RFM Holdco LLC-Control Exemption-Pioneer Railcorp, et al.; The Baupost Group, L.L.C. and US Infravest Managers LP-Control Exemption-Pioneer Railcorp, et al., 15765-15768 [2021-06066]
Download as PDF
Federal Register / Vol. 86, No. 55 / Wednesday, March 24, 2021 / Notices
rule change (File No. SR–NYSEArca–
2021–09).
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.6
Eduardo A. Aleman,
Deputy Secretary.
[FR Doc. 2021–05996 Filed 3–23–21; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–91362; File No. SR–
NYSECHX–2021–01]
Self-Regulatory Organizations; NYSE
Chicago, Inc.; Notice of Designation of
a Longer Period for Commission
Action on a Proposed Rule Change To
Amend the Exchange’s Co-Location
Services and Fee Schedule To Add
Two Partial Cabinet Solution Bundles
khammond on DSKJM1Z7X2PROD with NOTICES
March 18, 2021.
On January 19, 2021, NYSE Chicago,
Inc. (‘‘NYSE Chicago’’ or ‘‘Exchange’’)
filed with the Securities and Exchange
Commission (‘‘Commission’’), pursuant
to Section 19(b)(1) of the Securities
Exchange Act of 1934 (‘‘Act’’) 1 and Rule
19b–4 thereunder,2 a proposed rule
change to amend the Exchange’s colocation rules to add two partial cabinet
solution bundles. The proposed rule
change was published for comment in
the Federal Register on February 5,
2021.3 The Commission received no
comments on the proposed rule change.
Section 19(b)(2) of the Act 4 provides
that within 45 days of the publication of
notice of the filing of a proposed rule
change, or within such longer period up
to 90 days as the Commission may
designate if it finds such longer period
to be appropriate and publishes its
reasons for so finding, or as to which the
self-regulatory organization consents,
the Commission shall either approve the
proposed rule change, disapprove the
proposed rule change, or institute
proceedings to determine whether the
proposed rule change should be
disapproved. The 45th day after
publication of the notice for this
proposed rule change is March 22, 2021.
The Commission is extending this 45day time period.
The Commission finds it appropriate
to designate a longer period within
which to take action on the proposed
6 17
CFR 200.30–3(a)(31).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
3 See Securities Exchange Act Release No. 91036
(February 1, 2021), 86 FR 8440 (SR–NYSECHX–
2021–01).
4 15 U.S.C. 78s(b)(2).
rule change so that it has sufficient time
to consider the proposed rule change
and the comments received.
Accordingly, the Commission, pursuant
to Section 19(b)(2) of the Act,5
designates May 6, 2021, as the date by
which the Commission shall either
approve or disapprove, or institute
proceedings to determine whether to
disapprove, the proposed rule change
(File No. SR–NYSECHX–2021–01).
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.6
Eduardo A. Aleman,
Deputy Secretary.
[FR Doc. 2021–06019 Filed 3–23–21; 8:45 am]
BILLING CODE 8011–01–P
SURFACE TRANSPORTATION BOARD
[Docket No. EP 290 (Sub-No. 5) (2021–2)]
Quarterly Rail Cost Adjustment Factor
AGENCY:
ACTION:
Surface Transportation Board.
Approval of rail cost adjustment
factor.
The Board approves the
second quarter 2021 Rail Cost
Adjustment Factor (RCAF) and cost
index filed by the Association of
American Railroads. The second quarter
2021 RCAF (Unadjusted) is 1.059. The
second quarter 2021 RCAF (Adjusted) is
0.441. The second quarter 2021 RCAF–
5 is 0.417.
SUMMARY:
DATES:
Applicability Date: April 1, 2021.
FOR FURTHER INFORMATION CONTACT:
Pedro Ramirez at (202) 245–0333.
Assistance for the hearing impaired is
available through the Federal Relay
Service at (800) 877–8339.
SUPPLEMENTARY INFORMATION:
Additional information is contained in
the Board’s decision, which is available
at www.stb.gov.
Decided: March 18, 2021.
By the Board, Board Members Begeman,
Fuchs, Oberman, Primus, and Schultz.
Kenyatta Clay,
Clearance Clerk.
[FR Doc. 2021–06042 Filed 3–23–21; 8:45 am]
BILLING CODE 4915–01–P
1 15
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6 17
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15765
SURFACE TRANSPORTATION BOARD
[Docket No. FD 36306 (Sub-No. 1); Docket
No. FD 36451]
RFM Holdco LLC—Control
Exemption—Pioneer Railcorp, et al.;
The Baupost Group, L.L.C. and US
Infravest Managers LP—Control
Exemption—Pioneer Railcorp, et al.
The Board has received two verified
notices of exemption seeking authority
to acquire control of Pioneer Railcorp
(Pioneer), a noncarrier holding
company, and the 15 Class III railroads
controlled by Pioneer (the Pioneer
Railroads).1 In Docket No. FD 36306
(Sub-No. 1), RFM HoldCo LLC (RFM)
seeks an after-the-fact exemption for its
unauthorized 2019 acquisition of
control of Pioneer and the Pioneer
Railroads. (RFM Verified Notice 1, FD
36306 (Sub-No. 1) et al.) In Docket No.
FD 36451, The Baupost Group, L.L.C.
(Baupost), and US Infravest Managers
LP (Infravest Managers) seek authority
to acquire indirect control of Pioneer
and the Pioneer Railroads from a
subsidiary of RFM, Related
Infrastructure Holdings LLC (Related
Infrastructure Holdings). (Baupost
Verified Notice 1 & Ex. 3, FD 36451.)
Both notices were held in abeyance
pending further order of the Board. See
Baupost Grp., L.L.C.—Control
Exemption—Pioneer Railcorp, FD 36451
et al. (STB served Nov. 25, 2020); RFM
HoldCo LLC—Control Exemption—
Pioneer Railcorp, FD 36306 (Sub-No. 1)
et al. (STB served Dec. 28, 2020).
The Board finds that these
transactions are not appropriate for the
expedited class exemption process.
However, after reviewing the
supplemental information submitted in
this docket, the Board will grant, on its
own motion, the appropriate
exemptions to authorize the
transactions.
