of written comments will be
available for viewing and self-copying at
the Board’s Public Docket Room, Room
131, and will be posted to the Board’s
Web site.
FOR FURTHER INFORMATION CONTACT:
Timothy Strafford at (202) 245–0356.
(Assistance for the hearing impaired is
available through the Federal
Information Relay Service (FIRS) at 1–
800–877–8339.)
SUPPLEMENTARY INFORMATION: In a
Notice of Proposed Rulemaking in STB
Ex Parte No. 669 served on March 29,
2007 (2007 NPRM) and published in the
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Federal Register on April 4, 2007 (72 FR
16316–18), the Board sought to address
two concerns arising from hybrid rail
pricing mechanisms such as the one
involved in Kansas City Power & Light
Company v. Union Pacific Railroad
Company, STB Docket No. 42095 (STB
served Mar. 27, 2007) (KCPL), which,
despite having characteristics of a rail
transportation contract beyond the
Board’s jurisdiction under 49 U.S.C.
10709, are designated by the carrier as
common carriage rates subject to the
Board’s jurisdiction.
The first concern was uncertainty.
Although Congress expressly removed
all matters and disputes arising from rail
transportation contracts from the
Board’s jurisdiction, 49 U.S.C. 10709(c),
the statute provides no clear
demarcation between a contract rate and
common carriage rate. The issue of
whether a rate is a contract rate or
common carriage rate has been
examined on a case-by-case basis in
light of the parties’ intent. See Aggregate
Volume Rate on Coal, Acco, UT to
Moapa, NV, 364 I.C.C. 678, 689 (1981).
With the enactment of the ICC
Termination Act of 1995 (ICCTA), it
became more difficult to distinguish
between the two types of rates, as
railroads are no longer required to file
with the agency either tariffs containing
their common carriage rates or
summaries of their non-agricultural
contracts.
The second concern was that
increased use of hybrid pricing
arrangements could create an
environment where collusive activities
in the form of anticompetitive price
signaling could occur. Although the
terms of a rail transportation contract
generally are kept confidential, the
terms and conditions of common
carriage rates must be publicly disclosed
upon request, 49 U.S.C. 11101, thereby
increasing the possibility of collusive
behavior in a highly concentrated
industry.
In the 2007 NPRM, the Board
proposed to address these two concerns
by interpreting the term ‘‘contract’’ in 49
U.S.C. 10709 as embracing ‘‘any
bilateral agreement between a carrier
and a shipper for rail transportation in
which the railroad agrees to a specific
rate for a specific period of time in
exchange for consideration from the
shipper, such as a commitment to
tender a specific amount of freight
during a specific period or to make
specific investments in rail facilities.’’
Both shippers and carriers opposed
that proposal. After reviewing their
comments, the Board concluded that its
original proposal might have
unintended and undesirable
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consequences, and it decided to
discontinue that proceeding.1
Nevertheless, we remained concerned
with the lack of any clear demarcation
between common carriage rates and
contract pricing arrangements and the
resulting ambiguity regarding the
Board’s jurisdiction. This ambiguity was
exhibited in two recent Board
proceedings regarding Option 2 of the
Union Pacific Railway Company’s
(UP’s) Circular 111.2 In the first
proceeding, the shipper, Kansas City
Power & Light Company, agreed with
UP that Circular 111 is a tariff. See
KCPL. In the second proceeding, the
shipper, Ameren Energy and Fuels
Services Company, argued that Circular
111 is a contract. See Union Pacific
Railroad Company—Petition for
Declaratory Order, STB Finance Docket
No. 35021 (STB served May 15, 2007).
The fact that two sophisticated shippers
regarded the same document, with the
same language, in completely opposite
ways underscores the need for greater
clarity.
Thus, we sought an alternative, lessintrusive way to distinguish contracts
from common carriage agreements.3
Specifically, we sought public comment
on whether the Board should require
that each carrier provide a formal
written disclosure statement when it
seeks to enter into a rail transportation
contract under 49 U.S.C. 10709. That
statement would explicitly advise the
shipper that the carrier intends the
document to be a rail transportation
contract and that any transportation
under the document would not be
subject to regulation by the Board. The
statement would further advise the
shipper that it has a statutory right to
request a common carriage rate that the
carrier would then have to supply
promptly, and that such a rate might be
open to challenge before the Board. We
also sought comment on whether to
include a requirement for a written
informed consent statement in which
the shipper acknowledges, and states its
1 A complete review of the comments submitted
in STB Ex Parte No. 669 and the Board’s reasons
for rejecting that approach and pursuing a different
approach by instituting STB Ex Parte No. 676 is
provided in Rail Transportation Contracts Under 49
U.S.C. 10709, STB Ex Parte No. 676, et al. (STB
served Mar. 12, 2008) (ANPR).
2 UP’s Circular 111, ‘‘Unit Train Coal Common
Carrier Circular Applying On: Unit Coal Trains
from the Powder River Basin of Wyoming,’’
contains two classes of rates for customers. One
class, referred to as Option 1, contains a higher rate
with no volume requirement. The second class,
referred to as Option 2, contains a lower rate with
commitments from both parties for term, volume,
rates, and service.
3 See ANPR supra.
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willingness to forgo, its regulatory
options.
