NCGA joined several other members (~50) of the Agriculture Transportation Working Group in submitting comments to the Department of Transportation on the state of the U.S. supply chain. The comments address the many disruptive factors our supply chain is facing and give recommendations on how to alleviate them through legislative and regulatory actions. The comments address several key areas of concern to NCGA members; inland waterways, rail competition and truck transportation. The Agricultural Transportation Working Group (ATWG) is composed of associations representing producers, grain handlers, millers, processors and exporters, input suppliers, feed and pet food manufacturers and other agribusinesses. A primary goal and focus of the ATWG is to advocate for federal policies and investments in infrastructure that make America more competitive.

The following is a brief summary of different comments:

Inland Waterways

The inland waterways system is vital to the American supply chain and gives U.S. producers a significant advantage in terms of cost and efficiency over our international competitors. The comments urge the administration to prioritize legislative and regulatory actions that promote the rehabilitation of aging waterway infrastructure on the Upper Mississippi River and Illinois River. This includes the addition of seven 1,200-foot locks on the Upper Mississippi River and Illinois Waterway as part of the Navigation Ecosystem Sustainability Program (NESP).

Rail Competition and Service

The comments mention the value of promoting competition in rail transportation and the cost saving outcomes such actions would have on U.S. grain shippers and receivers. The comments encourage the Surface Transportation Board (STB) to consider a regulation which would allow for the use of “reciprocal” or “competitive switching.” Competitive switching would enable shippers and receivers geographically beholden to one rail carrier to gain access to a second rail carrier through a short distance “switch.” NCGA supports a competitive and nondiscriminatory rate structure for our nation’s railroads.

Motor Carrier Freight Transportation Efficiency

The comments recommend a few key actions that could help alleviate the disruption in our motor carrier freight transportation sector, they are the following:

1. Adoption of policies to mitigate the ongoing truck driver shortage, such as removing the commercial driver’s license (CDL) restrictions on drivers aged 18-20 that creates an obstacle to recruiting a new generation of drivers into the industry.
2. We recommend that USDA and USDOT continue to coordinate to ensure agricultural haulers and the rest of the trucking industry have the flexibilities needed to provide timely delivery of essential products. Flexibilities, such as relief from Hours-of-Service requirements, have been critical over the last 18 months.
3. Adoption of a 10% axle tolerance for dry bulk shipments.
4. Adoption of a pilot program to achieve economic and environmental efficiencies through a modest increase in federal truck weight limits.
5. Maintaining the existing minimum financial liability coverage level for motor carriers.  Efforts to increase liability insurance for motor carriers beyond the current $750,000 level will increase freight costs without any known safety benefits.
6. Support necessary reforms to modernize the Farm-Related Restricted CDL program, which has currently been adopted by 24 states.

Finally, it is also worth noting that last week the President announced that the Port of Los Angeles would begin to operate on a 24/7 basis. This move could potentially mitigate the bottleneck of goods on the west coast awaiting distribution throughout the country. (My comment: The unknown is whether or not people will come to work.)

The full comments are available upon an emailed request to deweylee@uga.edu. It is about 12 pages long if you desire to read it.