Background
In June 2019, Brookhaven Rail
Partners, LLC (Brookhaven), Related
Infrastructure, LLC (Related
Infrastructure), BRX Transportation
Holdings, LLC (BRX Transportation),
and BRX Acquisition Sub, Inc. (BRX
Acquisition), obtained an exemption to
1 They are: Alabama & Florida Railway Co., Inc.;
Alabama Railroad Co., Inc.; Decatur Junction
Railway Co.; Elkhart & Western Railroad Co.; Fort
Smith Railroad Co.; The Garden City Western
Railway, Inc.; Georgia Southern Railway Co.;
Gettysburg & Northern Railroad Co.; Indiana
Southwestern Railway Co.; Kendallville Terminal
Railway Co.; Keokuk Junction Railway Co.;
Michigan Southern Railroad Company; Mississippi
Central Railroad Co.; Pioneer Industrial Railway
Co.; and Vandalia Railroad Company. (See Baupost
Verified Notice 1–3, FD 36451.)
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acquire control of Pioneer and the
Pioneer Railroads. See Brookhaven Rail
Partners, LLC—Control Exemption—
Pioneer Railcorp, FD 36306, slip op. at
1 (STB served June 21, 2019) (84 FR
29,276).
On October 22, 2020, in Docket No.
FD 36451, Baupost and Infravest
Managers filed a verified notice of
exemption under 49 CFR 1180.2(d)(2) to
acquire indirect control of Pioneer and
the Pioneer Railroads by acquiring a
majority equity interest in BRX
Transportation. (See Baupost Verified
Notice 1–4, FD 36451.) Baupost and
Infravest Managers identified the
current owner of the majority equity
interest in BRX Transportation as ‘‘an
affiliate of Related Infrastructure.’’ (Id.
at 3–4.) In a supplement filed on
November 2, 2020, Baupost and
Infravest Managers 2 stated that,
following the 2019 filing of the verified
notice of exemption in Docket No. FD
36306 but before the filing of the
verified notice in Docket No. FD 36451,
two additional transactions had taken
place. First, Related Infrastructure
Acquisitions LLC (Related Acquisitions)
transferred its interest in BRX
Transportation to Related Infrastructure
BRX Holdings LLC (Related BRX
Holdings).3 (Baupost Suppl. 2, Nov. 2,
2020, FD 36451.) Second, Related
Infrastructure transferred its interest in
Related BRX Holdings to Related
Infrastructure Holdings LLC (Related
Infrastructure Holdings), which now
‘‘directly owns and controls Related
BRX Holdings.’’ (Id.) The supplement
further stated that Related Infrastructure
and Related Infrastructure Holdings are
subsidiaries of Related Fund
Management, (id.), and the verified
notice in Docket No. FD 36306
identified Related Fund Management as
a subsidiary of Related Companies, L.P.
(Related Companies), (Brookhaven
Verified Notice 2 n.2, June 7, 2019,
Brookhaven Rail Partners, LLC—Control
Exemption—Pioneer Railcorp, et al., FD
36306).
In a decision served November 25,
2020, the Board postponed the effective
date of the exemption sought by
2 The supplement was filed by Baupost and US
Infravest Managers LP, but facts regarding Related
Infrastructure and its affiliates were verified by
Richard O’Toole, Vice President of Related Fund
Management, LLC (Related Fund Management).
(See Baupost Suppl. 5, Nov. 2, 2020, FD 36451.)
3 Baupost and Infravest Managers stated that,
when the verified notice was filed in Docket No. FD
36306, Related Acquisitions held the majority
ownership interest in BRX Transportation, and
‘‘Related Infrastructure—the entity authorized to
control Pioneer and the Pioneer Railroads through
that proceeding—directly owned and controlled
Related Acquisitions.’’ (Baupost Suppl. 2, Nov. 2,
2020, FD 36451.)
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Baupost and Infravest Managers in
Docket No. FD 36451, held that
proceeding in abeyance, and directed
Related Infrastructure Holdings, Related
Fund Management, and Related
Companies (and any other entity or
individual that controls Related
Companies, as appropriate) to explain
why Board authority was not required
for the two transactions that occurred in
2019, or, if they believe such authority
was needed, to seek after-the-fact
authority under 49 U.S.C. 11323 to
control Pioneer and the Pioneer
Railroads. See Baupost Grp., L.L.C.—
Control Exemption—Pioneer Railcorp,
FD 36451 et al., slip op. at 3 (STB served
Nov. 25, 2020).
On December 2, 2020, RFM filed its
verified notice of exemption, identifying
itself as ‘‘the highest person currently in
the corporate chain of control,’’ (RFM
Verified Notice 2, FD 36306 (Sub-No. 1)
et al.), and elaborating on the
transactions described in Baupost and
Infravest Managers’ November 2, 2020
supplement. As stated by RFM, when
the notice of exemption in Docket No.
FD 36306 was filed on June 7, 2019,
‘‘Related Companies controlled Related
Fund Management, which controlled
Related Infrastructure, which controlled
Related Acquisitions, which controlled
BRX Transportation.’’ (Id.) Therefore,
according to RFM, ‘‘Related Companies,
as the ultimate controlling party, should
have sought control authority . . . in FD
36306.’’ (Id. at 3.)
RFM stated, however, that it is the
proper party to file the verified notice of
exemption because of the second
transaction that occurred in 2019—the
transfer of the ownership interest in
Related BRX Holdings from Related
Infrastructure to Related Infrastructure
Holdings—which RFM claims was part
of a ‘‘broader intracompany
reorganization.’’ (Id. at 3–4.) RFM states
that, in the reorganization, Related
Companies formed RFM; RFM formed a
subsidiary, Related Infrastructure
Holdings Investor LLC (Related
Infrastructure Investor); Related
Infrastructure Investor formed a
subsidiary, Related Infrastructure
Holdings; and Related Infrastructure’s
interest in Related BRX Holdings was
transferred to Related Infrastructure
Holdings. (Id. at 4.) As a result, RFM
replaced Related Companies as ‘‘the
ultimate controlling party.’’ (Id. at 3–4.)
According to RFM, it is ‘‘owned by
equity holders of Related Companies,’’
and Related Companies and Related
Fund Management no longer have any
ownership interest in entities
controlling BRX Transportation,
Pioneer, or RFM. (Id. (footnote
omitted).) RFM also noted that none of
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Sfmt 4703
its equity owners have control of
Related Companies or RFM. (Id. at 4
n.4.)
On December 3, 2020, Baupost and
Infravest Managers filed a letter, which
included the agreement through which
Baupost and Infravest Managers are
acquiring Pioneer and the Pioneer
Railroads, stating that the parties
‘‘expect to consummate the transaction
shortly after the Board allows the
exemption in this proceeding to take
effect.’’ (Baupost Letter 1, Dec. 3, 2020,
FD 36451.) Baupost and Infravest
Managers also requested that the Board
remove Docket No. FD 36451 from
abeyance and allow the exemption to
take effect promptly or, at the latest, no
later than the day that the Board
‘‘resolves the issues regarding current
control of Pioneer.’’ (Id.)