The Board received comments from
Arkansas Electric Cooperative Corp.
(AECC); the Association of American
Railroads (AAR); BNSF Railway
Company (BNSF); CSX Transportation,
Inc. (CSXT); Edison Electric Institute
(EEI); National Grain and Feed
Association (NGFA); the National
Industrial Transportation League
(NITL); Norfolk Southern Railway
Company (NS); Occidental Chemical
Corp. (OxyChem); Olin Corp. (Olin);
PPG Industries, Inc. (PPG); Progressive
Rail, Inc. (PGR); Union Pacific Railroad
Company (UP); United Transportation
Union-General Committee of
Adjustment, GO–386 (UTU); the U.S.
Clay Producers Traffic Association, Inc.
(Clay Producers); and the Western Coal
Traffic League (WCTL). We have
reviewed the record and taken each of
these comments into account in the
development of the proposed rule.
Proposed Rule
The somewhat different rule we now
propose, which is set forth in the
regulatory text of this document, seeks
to provide a more objective means of
determining whether the parties’ intent
was to use a common carriage tariff
subject to the Board’s jurisdiction or to
agree to a rail transportation contract
outside the Board’s jurisdiction under
49 U.S.C. 10709.4 A need for a clear
demarcation between tariffs and
contracts has become evident in recent
Board proceedings and is recognized by
many within the industry.5 By
proposing a rule that would encourage
full disclosure to shippers of their
regulatory options at the time of
contract formation, the proposed rule
should further Congress’ dual intent to
offer regulatory protection to shippers
that desire such protection, while
encouraging private rail transportation
contracts for those shippers that prefer
such arrangements. The rule proposed
here would not require the inclusion of
a disclosure statement; rather, it would
simply set forth the criteria that the
Board would apply to determine its
4 This proposed rule would apply only to
agreements between shippers and carriers for rail
service. As PGR has pointed out, a disclosure
statement is not needed for contracts between
carriers, such as freight handling, haulage, and
switching agreements. Nor would the proposed rule
be intended to apply to separate contracts for
accessorial services such as demurrage and storage,
transloading to and from other modes, incidental
warehousing during transloading, and local
drayage.
5 See AECC at 2; CSXT at 4; Clay Producers at 1;
WCTL at 4.
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jurisdiction based on the presence or
absence of such a statement.
The significant change between this
proposal and our prior proposal is the
removal of the informed consent
requirement. The anticipated benefits of
the informed consent proposal are
outweighed by the potential for
unintended consequences that could
hamper contracting for rail carriage.
Carriers made a strong case that the
informed consent requirement would
unnecessarily complicate the contract
process and delay the timely
implementation of contracts, especially
when contracts are negotiated
electronically or in the case of
signatureless contracts.6 And shippers
made a strong case that, by signing an
informed consent statement, they would
be unable to argue in court that a
unilateral agreement is a contract of
adhesion.7 We believe that a
prominently displayed disclosure
statement that provides explicit notice
to the shipper of the nature of the
agreement would further Congress’
concern that shippers not opt out of our
regulatory protections unknowingly.
Nevertheless, the incremental benefit of
imposing an additional informed
consent requirement does not appear to
merit the hindrance and delay to
modern contract formation that it might
cause.
Given the Board’s lack of jurisdiction
over contracts under 49 U.S.C. 10709,
some comments suggest that any rule
should focus only on common carriage,8
an area clearly within our jurisdiction.9
But to exercise jurisdiction over matters
properly before us, we must be able to
distinguish between common carriage
and contract pricing arrangements in
situations where the terms and
conditions can appear to be identical.10
This proposal should establish a
practical way to allow a clear
demarcation between contract and
6 See AAR note 5 at 12; CSXT at 3; NS at 5; UP
at 7.
7 See Olin at 2.
8 See AAR at 5; BNSF at 4; CSXT at 7; NS at 3;
WCTL at 5.
9 Although the Board has authority to define how
it will determine what constitutes a tariff, doing so
could overlap with the jurisdiction of the courts.
For instance, NITL and others have argued that we
should define common carriage to include
unilateral rate offerings. See NITL at 5. However,
there are unilateral agreements that are recognized
by courts as contracts and we have no authority to
question a court’s judgment on these matters.
10 It is well-settled that the Board has jurisdiction
to determine its jurisdiction. See Burlington N., Inc.
v. Chicago & N.W. Transp. Co., 649 F.2d 556, 558
(8th Cir. 1981); cf. Wms. Gas Processing-Gulf Coast
Co. v. FERC, 475 F.3d 319, 323 (D.C. Cir. 2006)
(FERC must draw the line between nonjurisdictional gathering and jurisdictional
transportation of natural gas, a line that is ‘‘not
always clear’’).
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common carrier rates. With respect to
the proposed disclosure statement
provision, set forth in the proposed new
§ 1301.1 11 the disclosure statement
should be placed prominently at the top
of the first page of the agreement, in
type size at least as large as the type
used for the body of the agreement.12
We are not proposing that carriers be
required to use the disclosure statement
but rather that the inclusion of this
statement in an agreement would
establish clear and objective evidence
that the parties intended to enter into a
contract under 49 U.S.C. 10709 and that
their dispute thus lies outside the
Board’s jurisdiction. Absent the
inclusion of such a disclosure
statement, we would find that an
agreement for rail transportation is a
common carriage tariff and would take
jurisdiction over a rate or service
complaint absent clear and convincing
evidence both that the parties intended
to enter into a rail transportation
contract and that the shipper was made
aware that it could request a common
carriage tariff that would be subject to
STB jurisdiction.
