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Brad Hildebrand, a member of the National Industrial Transportation League (NITL), submitted additional comments to the Subcommittee on Railroads, Pipelines, and Hazardous Materials regarding the Surface Transportation Board Reauthorization hearing. He discussed three main topics: Reciprocal Switching, Final Offer Rate Review, and Commodity Exemptions.

Hildebrand argued that the Surface Transportation Board's (STB) reciprocal switching proposal aims to enhance competition, not reduce railroad rates. He countered the Association of American Railroads' (AAR) claims that the proposal would jeopardize their operations, stating that shippers would need to demonstrate an established working interchange between two rail carriers and meet specific criteria.

Regarding Final Offer Rate Review, Hildebrand supported the STB's proposed rule, which would establish a series of procedural deadlines for rate complaints. He opposed the Small Alternative Voluntary Arbitration proposal put forth by Class I railroads, viewing it as an attempt to stall the STB's consideration of the Final Offer Rate Review proposal.

Hildebrand also requested that Congress require the STB to eliminate all exemptions for commodities in a streamlined and transparent process. He suggested that the STB should interpret its revocation authority more broadly, given the current concentrated market conditions, or eliminate all exemptions by a date certain unless the railroads can show that the exemption is still warranted.