In a decision served December 28,
2020, the Board held RFM’s notice of
exemption in abeyance and directed
RFM to provide additional information.
See RFM HoldCo LLC, FD 36306 (SubNo. 1) et al., slip op. at 5. The Board
found that, although RFM implied that
it acquired control of Pioneer and the
Pioneer Railroads when Related
Infrastructure transferred its interest in
Related BRX Holdings to Related
Infrastructure Holdings, the
organizational chart provided by RFM
depicted both Related Infrastructure and
Related Infrastructure Holdings as being
under RFM’s control. Id. at 4.
Additionally, the Board noted that
neither of the agreements provided by
RFM appeared to be relevant to the
transaction in which it acquired control
of Pioneer and the Pioneer Railroads. Id.
On January 6, 2021, RFM filed a
supplement to its notice clarifying when
it acquired control of Pioneer and the
Pioneer Railroads. According to RFM,
‘‘[o]n December 13, 2019, the ownership
interests in Related Fund Management
were distributed to the owners of
Related Companies and on the same
date, immediately following that
distribution, were contributed by those
owners to RFM in exchange for equity
interests in RFM.’’ (RFM Suppl. 2, FD
36306 (Sub-No. 1) et al.) On February
17, 2021, Baupost and Infravest
Managers submitted a letter in Docket
No. FD 36451 requesting that the
proceeding be removed from abeyance
and the exemption granted with an
effective date in advance of the ‘‘End
Date’’ in the parties’ purchase
agreement.
Discussion and Conclusions
Under 49 U.S.C. 11323(a)(4), the
‘‘[a]cquisition of control of at least 2 rail
carriers by a person that is not a rail
carrier’’ requires Board authorization.
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The verified notices of exemption at
issue in these proceedings were
submitted under the class exemption
procedures found at 49 CFR
1180.2(d)(2), which provide an
expedited process for obtaining control
authority under 11323. These
streamlined class exemption procedures
are reserved for transactions involving
routine, uncomplicated, and noncontroversial matters, and which do not
raise substantial factual and legal issues.
See S. San Luis Valley R.R.—Acquis. &
Operation Exemption—Iowa Pac.
Holdings, LLC, FD 35586 et al., slip op.
at 2 (STB served Feb. 10, 2012)
(rejecting notice of exemption raising
substantial questions about prior
acquisitions); V & S Ry.—Aban.
Exemption—in Kiowa Cnty., Colo., AB
603 (Sub-No. 3X), slip op. at 2 (STB
served June 17, 2014).
The Verified Notices of Exemption.
The verified notice filed by RFM and
the verified notice filed by Baupost and
Infravest Managers will be rejected
because both matters are sufficiently
complicated and non-routine to make
them inappropriate for consideration
under the streamlined class exemption
procedures of 49 CFR 1180.4(g). Both
proceedings involve the unauthorized
acquisitions of control of Pioneer and
the Pioneer Railroads by Related
Companies and entities within RFM’s
corporate family. RFM acquired control
of Pioneer and the Pioneer Railroads,
without Board authorization, from
Related Companies, which itself also
did not have Board authorization to
control Pioneer and the Pioneer
Railroads. (See RFM Verified Notice 3,
FD 36306 (Sub-No. 1) et al.) Baupost
and Infravest Managers are seeking to
acquire control of Pioneer and the
Pioneer Railroads from Related
Infrastructure Holdings, a subsidiary of
RFM, which does not currently have
authority to control Pioneer and the
Pioneer Railroads. Although RFM has
sought after-the-fact control authority,
Related Companies has not. RFM has
argued both that Related Companies
need not seek after-the-fact control
authority, and that the Board should
grant that authority to Related
Companies through the Board’s
streamlined class exemption procedures
even though Related Companies did not
itself request it.4 (RFM Verified Notice
5 n.6, FD 36306 (Sub-No. 1) et al.) The
facts cited during these proceedings, as
described in detail above, demonstrate
4 RFM was formed by equity owners of Related
Companies, but RFM and Related Companies are
not under common control because the equity
owners do not have control of either Related
Companies or RFM. (RFM Verified Notice 3–4 &
n.4, FD 36306 (Sub-No. 1) et al.)
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that these matters are not routine and
require scrutiny by the Board outside of
the streamlined class exemption
procedures. See S. San Luis Valley R.R.,
FD 35586 et al., slip op. at 2–3.
Therefore, the verified notices in Docket
Nos. FD 36451 and FD 36306 (Sub-No.
1) will be rejected.
The Board also notes that the
information provided during the course
of these proceedings has at times been
incomplete or inaccurate.5 For example,
Baupost and Infravest Managers, in their
notice, identified the entity from which
they were acquiring control of Pioneer
and the Pioneer Railroads as ‘‘an
affiliate of’’ Related Infrastructure,
without further detail. (See Baupost
Verified Notice 3, FD 36451.) Later, the
November 2, 2020 supplement filed in
Docket No. FD 36451 provided incorrect
information that identified Related
Infrastructure Holdings as a
‘‘subsidiar[y] of Related Fund
Management LLC,’’ notwithstanding
that the facts in the supplement
‘‘regarding Related Infrastructure LLC
and its affiliates’’ were verified by an
official at Related Fund Management.
(See Baupost Suppl. 1–2, FD 36451,
Nov. 2, 2020, FD 36451.) Only after the
Board postponed the effective date of
the exemption in Docket No. FD 36451
and requested that Related Companies
seek acquisition authority did the Board
learn that Related Companies had
transferred control of Pioneer and the
Pioneer Railroads to RFM. RFM, for its
part, filed a verified notice that failed to
identify the date on which RFM
acquired control of Pioneer and the
Pioneer Railroads, which was later
cured through its January 6 supplement.
While the record does not indicate bad
faith by these parties, inaccuracies and
omissions such as these raise questions
that often cannot be adequately
addressed under the streamlined class
exemption procedures. It is important
for parties to ensure that their filings in
exemption (and other) proceedings are
accurate and complete. Nevertheless, as
discussed below, the Board has now
received from the parties adequate
information for the Board to assess, sua
sponte and pursuant to the exemption
standard set forth at 49 U.S.C. 10502(a),
the appropriateness of granting
exemptions in these proceedings.6
5 Given the Board’s finding that the class
exemption procedures are inappropriate in light of
the facts and circumstances, it need not address
whether the notices were also false or misleading.
See, e.g., 49 CFR 1180.4(g)(1)(ii).
6 In granting acquisition authority sua sponte, the
Board would effectively proceed as though the
parties had formally petitioned for exemption. The
Board will consider below the value of requiring
such petitions at this stage of the proceedings and
the harm that could arise from the ensuing delay.