This disclosure statement provision
should be a workable mechanism to
solve the demarcation problem between
contracts and tariffs without hindering
contracting or inappropriately
encouraging the use of tariffs. Use of the
disclosure statement by carriers should
adequately allay shipper and carrier
concerns in this regard.13 Nevertheless,
we remain open to comments not only
on the proposed rule itself but also
regarding the language of the disclosure
statement to ensure that it would not
inadvertently encourage a common
carriage agreement over a rail
transportation contract.
The disclosure statement provision
should promote regulatory efficiency by
establishing a transparent mechanism to
determine our jurisdiction over a rate or
service complaint instead of having to
glean the parties’ intent based on the
unique facts of each case before us. The
parties should benefit by the associated
reduction in legal fees in actions before
the Board and in court.
Railroads have suggested using a safe
harbor approach, instead of a disclosure
statement, to allow various ways to
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11 The
disclosure language is based on language
suggested by WCTL. See WCTL at 12.
12 Some shipper groups expressed concern that a
contract disclosure provision would be useless, and
possibly harmful to shippers, if the language is not
easily discernable on the front of the document. See
Clay Producers at 2–3. We are proposing to specify
the expected location and minimum type size in
order to address this concern.
13 See AAR at 10; BNSF at 3; UP at 7; WCTL at
11.
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demonstrate the parties’ intentions.14
Shippers suggest alternatively that any
ambiguity on the face of a document
should be construed against the carrier
as the drafter of the document.15 Neither
of these approaches would promote
efficiency, however, as they would
require the Board to examine extraneous
evidence beyond the document to
determine the parties’ intent in every
instance.
Finally, Olin expressed concern that
the Board not preempt by rule state law
as to what constitutes a contract, or on
whether one can have an enforceable
contract on rates without other agreedupon terms and conditions.16 We do not
intend for inclusion of the disclosure
statement in an agreement to be
dispositive in court that a contract
exists, or to preclude shippers from
making an argument that the document
is a contract of adhesion or raising any
other defense in state court. The
proposed rule is simply intended to be
a mechanism for assisting the Board in
determining the Board’s jurisdiction to
adjudicate a rate or service complaint
involving rail transportation
arrangements.
Ancillary Matters
Two additional concerns have been
raised in the shippers’ comments
regarding how carriers negotiate
contracts for rail service. They relate to
unilateral contracts and bundling.
Unilateral contracts, or signatureless
contracts, are contract offers made by a
carrier that a shipper accepts by
tendering shipment. Shippers suggest
that this practice should be considered
a tariff subject to Board jurisdiction, as
there is no bilateral negotiation.17 But
this practice is generally beyond the
jurisdiction of the Board; carriers may
offer and shippers may accept these
contracts, as long as state courts
recognize them as such. Instead, we
propose to regard unilateral or
signatureless agreements that lack the
disclosure language as common carrier
tariffs subject to our jurisdiction, unless
there is clear and convincing evidence
both that the parties intended to enter
into a rail transportation contract and
that the shipper was made aware that it
could request a common carriage tariff
that would be subject to STB
jurisdiction.
Bundling occurs when a shipper and
carrier negotiate multiple movements at
one time. Shippers claim that carriers
often refuse to provide common carriage
rates until contract negotiations are
exhausted, or they withdraw contract
offers on all movements if a tariff rate
is requested on any movement.18 The
purpose of the proposed rule is to
provide clarity regarding when an
arrangement is one for common carriage
and thus within the Board’s jurisdiction.
We will not complicate this proceeding
by addressing negotiating practices.
Carriers have a common carrier
obligation to provide service upon
reasonable request. Allegations of
violations of that obligation are best
considered by individual complaint.
Conclusion
This proposal is consistent with the
Board’s jurisdiction and regulatory
responsibilities. The proposed rule
would have no substantive effect on
contracting; the Board is not proposing
to dictate how parties negotiate. Nor
would the proposal seek to dictate to a
court of competent jurisdiction how to
interpret, apply, or determine what
constitutes a contract. However, as rail
transportation contracts and tariffs can
be indistinguishable, all parties should
know what they are agreeing to and
what rights may be available to them,
including any right to seek regulatory
relief.
The proposed rule, if adopted, would
apply prospectively only, and would
not be applicable to existing contracts,
existing amendments, or existing
supplements to contracts.19 But if the
proposed rule is adopted, all subsequent
contracts, amendments and
supplements, even those that attach to
contracts signed before the effective date
of the new rule, would need to contain
the disclosure statement in order to be
conclusively presumed to be a contract
under 49 U.S.C. 10907 and thus outside
of the Board’s jurisdiction.
Pursuant to 5 U.S.C. 605(b), the Board
certifies that the proposed action would
not have a significant economic effect
on a substantial number of small entities
within the meaning of the Regulatory
Flexibility Act.
