The reactive as opposed to proactive comment in the report really refers to the fact that the agency is empowered to react to specific complaints. If some shipper, for example, has a complaint about treatment by a railway, and yet this is part of a pattern of behaviour on the part of the railways or some systemic issue, the agency is not empowered to deal with that. They're only empowered to deal with the specific complaint by the specific complainant and the party that has caused the grievance.
We're saying that the agency should be empowered to get ahead of issues, to create systemic solutions, and have ex parte power when a crisis evolves to issue orders that could create fixes that pertain to more than one shipper, for example.