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Stakeholder Comment: James Nolan

[Email submission]

December 6, 2010

To whom it may concern;

As an individual with a research interest in rail pricing, I would
like to consider adding input to the call for discussion about the
limited limited distribution tariffs. However, it sounds like the agency
is seeking more complete information about what they are, while at the
same time pursuing a broader discussion about them. I am not sure this
is a good idea.

Without knowing much about them personally, I cannot begin to offer a
regulatory economics perspective on whether these tariff structures
might emerge from a competitive transportation market, or if they are in
fact a form of rent-extraction (i.e. price discrimination) or if they
are even legal from a common carrier perspective.

My suggestion is that this stage of the process should be about
information accumulation, with a later call for input on the LDT's, once
the broader community (regional government, academics and lawyers, for
example) have had a chance to assimilate their characteristics.
Alternatively if the agency has more information about LDT's (either
examples or aggregate publication/statistics on their characteristics), then I would
appreciate having that information before I can offer input to the CTA.

James Nolan
Associate Professor
University of Saskatchewan

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