This action will not significantly
affect either the quality of the human
environment or the conservation of
energy resources.
List of Subjects
49 CFR Part 1301
Administrative practice and
procedure, and Railroads.
Authority: 49 U.S.C. 721(a) and 10709.
14 See
AAR at 13; BNSF at 5; NS at 4; WCTL at
7.
18 See
EEI at 4; Oxychem at 2; Olin at 3.
agree with public comments to the ANPR
suggesting that any rule should only apply
prospectively. See AAR at 14.
15 See
WCTL at 6.
16 See Olin at 2.
17 See NITL at 5.
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Decided: December 30, 2008.
By the Board, Chairman Nottingham, Vice
Chairman Mulvey, and Commissioner
Buttrey.
Jeffrey Herzig,
Clearance Clerk.
DEPARTMENT OF THE INTERIOR
For the reasons set forth in the
preamble, the Surface Transportation
Board proposes to add part 1301 of title
49, chapter X, of the Code of Federal
Regulations as follows:
Endangered and Threatened Wildlife
and Plants; Partial 90-Day Finding on
a Petition To List 475 Species in the
Southwestern United States as
Threatened or Endangered With
Critical Habitat
PART 1301—RAIL TRANSPORTATION
CONTRACTS
Authority: 49 U.S.C. 721(a) and 10709.
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§ 1301.1
Contract Disclosure Statement.
(a) The Board will not find
jurisdiction over a dispute involving the
rate or service under a rail
transportation agreement where that
agreement contains a disclosure
statement that conforms with
paragraphs (b) and (c) of this section.
Conversely, where a rail transportation
agreement fails to contain such a
disclosure statement, the Board will
find jurisdiction over a dispute
involving the rate or service provided
under that agreement, absent clear and
convincing evidence both that the
parties intended to enter into a rail
transportation contract governed by 49
U.S.C. 10709 and that the shipper was
made aware that it could request service
under a common carrier tariff rate that
would be subject to STB jurisdiction.
(b) The disclosure statement should
appear at the top of the first page of the
rail transportation agreement in type
size at least as large as the type size used
for the body of the agreement.
(c) The disclosure statement should
read as follows:
Disclosure Statement—This
agreement constitutes a rail
transportation contract under 49 U.S.C.
10709. Contract arrangements are
generally not subject to challenge before
the Surface Transportation Board
(‘‘STB’’), but can be enforced in a court
of competent jurisdiction. Under federal
rules found at 49 CFR 1300, railroads
are required, upon request, to quote to
shippers a rate for common carriage
transportation (i.e., a non-contract rate).
Pursuant to 49 U.S.C. 10701, the STB
has jurisdiction (subject to some
exceptions) over disputes arising out of
common carriage (non-contract) rates.
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Fish and Wildlife Service
50 CFR Part 17
[FWS–R2–ES–2008–0130; MO 9221050083]
AGENCY: Fish and Wildlife Service,
Interior.
ACTION: Notice of 90-day petition
finding.
SUMMARY: We, the U.S. Fish and
Wildlife Service (Service), announce a
90-day finding on 270 species from a
petition to list 475 species in the
southwestern United States as
threatened or endangered under the
Endangered Species Act of 1973, as
amended (Act). We find that for these
270 species the petition does not
present substantial scientific or
commercial information indicating that
listing these species may be warranted.
Therefore, for these 270 species, we will
not initiate a further status review in
response to this petition. We ask the
public to submit to us any new
information that becomes available
concerning the status of these 270
species or threats to them or their
habitat at any time. This information
will help us monitor and encourage the
conservation of these species. An
additional 5 species of the 475 included
in the petition do not fall within the
scope of the petition or are not a listable
entity and, therefore, were not
considered in this finding (see Petition).
DATES: The finding announced in this
document was made on January 6, 2009.
You may submit new information
concerning this species for our
consideration at any time.
ADDRESSES: This finding is available on
the Internet at https://
www.regulations.gov. Supporting
information we used in preparing this
finding is available for public
inspection, by appointment, during
normal business hours, at the U.S. Fish
and Wildlife Service, Southwest
Regional Ecological Services Office, 500
Gold Ave., SW., Albuquerque, NM
87102. Please submit any new
information, materials, comments, or
questions concerning these species or
this finding to the above address.
FOR FURTHER INFORMATION CONTACT:
Nancy Gloman, Assistant Regional
Director, Southwest Regional Ecological
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419
Services Office (see ADDRESSES);
telephone 505/248–6920; facsimile 505/
248–6788. If you use a
telecommunications device for the deaf
(TDD), please call the Federal
Information Relay Service (FIRS) at
800–877–8339.
SUPPLEMENTARY INFORMATION:
Background
Section 4(b)(3)(A) of the Act (16
U.S.C. 1531 et seq.) requires that we
make a finding on whether a petition to
list, delist, or reclassify a species
presents substantial scientific or
commercial information to indicate that
a petitioned action may be warranted.
We are to base this finding on
information provided in the petition. To
the maximum extent practicable, we are
to make the finding within 90 days of
our receipt of the petition, and publish
our notice of this finding promptly in
the Federal Register.