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15767
The Sua Sponte Exemptions. As
noted, the Board has now received
multiple filings in these proceedings
providing information about the
transactions involving Related
Companies and RFM that occurred
without Board authority. Although there
does not appear to be bad faith, this
does not excuse the failures to obtain
Board authorization; and while RFM has
now sought to cure the defect, the Board
remains troubled that the parties did not
adequately consider the required
authorizations at the appropriate time.
When it rejects verified notices in
non-routine or controversial cases, the
Board often requires parties to seek the
necessary authority by petition for
exemption or application. Here,
however, an extensive record has
already been developed through the
supplemental pleadings. Additionally,
the Board is mindful of the fact that the
proposed acquisition by Baupost and
Infravest Managers to acquire Pioneer
and the Pioneer Railroads is also
pending before the Board. That
transaction, but for the failures of the
selling entity (RFM and its subsidiaries)
discussed above, would have met the
standards for the expedited class
exemption process. To require RFM to
file a petition for exemption or
application to remedy the prior
unauthorized transactions would further
delay, and possibly frustrate, Baupost
and Infravest Managers’ proposed
transaction. (Baupost Letter 1, Feb. 17,
2020, FD 36451.) No party has sought to
oppose Baupost and Infravest Managers’
proposed acquisition of control of the
Pioneer Railroads, and one of the stated
goals of that transaction is to ‘‘improve
Pioneer’s efficiency, financial strength,
and ability to meet the needs of
shippers.’’ (Baupost Verified Notice 5,
FD 36451.) Baupost argues that further
delaying its acquisition would, among
other things, ‘‘affect the ability of
Pioneer and the Pioneer Railroads to
accelerate capital expenditures.’’
(Baupost & Infravest Managers Letter 2,
Dec. 3, 2020, FD 36451.)
For the reasons discussed above and
based on the particular facts of this case,
the Board concludes that it is
appropriate to consider granting the
exemptions sua sponte pursuant to
10502. See, e.g., BNSF Ry.—Pet. for
Declaratory Order, FD 35164 et al., slip
op. at 10 (STB served May 20, 2009);
Borealis Infrastructure Trust
Management—Acquis. Exemption—
Detroit River Tunnel Co., FD 33984 et
al., slip op. at 6 (STB served Dec. 19,
2001). The Board will consider here the
merits of the exemptions requested in
these dockets and, as discussed further
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below, will grant the exemptions sua
sponte.
As RFM, Baupost, and Infravest
Managers are each noncarriers, their
acquisitions of control of the Pioneer
Railroads require prior Board approval
under 49 U.S.C. 11323(a)(4). Because
the acquisitions of control do not
involve the merger or control of at least
two Class I railroads, approval of the
transactions is governed by 49 U.S.C.
11324(d). However, under 49 U.S.C.
10502(a), the Board must exempt a
transaction or service from regulation
upon finding that: (1) Regulation is not
necessary to carry out the rail
transportation policy (RTP) of 49 U.S.C.
10101; and (2) either (a) the transaction
or service is of limited scope, or (b)
regulation is not needed to protect
shippers from the abuse of market
power.
Here, exemptions from the prior
approval requirements of sections
11323–25 are consistent with 10502(a).
Detailed scrutiny of the acquisitions of
control of the Pioneer Railroads in each
docket is not necessary to carry out the
RTP. An exemption from the
application process would promote a
fair and expeditious regulatory decisionmaking process, minimize the need for
Federal regulatory control, reduce
regulatory barriers to entry, and result in
more expeditious handling of this
proceeding. See 49 U.S.C. 10101(2), (7),
(15). Other aspects of the RTP would not
be adversely affected.
Regulation of these transactions is not
needed to protect shippers from the
abuse of market power. RFM states that
it ‘‘does not own or control any other
carriers other than the Pioneer
Railroads, nor did it, or its equity
owners, at the time of its formation.’’
(RFM Verified Notice 4 n.5, FD 36306
(Sub-No. 1) et al.) Accordingly, RFM’s
2019 acquisition of control of Pioneer
and the Pioneer Railroads did not create
any adverse change in competition
among rail carriers or between rail
carriers and other modes. For their part,
Baupost and Infravest Managers also
state that they ‘‘are not themselves rail
carriers and do not currently control any
rail carriers,’’ (Baupost Verified Notice
4, FD 36451), so their proposed
acquisition of Pioneer and the Pioneer
Railroads similarly would not adversely
affect the competitive landscape so as to
require regulation to protect shippers
from an abuse of market power.7
7 Because this decision finds that regulation is not
necessary to protect shippers from the abuse of
market power, the Board need not determine
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Under 49 U.S.C. 10502(g), the Board
may not use its exemption authority to
relieve a rail carrier of its statutory
obligation to protect the interests of its
employees. Section 11326(c), however,
precludes the Board from imposing
labor protections for transactions
involving only Class III rail carriers.
Because all the Pioneer Railroads are
Class III carriers, the Board may not
impose labor protections here.
In light of Baupost’s and Infravest
Managers’ request regarding the
effective date, the exemptions will be
effective on March 26, 2021. Petitions to
stay will be due by March 24, 2021.
The transactions are categorically
excluded from environmental review
under 49 CFR 1105.6(c)(1) and from the
historic reporting requirements under
49 CFR 1105.8(b).
It is ordered:
1. The verified notices of exemption
in Docket Nos. FD 36306 (Sub-No. 1)
and FD 36451 are rejected.
2. In Docket No. FD 36306 (Sub-No.
1), under 49 U.S.C. 10502, the Board
exempts from the prior approval
requirements of 49 U.S.C. 11323–25
RFM’s 2019 acquisition of control of the
Pioneer Railroads.
3. In Docket No. FD 36451, under 49
U.S.C. 10502, the Board exempts from
the prior approval requirements of 49
U.S.C. 11323–25 Baupost’s and Infravest
Managers’ acquisition of control of the
Pioneer Railroads from RFM.
4. Notice of the exemptions will be
published in the Federal Register.
5. The exemptions will be effective on
March 26, 2021. Petitions to stay will be
due by March 24, 2021.
Decided: March 18, 2021.
By the Board, Board Members
Begeman, Fuchs, Oberman, Primus, and
Schultz. Board Member Primus
dissented with a separate expression.
Board Member Primus, dissenting:
This case is extremely troubling and
lays bare gaps in compliance that I am
not willing to excuse. The focus of my
displeasure is not directed toward
Baupost and Infravest Managers, but
rather Related Companies and RFM.
