IWLA filed comments on June 5, in response to a supplemental notice of proposed rulemaking (SNPRM) from the Surface Transportation Board (STB) on changes to its existing demurrage regulations. The changes seek to address several issues regarding carriers’ demurrage billing practices. The STB’s SNPRM was issued following a series of demurrage-related policy decisions and a prior notice of proposed rulemaking, in an effort to clarify the requirements for the information included on demurrage invoices.

Specifically, the SNPRM proposed requirement to include additional information such as the invoice date range (billing cycle), the original estimated date and time of arrival, and the date and time cars are received at an interchange, the ordered-in date and time, and machine-readable data.

IWLA’s comments voiced strong support for the additional information requirements discussed in the SNPRM and offered suggestions regarding how these requirements could be refined for further effectiveness. IWLA also echoed support for requirements that ensure any carrier-imposed demurrage charges are warranted and accurate, and that demurrage billing requirements be applied to all rail carriers, not just those that are Class I carriers.