Our standard for ‘‘substantial
information,’’ as defined in the Code of
Federal Regulations at 50 CFR 424.14(b),
with regards to a 90-day petition finding
is ‘‘that amount of information that
would lead a reasonable person to
believe that the measure proposed in the
petition may be warranted.’’ If we find
that substantial information was
presented, we are required to promptly
commence a status review of the
species.
In making this finding, we based our
decision on information provided by the
petitioner that we determined to be
reliable after reviewing sources
referenced in the petition and otherwise
available in our files. We evaluated that
information in accordance with 50 CFR
424.14(b). Our process for making this
90-day finding under section 4(b)(3)(A)
of the Act is limited to a determination
of whether the information in the
petition meets the ‘‘substantial
information’’ threshold.
Petition
On June 25, 2007, we received a
formal petition dated June 18, 2007,
from Forest Guardians (now WildEarth
Guardians) requesting that the Service:
(1) Consider all full species in our
Southwest Region ranked as G1 or G1G2
by the organization NatureServe, except
those that are currently listed, proposed
for listing, or candidates for listing; and
(2) list each species as either
endangered or threatened with critical
habitat. The petition incorporates all
analyses, references, and documentation
provided by NatureServe in its online
database at https://www.natureserve.org/
into the petition. The petition clearly
identified itself as a petition and
included the identification information,
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Agencies
[Federal Register Volume 74, Number 3 (Tuesday, January 6, 2009)]
[Proposed Rules]
[Pages 416-419]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E8-31398]
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DEPARTMENT OF TRANSPORTATION
Surface Transportation Board
49 CFR Part 1301
[STB Ex Parte No. 676]
Rail Transportation Contracts Under 49 U.S.C. 10709
AGENCY: Surface Transportation Board.
ACTION: Notice of proposed rule.
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SUMMARY: The Surface Transportation Board (Board or STB) proposes to
amend its rules to provide that where an agreement for rail carriage
contains the disclosure statement to be set forth in this new rule, the
Board will not find jurisdiction over a dispute involving the rate or
service under the agreement and will treat that agreement as a rail
transportation contract governed by 49 U.S.C. 10709; and conversely
where an agreement for rail carriage fails to contain the disclosure
statement, the Board will find jurisdiction over a dispute involving
the rate or service under the agreement, absent clear and convincing
evidence that the parties intended to enter into a rail transportation
contract governed by 49 U.S.C. 10709; and the shipper was made aware
that it could request service under a common carrier tariff rate that
would be subject to STB jurisdiction.
DATES: Comments on this proposal are due by February 5, 2009. Reply
comments are due by March 9, 2009.
ADDRESSES: Comments may be submitted either via the Board's e-filing
format or in the traditional paper format. Any person using e-filing
should attach a document and otherwise comply with the instructions at
the E-FILING link on the Board's Web site, at https://www.stb.dot.gov.
Any person submitting a filing in the traditional paper format should
send an original and 10 copies to: Surface Transportation Board, Attn.:
STB Ex Parte No. 676, 395 E Street, SW., Washington, DC 20423-0001.
Copies of written comments will be available for viewing and self-
copying at the Board's Public Docket Room, Room 131, and will be posted
to the Board's Web site.
FOR FURTHER INFORMATION CONTACT: Timothy Strafford at (202) 245-0356.
(Assistance for the hearing impaired is available through the Federal
Information Relay Service (FIRS) at 1-800-877-8339.)
SUPPLEMENTARY INFORMATION: In a Notice of Proposed Rulemaking in STB Ex
Parte No. 669 served on March 29, 2007 (2007 NPRM) and published in the
Federal Register on April 4, 2007 (72 FR 16316-18), the Board sought to
address two concerns arising from hybrid rail pricing mechanisms such
as the one involved in Kansas City Power & Light Company v. Union
Pacific Railroad Company, STB Docket No. 42095 (STB served Mar. 27,
2007) (KCPL), which, despite having characteristics of a rail
transportation contract beyond the Board's jurisdiction under 49 U.S.C.
10709, are designated by the carrier as common carriage rates subject
to the Board's jurisdiction.
The first concern was uncertainty. Although Congress expressly
removed all matters and disputes arising from rail transportation
contracts from the Board's jurisdiction, 49 U.S.C. 10709(c), the
statute provides no clear demarcation between a contract rate and
common carriage rate. The issue of whether a rate is a contract rate or
common carriage rate has been examined on a case-by-case basis in light
of the parties' intent. See Aggregate Volume Rate on Coal, Acco, UT to
Moapa, NV, 364 I.C.C. 678, 689 (1981). With the enactment of the ICC
Termination Act of 1995 (ICCTA), it became more difficult to
distinguish between the two types of rates, as railroads are no longer
required to file with the agency either tariffs containing their common
carriage rates or summaries of their non-agricultural contracts.
The second concern was that increased use of hybrid pricing
arrangements could create an environment where collusive activities in
the form of anticompetitive price signaling could occur. Although the
terms of a rail transportation contract generally are kept
confidential, the terms and conditions of common carriage rates must be
publicly disclosed upon request, 49 U.S.C. 11101, thereby increasing
the possibility of collusive behavior in a highly concentrated
industry.