When the history of Related Companies
and RFM is taken into account,
specifically their inability to provide
accurate and complete information to
the Board with respect to ownership,
what we have before us is at best a
comedy of errors and at worst a blatant
disregard for the Board’s role as the
economic regulator of the rail industry.
whether the transaction is limited in scope. See 49
U.S.C. 10502(a)(2).
PO 00000
Frm 00129
Fmt 4703
Sfmt 4703
The Board was faced with two notices
of exemption involving a chain of
unauthorized transactions. Details
surrounding the history of the
ownership of Pioneer and the Pioneer
Railroads is murky and unnecessarily
complicated. Upon further review, it
was revealed that Related Companies
never obtained Board authorization to
acquire Pioneer and the Pioneer
Railroads. Similarly, RFM skirted Board
authority when it acquired the railroad
entities from Related Companies. Only
now, when Baupost and Infravest
Managers have come before the Board to
acquire control of these railroad entities,
has RFM decided to step into the light.
Failure to obtain the required Board
authority lies squarely with RFM. Both
RFM and its subsidiaries (and Related
Companies before it) did not bother to
adhere to 49 U.S.C. 11323, which
clearly requires an entity seeking to
purchase/acquire a railroad to obtain
Board authority. Given the fact that the
proposed acquisition involves
unauthorized transactions, it was
incumbent upon the parties to be
forthcoming with accurate and complete
information about the ownership and
relationship of the numerous railroads
involved in the proposed transaction.
This clearly did not happen.
Accordingly, I do not believe that the
selling entity should be permitted to
benefit or profit from such a transaction
without first curing its unauthorized
acquisition. While RFM has asked for
after-the-fact authority, it has done so
through the Board’s streamlined class
exemption procedures, which are
reserved for transactions involving
routine, uncomplicated, and noncontroversial matters, and not
appropriate here. Moreover, Related
Companies has not sought after-the-fact
authority for its unauthorized
acquisition.
My hope is that, moving forward, the
Board will begin to look at ways to
effectively promote greater compliance
and transparency as it relates to the
licensing of rail activities. For those
who continue to operate outside the
rules, stronger enforcement, including
the administering of severe penalties
when appropriate, should prevail.
For these reasons, I respectfully
dissent.
Aretha Laws-Byrum,
Clearance Clerk.
[FR Doc. 2021–06066 Filed 3–23–21; 8:45 am]
BILLING CODE 4915–01–P
E:\FR\FM\24MRN1.SGM
24MRN1
Agencies
[Federal Register Volume 86, Number 55 (Wednesday, March 24, 2021)]
[Notices]
[Pages 15765-15768]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2021-06066]
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SURFACE TRANSPORTATION BOARD
[Docket No. FD 36306 (Sub-No. 1); Docket No. FD 36451]
RFM Holdco LLC--Control Exemption--Pioneer Railcorp, et al.; The
Baupost Group, L.L.C. and US Infravest Managers LP--Control Exemption--
Pioneer Railcorp, et al.
The Board has received two verified notices of exemption seeking
authority to acquire control of Pioneer Railcorp (Pioneer), a
noncarrier holding company, and the 15 Class III railroads controlled
by Pioneer (the Pioneer Railroads).\1\ In Docket No. FD 36306 (Sub-No.
1), RFM HoldCo LLC (RFM) seeks an after-the-fact exemption for its
unauthorized 2019 acquisition of control of Pioneer and the Pioneer
Railroads. (RFM Verified Notice 1, FD 36306 (Sub-No. 1) et al.) In
Docket No. FD 36451, The Baupost Group, L.L.C. (Baupost), and US
Infravest Managers LP (Infravest Managers) seek authority to acquire
indirect control of Pioneer and the Pioneer Railroads from a subsidiary
of RFM, Related Infrastructure Holdings LLC (Related Infrastructure
Holdings). (Baupost Verified Notice 1 & Ex. 3, FD 36451.) Both notices
were held in abeyance pending further order of the Board. See Baupost
Grp., L.L.C.--Control Exemption--Pioneer Railcorp, FD 36451 et al. (STB
served Nov. 25, 2020); RFM HoldCo LLC--Control Exemption--Pioneer
Railcorp, FD 36306 (Sub-No. 1) et al. (STB served Dec. 28, 2020).
---------------------------------------------------------------------------
\1\ They are: Alabama & Florida Railway Co., Inc.; Alabama
Railroad Co., Inc.; Decatur Junction Railway Co.; Elkhart & Western
Railroad Co.; Fort Smith Railroad Co.; The Garden City Western
Railway, Inc.; Georgia Southern Railway Co.; Gettysburg & Northern
Railroad Co.; Indiana Southwestern Railway Co.; Kendallville
Terminal Railway Co.; Keokuk Junction Railway Co.; Michigan Southern
Railroad Company; Mississippi Central Railroad Co.; Pioneer
Industrial Railway Co.; and Vandalia Railroad Company. (See Baupost
Verified Notice 1-3, FD 36451.)
---------------------------------------------------------------------------
The Board finds that these transactions are not appropriate for the
expedited class exemption process. However, after reviewing the
supplemental information submitted in this docket, the Board will
grant, on its own motion, the appropriate exemptions to authorize the
transactions.
Background
In June 2019, Brookhaven Rail Partners, LLC (Brookhaven), Related
Infrastructure, LLC (Related Infrastructure), BRX Transportation
Holdings, LLC (BRX Transportation), and BRX Acquisition Sub, Inc. (BRX
Acquisition), obtained an exemption to
[[Page 15766]]
acquire control of Pioneer and the Pioneer Railroads. See Brookhaven
Rail Partners, LLC--Control Exemption--Pioneer Railcorp, FD 36306, slip
op. at 1 (STB served June 21, 2019) (84 FR 29,276).
On October 22, 2020, in Docket No. FD 36451, Baupost and Infravest
Managers filed a verified notice of exemption under 49 CFR 1180.2(d)(2)
to acquire indirect control of Pioneer and the Pioneer Railroads by
acquiring a majority equity interest in BRX Transportation. (See
Baupost Verified Notice 1-4, FD 36451.) Baupost and Infravest Managers
identified the current owner of the majority equity interest in BRX
Transportation as ``an affiliate of Related Infrastructure.'' (Id. at
3-4.) In a supplement filed on November 2, 2020, Baupost and Infravest
Managers \2\ stated that, following the 2019 filing of the verified
notice of exemption in Docket No. FD 36306 but before the filing of the
verified notice in Docket No. FD 36451, two additional transactions had
taken place. First, Related Infrastructure Acquisitions LLC (Related
Acquisitions) transferred its interest in BRX Transportation to Related
Infrastructure BRX Holdings LLC (Related BRX Holdings).\3\ (Baupost
Suppl. 2, Nov. 2, 2020, FD 36451.) Second, Related Infrastructure
transferred its interest in Related BRX Holdings to Related
Infrastructure Holdings LLC (Related Infrastructure Holdings), which
now ``directly owns and controls Related BRX Holdings.'' (Id.) The
supplement further stated that Related Infrastructure and Related
Infrastructure Holdings are subsidiaries of Related Fund Management,
(id.), and the verified notice in Docket No. FD 36306 identified
Related Fund Management as a subsidiary of Related Companies, L.P.
