I would say the simple answer to that is yes. The definition of a shipper should be quite broad. Usually the term that's used is the beneficial owner of the cargo as the real shipper, but it could be a freight forwarder. It could be a short-line railway, and I think that would make a lot of sense, actually, for the short-line railways to have some of those rights.
I think Mr. Pellerin's comment about the short-lines being able to take cases before the agency, similar to the way shippers can for service problems, for example, makes a lot of sense. So I would make it a very broad definition.