Can we go at it from the obverse? If the bill is left alone, could a shipper in an arbitration proceeding insist that dwell times be part of the service obligations required for the arbitrator to put into a service level agreement, or is it the subject of debate, as it is today? Because that's what the shippers are telling us: they have all kinds of difficulties with what is “adequate and suitable service obligation”. If they come to the arbitrator and say, “We must have a dwell time”, can the carrier say, “Well, it's not defined, so you don't get it”?
On April 16th, 2013. See this statement in context.