(Related Companies), (Brookhaven Verified Notice 2 n.2, June 7, 2019,
Brookhaven Rail Partners, LLC--Control Exemption--Pioneer Railcorp, et
al., FD 36306).
---------------------------------------------------------------------------
\2\ The supplement was filed by Baupost and US Infravest
Managers LP, but facts regarding Related Infrastructure and its
affiliates were verified by Richard O'Toole, Vice President of
Related Fund Management, LLC (Related Fund Management). (See Baupost
Suppl. 5, Nov. 2, 2020, FD 36451.)
\3\ Baupost and Infravest Managers stated that, when the
verified notice was filed in Docket No. FD 36306, Related
Acquisitions held the majority ownership interest in BRX
Transportation, and ``Related Infrastructure--the entity authorized
to control Pioneer and the Pioneer Railroads through that
proceeding--directly owned and controlled Related Acquisitions.''
(Baupost Suppl. 2, Nov. 2, 2020, FD 36451.)
---------------------------------------------------------------------------
In a decision served November 25, 2020, the Board postponed the
effective date of the exemption sought by Baupost and Infravest
Managers in Docket No. FD 36451, held that proceeding in abeyance, and
directed Related Infrastructure Holdings, Related Fund Management, and
Related Companies (and any other entity or individual that controls
Related Companies, as appropriate) to explain why Board authority was
not required for the two transactions that occurred in 2019, or, if
they believe such authority was needed, to seek after-the-fact
authority under 49 U.S.C. 11323 to control Pioneer and the Pioneer
Railroads. See Baupost Grp., L.L.C.--Control Exemption--Pioneer
Railcorp, FD 36451 et al., slip op. at 3 (STB served Nov. 25, 2020).
On December 2, 2020, RFM filed its verified notice of exemption,
identifying itself as ``the highest person currently in the corporate
chain of control,'' (RFM Verified Notice 2, FD 36306 (Sub-No. 1) et
al.), and elaborating on the transactions described in Baupost and
Infravest Managers' November 2, 2020 supplement. As stated by RFM, when
the notice of exemption in Docket No. FD 36306 was filed on June 7,
2019, ``Related Companies controlled Related Fund Management, which
controlled Related Infrastructure, which controlled Related
Acquisitions, which controlled BRX Transportation.'' (Id.) Therefore,
according to RFM, ``Related Companies, as the ultimate controlling
party, should have sought control authority . . . in FD 36306.'' (Id.
at 3.)
RFM stated, however, that it is the proper party to file the
verified notice of exemption because of the second transaction that
occurred in 2019--the transfer of the ownership interest in Related BRX
Holdings from Related Infrastructure to Related Infrastructure
Holdings--which RFM claims was part of a ``broader intracompany
reorganization.'' (Id. at 3-4.) RFM states that, in the reorganization,
Related Companies formed RFM; RFM formed a subsidiary, Related
Infrastructure Holdings Investor LLC (Related Infrastructure Investor);
Related Infrastructure Investor formed a subsidiary, Related
Infrastructure Holdings; and Related Infrastructure's interest in
Related BRX Holdings was transferred to Related Infrastructure
Holdings. (Id. at 4.) As a result, RFM replaced Related Companies as
``the ultimate controlling party.'' (Id. at 3-4.) According to RFM, it
is ``owned by equity holders of Related Companies,'' and Related
Companies and Related Fund Management no longer have any ownership
interest in entities controlling BRX Transportation, Pioneer, or RFM.
(Id. (footnote omitted).) RFM also noted that none of its equity owners
have control of Related Companies or RFM. (Id. at 4 n.4.)
On December 3, 2020, Baupost and Infravest Managers filed a letter,
which included the agreement through which Baupost and Infravest
Managers are acquiring Pioneer and the Pioneer Railroads, stating that
the parties ``expect to consummate the transaction shortly after the
Board allows the exemption in this proceeding to take effect.''
(Baupost Letter 1, Dec. 3, 2020, FD 36451.) Baupost and Infravest
Managers also requested that the Board remove Docket No. FD 36451 from
abeyance and allow the exemption to take effect promptly or, at the
latest, no later than the day that the Board ``resolves the issues
regarding current control of Pioneer.'' (Id.)
In a decision served December 28, 2020, the Board held RFM's notice
of exemption in abeyance and directed RFM to provide additional
information. See RFM HoldCo LLC, FD 36306 (Sub-No. 1) et al., slip op.
at 5. The Board found that, although RFM implied that it acquired
control of Pioneer and the Pioneer Railroads when Related
Infrastructure transferred its interest in Related BRX Holdings to
Related Infrastructure Holdings, the organizational chart provided by
RFM depicted both Related Infrastructure and Related Infrastructure
Holdings as being under RFM's control. Id. at 4. Additionally, the
Board noted that neither of the agreements provided by RFM appeared to
be relevant to the transaction in which it acquired control of Pioneer
and the Pioneer Railroads. Id.
On January 6, 2021, RFM filed a supplement to its notice clarifying
when it acquired control of Pioneer and the Pioneer Railroads.
According to RFM, ``[o]n December 13, 2019, the ownership interests in
Related Fund Management were distributed to the owners of Related
Companies and on the same date, immediately following that
distribution, were contributed by those owners to RFM in exchange for
equity interests in RFM.'' (RFM Suppl. 2, FD 36306 (Sub-No. 1) et al.)
On February 17, 2021, Baupost and Infravest Managers submitted a letter
in Docket No. FD 36451 requesting that the proceeding be removed from
abeyance and the exemption granted with an effective date in advance of
the ``End Date'' in the parties' purchase agreement.
Discussion and Conclusions
Under 49 U.S.C. 11323(a)(4), the ``[a]cquisition of control of at
least 2 rail carriers by a person that is not a rail carrier'' requires
Board authorization.