In the 2007 NPRM, the Board proposed to address these two concerns
by interpreting the term ``contract'' in 49 U.S.C. 10709 as embracing
``any bilateral agreement between a carrier and a shipper for rail
transportation in which the railroad agrees to a specific rate for a
specific period of time in exchange for consideration from the shipper,
such as a commitment to tender a specific amount of freight during a
specific period or to make specific investments in rail facilities.''
Both shippers and carriers opposed that proposal. After reviewing
their comments, the Board concluded that its original proposal might
have unintended and undesirable
[[Page 417]]
consequences, and it decided to discontinue that proceeding.\1\
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\1\ A complete review of the comments submitted in STB Ex Parte
No. 669 and the Board's reasons for rejecting that approach and
pursuing a different approach by instituting STB Ex Parte No. 676 is
provided in Rail Transportation Contracts Under 49 U.S.C. 10709, STB
Ex Parte No. 676, et al. (STB served Mar. 12, 2008) (ANPR).
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Nevertheless, we remained concerned with the lack of any clear
demarcation between common carriage rates and contract pricing
arrangements and the resulting ambiguity regarding the Board's
jurisdiction. This ambiguity was exhibited in two recent Board
proceedings regarding Option 2 of the Union Pacific Railway Company's
(UP's) Circular 111.\2\ In the first proceeding, the shipper, Kansas
City Power & Light Company, agreed with UP that Circular 111 is a
tariff. See KCPL. In the second proceeding, the shipper, Ameren Energy
and Fuels Services Company, argued that Circular 111 is a contract. See
Union Pacific Railroad Company--Petition for Declaratory Order, STB
Finance Docket No. 35021 (STB served May 15, 2007). The fact that two
sophisticated shippers regarded the same document, with the same
language, in completely opposite ways underscores the need for greater
clarity.
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\2\ UP's Circular 111, ``Unit Train Coal Common Carrier Circular
Applying On: Unit Coal Trains from the Powder River Basin of
Wyoming,'' contains two classes of rates for customers. One class,
referred to as Option 1, contains a higher rate with no volume
requirement. The second class, referred to as Option 2, contains a
lower rate with commitments from both parties for term, volume,
rates, and service.
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Thus, we sought an alternative, less-intrusive way to distinguish
contracts from common carriage agreements.\3\ Specifically, we sought
public comment on whether the Board should require that each carrier
provide a formal written disclosure statement when it seeks to enter
into a rail transportation contract under 49 U.S.C. 10709. That
statement would explicitly advise the shipper that the carrier intends
the document to be a rail transportation contract and that any
transportation under the document would not be subject to regulation by
the Board. The statement would further advise the shipper that it has a
statutory right to request a common carriage rate that the carrier
would then have to supply promptly, and that such a rate might be open
to challenge before the Board. We also sought comment on whether to
include a requirement for a written informed consent statement in which
the shipper acknowledges, and states its willingness to forgo, its
regulatory options.
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\3\ See ANPR supra.
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The Board received comments from Arkansas Electric Cooperative
Corp. (AECC); the Association of American Railroads (AAR); BNSF Railway
Company (BNSF); CSX Transportation, Inc. (CSXT); Edison Electric
Institute (EEI); National Grain and Feed Association (NGFA); the
National Industrial Transportation League (NITL); Norfolk Southern
Railway Company (NS); Occidental Chemical Corp. (OxyChem); Olin Corp.
(Olin); PPG Industries, Inc. (PPG); Progressive Rail, Inc. (PGR); Union
Pacific Railroad Company (UP); United Transportation Union-General
Committee of Adjustment, GO-386 (UTU); the U.S. Clay Producers Traffic
Association, Inc. (Clay Producers); and the Western Coal Traffic League
(WCTL). We have reviewed the record and taken each of these comments
into account in the development of the proposed rule.
Proposed Rule
The somewhat different rule we now propose, which is set forth in
the regulatory text of this document, seeks to provide a more objective
means of determining whether the parties' intent was to use a common
carriage tariff subject to the Board's jurisdiction or to agree to a
rail transportation contract outside the Board's jurisdiction under 49
U.S.C. 10709.\4\ A need for a clear demarcation between tariffs and
contracts has become evident in recent Board proceedings and is
recognized by many within the industry.\5\ By proposing a rule that
would encourage full disclosure to shippers of their regulatory options
at the time of contract formation, the proposed rule should further
Congress' dual intent to offer regulatory protection to shippers that
desire such protection, while encouraging private rail transportation
contracts for those shippers that prefer such arrangements. The rule
proposed here would not require the inclusion of a disclosure
statement; rather, it would simply set forth the criteria that the
Board would apply to determine its jurisdiction based on the presence
or absence of such a statement.
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\4\ This proposed rule would apply only to agreements between
shippers and carriers for rail service. As PGR has pointed out, a
disclosure statement is not needed for contracts between carriers,
such as freight handling, haulage, and switching agreements. Nor
would the proposed rule be intended to apply to separate contracts
for accessorial services such as demurrage and storage, transloading
to and from other modes, incidental warehousing during transloading,
and local drayage.
\5\ See AECC at 2; CSXT at 4; Clay Producers at 1; WCTL at 4.
