Reply Comments before the STB in EP 711

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On behalf of the Competitive Enterprise Institute (CEI), a non-profit public policy organization that specializes in regulatory policy, I respectfully submit this letter in reply to the Petition for Rulemaking to Adopt Revised Competitive Switching Rules. This comment letter develops the following points:

  1. NITL and supporters of its flawed proposal ignore the underlying economics of network industries and seek to require the Board to make arbitrary and capricious rulings on rates and access.
  2. Revised competitive switching rules for the limited short-run benefit of captive shippers will harm railroads, shippers, consumers, and the overall economy in the long-run.
  3. On these grounds, the Board should reject NITL’s proposal and other calls for new forced access regulations.