[[Page 15767]]
The verified notices of exemption at issue in these proceedings were
submitted under the class exemption procedures found at 49 CFR
1180.2(d)(2), which provide an expedited process for obtaining control
authority under 11323. These streamlined class exemption procedures are
reserved for transactions involving routine, uncomplicated, and non-
controversial matters, and which do not raise substantial factual and
legal issues. See S. San Luis Valley R.R.--Acquis. & Operation
Exemption--Iowa Pac. Holdings, LLC, FD 35586 et al., slip op. at 2 (STB
served Feb. 10, 2012) (rejecting notice of exemption raising
substantial questions about prior acquisitions); V & S Ry.--Aban.
Exemption--in Kiowa Cnty., Colo., AB 603 (Sub-No. 3X), slip op. at 2
(STB served June 17, 2014).
The Verified Notices of Exemption. The verified notice filed by RFM
and the verified notice filed by Baupost and Infravest Managers will be
rejected because both matters are sufficiently complicated and non-
routine to make them inappropriate for consideration under the
streamlined class exemption procedures of 49 CFR 1180.4(g). Both
proceedings involve the unauthorized acquisitions of control of Pioneer
and the Pioneer Railroads by Related Companies and entities within
RFM's corporate family. RFM acquired control of Pioneer and the Pioneer
Railroads, without Board authorization, from Related Companies, which
itself also did not have Board authorization to control Pioneer and the
Pioneer Railroads. (See RFM Verified Notice 3, FD 36306 (Sub-No. 1) et
al.) Baupost and Infravest Managers are seeking to acquire control of
Pioneer and the Pioneer Railroads from Related Infrastructure Holdings,
a subsidiary of RFM, which does not currently have authority to control
Pioneer and the Pioneer Railroads. Although RFM has sought after-the-
fact control authority, Related Companies has not. RFM has argued both
that Related Companies need not seek after-the-fact control authority,
and that the Board should grant that authority to Related Companies
through the Board's streamlined class exemption procedures even though
Related Companies did not itself request it.\4\ (RFM Verified Notice 5
n.6, FD 36306 (Sub-No. 1) et al.) The facts cited during these
proceedings, as described in detail above, demonstrate that these
matters are not routine and require scrutiny by the Board outside of
the streamlined class exemption procedures. See S. San Luis Valley
R.R., FD 35586 et al., slip op. at 2-3. Therefore, the verified notices
in Docket Nos. FD 36451 and FD 36306 (Sub-No. 1) will be rejected.
---------------------------------------------------------------------------
\4\ RFM was formed by equity owners of Related Companies, but
RFM and Related Companies are not under common control because the
equity owners do not have control of either Related Companies or
RFM. (RFM Verified Notice 3-4 & n.4, FD 36306 (Sub-No. 1) et al.)
---------------------------------------------------------------------------
The Board also notes that the information provided during the
course of these proceedings has at times been incomplete or
inaccurate.\5\ For example, Baupost and Infravest Managers, in their
notice, identified the entity from which they were acquiring control of
Pioneer and the Pioneer Railroads as ``an affiliate of'' Related
Infrastructure, without further detail. (See Baupost Verified Notice 3,
FD 36451.) Later, the November 2, 2020 supplement filed in Docket No.
FD 36451 provided incorrect information that identified Related
Infrastructure Holdings as a ``subsidiar[y] of Related Fund Management
LLC,'' notwithstanding that the facts in the supplement ``regarding
Related Infrastructure LLC and its affiliates'' were verified by an
official at Related Fund Management. (See Baupost Suppl. 1-2, FD 36451,
Nov. 2, 2020, FD 36451.) Only after the Board postponed the effective
date of the exemption in Docket No. FD 36451 and requested that Related
Companies seek acquisition authority did the Board learn that Related
Companies had transferred control of Pioneer and the Pioneer Railroads
to RFM. RFM, for its part, filed a verified notice that failed to
identify the date on which RFM acquired control of Pioneer and the
Pioneer Railroads, which was later cured through its January 6
supplement. While the record does not indicate bad faith by these
parties, inaccuracies and omissions such as these raise questions that
often cannot be adequately addressed under the streamlined class
exemption procedures. It is important for parties to ensure that their
filings in exemption (and other) proceedings are accurate and complete.
Nevertheless, as discussed below, the Board has now received from the
parties adequate information for the Board to assess, sua sponte and
pursuant to the exemption standard set forth at 49 U.S.C. 10502(a), the
appropriateness of granting exemptions in these proceedings.\6\
---------------------------------------------------------------------------
\5\ Given the Board's finding that the class exemption
procedures are inappropriate in light of the facts and
circumstances, it need not address whether the notices were also
false or misleading. See, e.g., 49 CFR 1180.4(g)(1)(ii).
\6\ In granting acquisition authority sua sponte, the Board
would effectively proceed as though the parties had formally
petitioned for exemption. The Board will consider below the value of
requiring such petitions at this stage of the proceedings and the
harm that could arise from the ensuing delay.
---------------------------------------------------------------------------
The Sua Sponte Exemptions. As noted, the Board has now received
multiple filings in these proceedings providing information about the
transactions involving Related Companies and RFM that occurred without
Board authority. Although there does not appear to be bad faith, this
does not excuse the failures to obtain Board authorization; and while
RFM has now sought to cure the defect, the Board remains troubled that
the parties did not adequately consider the required authorizations at
the appropriate time.
When it rejects verified notices in non-routine or controversial
cases, the Board often requires parties to seek the necessary authority
by petition for exemption or application. Here, however, an extensive
record has already been developed through the supplemental pleadings.
Additionally, the Board is mindful of the fact that the proposed
acquisition by Baupost and Infravest Managers to acquire Pioneer and
the Pioneer Railroads is also pending before the Board. That
transaction, but for the failures of the selling entity (RFM and its
subsidiaries) discussed above, would have met the standards for the
expedited class exemption process. To require RFM to file a petition
for exemption or application to remedy the prior unauthorized
transactions would further delay, and possibly frustrate, Baupost and
Infravest Managers' proposed transaction. (Baupost Letter 1, Feb. 17,
2020, FD 36451.) No party has sought to oppose Baupost and Infravest
Managers' proposed acquisition of control of the Pioneer Railroads, and
one of the stated goals of that transaction is to ``improve Pioneer's
efficiency, financial strength, and ability to meet the needs of
shippers.'' (Baupost Verified Notice 5, FD 36451.) Baupost argues that
further delaying its acquisition would, among other things, ``affect
the ability of Pioneer and the Pioneer Railroads to accelerate capital
expenditures.'' (Baupost & Infravest Managers Letter 2, Dec. 3, 2020,
FD 36451.)
For the reasons discussed above and based on the particular facts
of this case, the Board concludes that it is appropriate to consider
granting the exemptions sua sponte pursuant to 10502. See, e.g., BNSF
Ry.--Pet. for Declaratory Order, FD 35164 et al., slip op. at 10 (STB
served May 20, 2009); Borealis Infrastructure Trust Management--Acquis.