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The significant change between this proposal and our prior proposal
is the removal of the informed consent requirement. The anticipated
benefits of the informed consent proposal are outweighed by the
potential for unintended consequences that could hamper contracting for
rail carriage. Carriers made a strong case that the informed consent
requirement would unnecessarily complicate the contract process and
delay the timely implementation of contracts, especially when contracts
are negotiated electronically or in the case of signatureless
contracts.\6\ And shippers made a strong case that, by signing an
informed consent statement, they would be unable to argue in court that
a unilateral agreement is a contract of adhesion.\7\ We believe that a
prominently displayed disclosure statement that provides explicit
notice to the shipper of the nature of the agreement would further
Congress' concern that shippers not opt out of our regulatory
protections unknowingly. Nevertheless, the incremental benefit of
imposing an additional informed consent requirement does not appear to
merit the hindrance and delay to modern contract formation that it
might cause.
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\6\ See AAR note 5 at 12; CSXT at 3; NS at 5; UP at 7.
\7\ See Olin at 2.
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Given the Board's lack of jurisdiction over contracts under 49
U.S.C. 10709, some comments suggest that any rule should focus only on
common carriage,\8\ an area clearly within our jurisdiction.\9\ But to
exercise jurisdiction over matters properly before us, we must be able
to distinguish between common carriage and contract pricing
arrangements in situations where the terms and conditions can appear to
be identical.\10\
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\8\ See AAR at 5; BNSF at 4; CSXT at 7; NS at 3; WCTL at 5.
\9\ Although the Board has authority to define how it will
determine what constitutes a tariff, doing so could overlap with the
jurisdiction of the courts. For instance, NITL and others have
argued that we should define common carriage to include unilateral
rate offerings. See NITL at 5. However, there are unilateral
agreements that are recognized by courts as contracts and we have no
authority to question a court's judgment on these matters.
\10\ It is well-settled that the Board has jurisdiction to
determine its jurisdiction. See Burlington N., Inc. v. Chicago &
N.W. Transp. Co., 649 F.2d 556, 558 (8th Cir. 1981); cf. Wms. Gas
Processing-Gulf Coast Co. v. FERC, 475 F.3d 319, 323 (D.C. Cir.
2006) (FERC must draw the line between non-jurisdictional gathering
and jurisdictional transportation of natural gas, a line that is
``not always clear'').
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This proposal should establish a practical way to allow a clear
demarcation between contract and
[[Page 418]]
common carrier rates. With respect to the proposed disclosure statement
provision, set forth in the proposed new Sec. 1301.1 \11\ the
disclosure statement should be placed prominently at the top of the
first page of the agreement, in type size at least as large as the type
used for the body of the agreement.\12\ We are not proposing that
carriers be required to use the disclosure statement but rather that
the inclusion of this statement in an agreement would establish clear
and objective evidence that the parties intended to enter into a
contract under 49 U.S.C. 10709 and that their dispute thus lies outside
the Board's jurisdiction. Absent the inclusion of such a disclosure
statement, we would find that an agreement for rail transportation is a
common carriage tariff and would take jurisdiction over a rate or
service complaint absent clear and convincing evidence both that the
parties intended to enter into a rail transportation contract and that
the shipper was made aware that it could request a common carriage
tariff that would be subject to STB jurisdiction.
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\11\ The disclosure language is based on language suggested by
WCTL. See WCTL at 12.
\12\ Some shipper groups expressed concern that a contract
disclosure provision would be useless, and possibly harmful to
shippers, if the language is not easily discernable on the front of
the document. See Clay Producers at 2-3. We are proposing to specify
the expected location and minimum type size in order to address this
concern.
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This disclosure statement provision should be a workable mechanism
to solve the demarcation problem between contracts and tariffs without
hindering contracting or inappropriately encouraging the use of
tariffs. Use of the disclosure statement by carriers should adequately
allay shipper and carrier concerns in this regard.\13\ Nevertheless, we
remain open to comments not only on the proposed rule itself but also
regarding the language of the disclosure statement to ensure that it
would not inadvertently encourage a common carriage agreement over a
rail transportation contract.
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\13\ See AAR at 10; BNSF at 3; UP at 7; WCTL at 11.
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The disclosure statement provision should promote regulatory
efficiency by establishing a transparent mechanism to determine our
jurisdiction over a rate or service complaint instead of having to
glean the parties' intent based on the unique facts of each case before
us. The parties should benefit by the associated reduction in legal
fees in actions before the Board and in court.
Railroads have suggested using a safe harbor approach, instead of a
disclosure statement, to allow various ways to demonstrate the parties'
intentions.\14\ Shippers suggest alternatively that any ambiguity on
the face of a document should be construed against the carrier as the
drafter of the document.\15\ Neither of these approaches would promote
efficiency, however, as they would require the Board to examine
extraneous evidence beyond the document to determine the parties'
intent in every instance.
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\14\ See AAR at 13; BNSF at 5; NS at 4; WCTL at 7.
\15\ See WCTL at 6.
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Finally, Olin expressed concern that the Board not preempt by rule
state law as to what constitutes a contract, or on whether one can have
an enforceable contract on rates without other agreed-upon terms and
conditions.\16\ We do not intend for inclusion of the disclosure
statement in an agreement to be dispositive in court that a contract
exists, or to preclude shippers from making an argument that the
document is a contract of adhesion or raising any other defense in
state court. The proposed rule is simply intended to be a mechanism for
assisting the Board in determining the Board's jurisdiction to
adjudicate a rate or service complaint involving rail transportation
arrangements.
