The Alliance for Chemical Distribution (“ACD”), American Chemistry Council
(“ACC”), American Fuel & Petrochemical Manufacturers (“AFPM”), The National
Industrial Transportation League (“NITL”), and The Fertilizer Institute (“TFI”)
(collectively, “Joint Shipper Associations”) hereby move the Surface Transportation
Board (“STB” or “Board”), pursuant to 49 C.F.R. §§ 1117.1 and 1180.4(c)(8), to deny
the Amended Railroad Control Application filed by Applicants1 on April 30, 2026, as
supplemented on July 7 and 27, 2026 (collectively the “Application”), for failure to
present a prima facie case.