Exemption--Detroit River Tunnel Co., FD 33984 et al., slip op. at 6
(STB served Dec. 19, 2001). The Board will consider here the merits of
the exemptions requested in these dockets and, as discussed further
[[Page 15768]]
below, will grant the exemptions sua sponte.
As RFM, Baupost, and Infravest Managers are each noncarriers, their
acquisitions of control of the Pioneer Railroads require prior Board
approval under 49 U.S.C. 11323(a)(4). Because the acquisitions of
control do not involve the merger or control of at least two Class I
railroads, approval of the transactions is governed by 49 U.S.C.
11324(d). However, under 49 U.S.C. 10502(a), the Board must exempt a
transaction or service from regulation upon finding that: (1)
Regulation is not necessary to carry out the rail transportation policy
(RTP) of 49 U.S.C. 10101; and (2) either (a) the transaction or service
is of limited scope, or (b) regulation is not needed to protect
shippers from the abuse of market power.
Here, exemptions from the prior approval requirements of sections
11323-25 are consistent with 10502(a). Detailed scrutiny of the
acquisitions of control of the Pioneer Railroads in each docket is not
necessary to carry out the RTP. An exemption from the application
process would promote a fair and expeditious regulatory decision-making
process, minimize the need for Federal regulatory control, reduce
regulatory barriers to entry, and result in more expeditious handling
of this proceeding. See 49 U.S.C. 10101(2), (7), (15). Other aspects of
the RTP would not be adversely affected.
Regulation of these transactions is not needed to protect shippers
from the abuse of market power. RFM states that it ``does not own or
control any other carriers other than the Pioneer Railroads, nor did
it, or its equity owners, at the time of its formation.'' (RFM Verified
Notice 4 n.5, FD 36306 (Sub-No. 1) et al.) Accordingly, RFM's 2019
acquisition of control of Pioneer and the Pioneer Railroads did not
create any adverse change in competition among rail carriers or between
rail carriers and other modes. For their part, Baupost and Infravest
Managers also state that they ``are not themselves rail carriers and do
not currently control any rail carriers,'' (Baupost Verified Notice 4,
FD 36451), so their proposed acquisition of Pioneer and the Pioneer
Railroads similarly would not adversely affect the competitive
landscape so as to require regulation to protect shippers from an abuse
of market power.\7\
---------------------------------------------------------------------------
\7\ Because this decision finds that regulation is not necessary
to protect shippers from the abuse of market power, the Board need
not determine whether the transaction is limited in scope. See 49
U.S.C. 10502(a)(2).
---------------------------------------------------------------------------
Under 49 U.S.C. 10502(g), the Board may not use its exemption
authority to relieve a rail carrier of its statutory obligation to
protect the interests of its employees. Section 11326(c), however,
precludes the Board from imposing labor protections for transactions
involving only Class III rail carriers. Because all the Pioneer
Railroads are Class III carriers, the Board may not impose labor
protections here.
In light of Baupost's and Infravest Managers' request regarding the
effective date, the exemptions will be effective on March 26, 2021.
Petitions to stay will be due by March 24, 2021.
The transactions are categorically excluded from environmental
review under 49 CFR 1105.6(c)(1) and from the historic reporting
requirements under 49 CFR 1105.8(b).
It is ordered:
1. The verified notices of exemption in Docket Nos. FD 36306 (Sub-
No. 1) and FD 36451 are rejected.
2. In Docket No. FD 36306 (Sub-No. 1), under 49 U.S.C. 10502, the
Board exempts from the prior approval requirements of 49 U.S.C. 11323-
25 RFM's 2019 acquisition of control of the Pioneer Railroads.
3. In Docket No. FD 36451, under 49 U.S.C. 10502, the Board exempts
from the prior approval requirements of 49 U.S.C. 11323-25 Baupost's
and Infravest Managers' acquisition of control of the Pioneer Railroads
from RFM.
4. Notice of the exemptions will be published in the Federal
Register.
5. The exemptions will be effective on March 26, 2021. Petitions to
stay will be due by March 24, 2021.
Decided: March 18, 2021.
By the Board, Board Members Begeman, Fuchs, Oberman, Primus, and
Schultz. Board Member Primus dissented with a separate expression.
Board Member Primus, dissenting:
This case is extremely troubling and lays bare gaps in compliance
that I am not willing to excuse. The focus of my displeasure is not
directed toward Baupost and Infravest Managers, but rather Related
Companies and RFM. When the history of Related Companies and RFM is
taken into account, specifically their inability to provide accurate
and complete information to the Board with respect to ownership, what
we have before us is at best a comedy of errors and at worst a blatant
disregard for the Board's role as the economic regulator of the rail
industry.
The Board was faced with two notices of exemption involving a chain
of unauthorized transactions. Details surrounding the history of the
ownership of Pioneer and the Pioneer Railroads is murky and
unnecessarily complicated. Upon further review, it was revealed that
Related Companies never obtained Board authorization to acquire Pioneer
and the Pioneer Railroads. Similarly, RFM skirted Board authority when
it acquired the railroad entities from Related Companies. Only now,
when Baupost and Infravest Managers have come before the Board to
acquire control of these railroad entities, has RFM decided to step
into the light.
Failure to obtain the required Board authority lies squarely with
RFM. Both RFM and its subsidiaries (and Related Companies before it)
did not bother to adhere to 49 U.S.C. 11323, which clearly requires an
entity seeking to purchase/acquire a railroad to obtain Board
authority. Given the fact that the proposed acquisition involves
unauthorized transactions, it was incumbent upon the parties to be
forthcoming with accurate and complete information about the ownership
and relationship of the numerous railroads involved in the proposed
transaction. This clearly did not happen.
Accordingly, I do not believe that the selling entity should be
permitted to benefit or profit from such a transaction without first
curing its unauthorized acquisition. While RFM has asked for after-the-
fact authority, it has done so through the Board's streamlined class
exemption procedures, which are reserved for transactions involving
routine, uncomplicated, and non-controversial matters, and not
appropriate here. Moreover, Related Companies has not sought after-the-
fact authority for its unauthorized acquisition.
My hope is that, moving forward, the Board will begin to look at
ways to effectively promote greater compliance and transparency as it
relates to the licensing of rail activities. For those who continue to
operate outside the rules, stronger enforcement, including the
administering of severe penalties when appropriate, should prevail.
For these reasons, I respectfully dissent.
Aretha Laws-Byrum,
Clearance Clerk.
[FR Doc. 2021-06066 Filed 3-23-21; 8:45 am]
BILLING CODE 4915-01-P