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\16\ See Olin at 2.
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Ancillary Matters
Two additional concerns have been raised in the shippers' comments
regarding how carriers negotiate contracts for rail service. They
relate to unilateral contracts and bundling.
Unilateral contracts, or signatureless contracts, are contract
offers made by a carrier that a shipper accepts by tendering shipment.
Shippers suggest that this practice should be considered a tariff
subject to Board jurisdiction, as there is no bilateral
negotiation.\17\ But this practice is generally beyond the jurisdiction
of the Board; carriers may offer and shippers may accept these
contracts, as long as state courts recognize them as such. Instead, we
propose to regard unilateral or signatureless agreements that lack the
disclosure language as common carrier tariffs subject to our
jurisdiction, unless there is clear and convincing evidence both that
the parties intended to enter into a rail transportation contract and
that the shipper was made aware that it could request a common carriage
tariff that would be subject to STB jurisdiction.
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\17\ See NITL at 5.
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Bundling occurs when a shipper and carrier negotiate multiple
movements at one time. Shippers claim that carriers often refuse to
provide common carriage rates until contract negotiations are
exhausted, or they withdraw contract offers on all movements if a
tariff rate is requested on any movement.\18\ The purpose of the
proposed rule is to provide clarity regarding when an arrangement is
one for common carriage and thus within the Board's jurisdiction. We
will not complicate this proceeding by addressing negotiating
practices. Carriers have a common carrier obligation to provide service
upon reasonable request. Allegations of violations of that obligation
are best considered by individual complaint.
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\18\ See EEI at 4; Oxychem at 2; Olin at 3.
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Conclusion
This proposal is consistent with the Board's jurisdiction and
regulatory responsibilities. The proposed rule would have no
substantive effect on contracting; the Board is not proposing to
dictate how parties negotiate. Nor would the proposal seek to dictate
to a court of competent jurisdiction how to interpret, apply, or
determine what constitutes a contract. However, as rail transportation
contracts and tariffs can be indistinguishable, all parties should know
what they are agreeing to and what rights may be available to them,
including any right to seek regulatory relief.
The proposed rule, if adopted, would apply prospectively only, and
would not be applicable to existing contracts, existing amendments, or
existing supplements to contracts.\19\ But if the proposed rule is
adopted, all subsequent contracts, amendments and supplements, even
those that attach to contracts signed before the effective date of the
new rule, would need to contain the disclosure statement in order to be
conclusively presumed to be a contract under 49 U.S.C. 10907 and thus
outside of the Board's jurisdiction.
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\19\ We agree with public comments to the ANPR suggesting that
any rule should only apply prospectively. See AAR at 14.
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Pursuant to 5 U.S.C. 605(b), the Board certifies that the proposed
action would not have a significant economic effect on a substantial
number of small entities within the meaning of the Regulatory
Flexibility Act.
This action will not significantly affect either the quality of the
human environment or the conservation of energy resources.
List of Subjects
49 CFR Part 1301
Administrative practice and procedure, and Railroads.
Authority: 49 U.S.C. 721(a) and 10709.
[[Page 419]]
Decided: December 30, 2008.
By the Board, Chairman Nottingham, Vice Chairman Mulvey, and
Commissioner Buttrey.
Jeffrey Herzig,
Clearance Clerk.
For the reasons set forth in the preamble, the Surface
Transportation Board proposes to add part 1301 of title 49, chapter X,
of the Code of Federal Regulations as follows:
PART 1301--RAIL TRANSPORTATION CONTRACTS
Authority: 49 U.S.C. 721(a) and 10709.
Sec. 1301.1 Contract Disclosure Statement.
(a) The Board will not find jurisdiction over a dispute involving
the rate or service under a rail transportation agreement where that
agreement contains a disclosure statement that conforms with paragraphs
(b) and (c) of this section. Conversely, where a rail transportation
agreement fails to contain such a disclosure statement, the Board will
find jurisdiction over a dispute involving the rate or service provided
under that agreement, absent clear and convincing evidence both that
the parties intended to enter into a rail transportation contract
governed by 49 U.S.C. 10709 and that the shipper was made aware that it
could request service under a common carrier tariff rate that would be
subject to STB jurisdiction.
(b) The disclosure statement should appear at the top of the first
page of the rail transportation agreement in type size at least as
large as the type size used for the body of the agreement.
(c) The disclosure statement should read as follows:
Disclosure Statement--This agreement constitutes a rail
transportation contract under 49 U.S.C. 10709. Contract arrangements
are generally not subject to challenge before the Surface
Transportation Board (``STB''), but can be enforced in a court of
competent jurisdiction. Under federal rules found at 49 CFR 1300,
railroads are required, upon request, to quote to shippers a rate for
common carriage transportation (i.e., a non-contract rate). Pursuant to
49 U.S.C. 10701, the STB has jurisdiction (subject to some exceptions)
over disputes arising out of common carriage (non-contract) rates.
[FR Doc. E8-31398 Filed 1-5-09; 8:45 am]
BILLING CODE 4915-01-P