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67 APPENDIX D Compilation of Potential Obstacles to the Development of Marine Highways Service/Marketing Issue Comments References Perception by others Shippers and freight forwarders see water transportation as slow and old-fashioned ... NAMH 1, 2, 3, 4, 5, 6, 8, shipping is generally slower and less frequent than rail or road ... Skepticism about the service's 10, 14, 21, 31, 33, ability to provide adequate transit time and reliability ... IMCs (Intermodal Marketing Companies) 43 either are not aware of NAMH services or choose not to use them, making it difficult for NAMH to increase its market share ... Many shippers feel that barge transit times are less reliable than truck or rail because of weather factors ... It has a poor service image, it is seen as a segmented industry, and it is perceived to be a complex system involving many actors. The missing link that requires most attention is to convince shippers and forwarders presently using road transport to abandon their sole reliance on road and rail transport and give more serious consideration to alternative modes such as NAMH as a backbone for integrated door-to-door transport ... However, shippers in the general cargo market will see lack of daily services with faster travel times as a competitive disadvantage for NAMH services as compared to truck and even rail services. It takes time to convince cargo owners to change their habits, and they need to see reliable and regular services before doing so, making it difficult to fund the start-up phase. NAMH is perceived as a slow mode, and inappropriate for just- in-time delivery systems ... Not perceived to be competitive with trucks ... Past failures make shippers reluctant to switch. Lack of supply chain U.S. shippers are quite concerned about purchasing a service requiring multiple carrier contracts ... 1, 4, 21, 40 orientation/lack of Any possibility of commercial viability almost certainly hinges on a service that combines feeder modal integration operations with door-to-door (domestic or cross-border) service, so as to achieve a sufficient volume to allow sailings at a regularity sufficient to meet the expectations of shippers of higher value, more time-sensitive cargoes ... However, feeder service obligations are likely to tie any such NAMH operation to the schedules of deepsea carriers. It may, therefore, only be quite providential that such departure times, or indeed frequencies, meet the needs of door-to-door shippers ... Many NAMH companies are too small to operate total logistics chains and they are characterized by individualism that makes it difficult to cooperate with others in the industry ... Insufficient integration with other transport modes in the transport chain; NAMH can have difficulty in meeting "just-in-time" requirements ... Lack of supply chain orientation by carriers and integration with other modes. Schedule reliability Susceptible to inclement weather conditions. 6, 10, 33 Trip frequency Trucks can operate on demand. Rail carriers can offer daily or twice-daily service. No one has 6, 8, 10, 40 documented any NAMH operators in the United States offering daily service. Delivery schedules increasingly need to fit just-in-time delivery requirements ... Fixed-day departure every two weeks is not acceptable to a majority of exporters ... Only a small percentage of the market is interested in a NAMH option with biweekly service. Insufficient demand Viable cross-border NAMH services will require relatively high-volume shipping lanes to generate 33 sufficient demand for frequent services (a necessary pre-condition to compete with trucking). This may be difficult to develop in the primary corridors of cross-border movement on the West Coast. Difficulty in selling Fewer and fewer carriers or alliances control larger and larger blocs of cargo, and the number of 2, 7 feeder service to potential customers of a feeder service is reduced ... Steamship lines often do not realize the full ocean carriers costs of trucking operations and thus mistakenly believe barge service is overpriced ... Bills for "hidden costs" come into different departments and different individuals at the steamship company. International cargoes On Canada's Atlantic Coast, a NAMH based purely on international cargo is not financially viable 8, 9, 40 since the largest customers of Canadian National Railway (CN) also pay the lowest rates to the railway ... Coastwise between major ports: large ports already served by foreign liners, imports/exports tend to move east-west to/from these ports, versus north-south ... If the larger shipping lines decided to chase the cargo that a NAMH operator carried, they could jeopardize the existence of the service. (continued on next page)
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68 Issue Comments References Market issues The biggest barrier to NAMH operations in Canada is the lack of a defined market ... Inadequacy of 10, 11, 12, 21, 40 meaningful statistics, data, and information ... Furthermore, the possibility is complicated by the seasonality of the exported goods ... There is a lack of statistical data that make accurate analysis of trade flows between ports and regions difficult; this creates problems both for commercial development and policy making ... The academic community needs a far better picture of freight movements within the United States in order to support further analysis of the potential benefits of coastal shipping, as well as to capture the currently under-appreciated externalities of freight movements, such as pollution. Accurate and precise freight data along America's coastlines simply do not exist. Transit time Transit times for the barge services are not competitive even with current congestion levels at the 4, 12, 13, 21, 31, border ... Great Lakes ports have experimented with the concept of bringing in containers by ocean 33 vessel but have found that shippers preferred the shorter timeline of rail-truck intermodal movements from the ocean ports for containerized cargo ... Vessel performance leads to a lack of speed when compared to its competitors on U.S. trade corridors, especially highways and roads ... Transit times are cited in surveys more than any other factor as a major problem. Cost Issues Issue Comments References High fees for ports Another obstacle to NAMH container feeders is modal interchange costs, or handling 10, 14, 31, 33 and land-based costs ... The cost of the vessels (even the higher costs of U.S.-built Jones Act vessels), was services found to represent only 14% of the total cost per trailer. The most significant costs for NAMH on a per trailer basis remain the landside costs including truck drayage to and from the terminals, port costs, and fuel costs ... Research has shown that the economic viability of marine highways is influenced to a significantly greater degree by landside costs such as truck drayage and terminal costs than by vessel capital costs ... Often times the cost barrier comes in the form of transport onto or off a smaller port facility instead of the on-dock storage or cargo handling costs. Terminal lease Especially on the West Coast, the cost of land acquisition in a port area is prohibitive and 14 costs are too high the lease rates for waterfront property are very high. Lack of capital Private financiers are unwilling to take the plunge ... Reluctance to invest millions of 15, 22, 34, dollars on untested ideas ... Difficult to obtain financing in today's environment. Economic load The volume of freight handled in a single block (typically 4001,000 TEU) restricts the 2, 33, 40 requirements frequency of shipments compared to other competitive modes of intermodal transport. Trucking typically handles 2 TEU at a time and intermodal trains handle roughly 250 TEU per train ... The larger the vessels, the lower the frequency to handle the same volume. This creates a barrier to entry into shipping routes as the volume of cargo must be sufficient to enter the market with an economically sized vessel ... The need to consolidate loads and the associated impacts on frequency of service clearly puts NAMH at a disadvantage, particularly for general cargo moves, when compared to rail or trucking. Increased lead time Cargo has to be accumulated at the outbound dock ahead of time (a particular issue for high- 31 value goods because of increased inventory costs). Infrastructure Issue Comments References Terminal handling Most Great Lakes ports do not have the necessary equipment to handle containers 1 equipment efficiently, and justifying such investment is difficult. Driver hours-of- Time spent by drivers with their vehicles on a ferry is considered to be on-duty time, thus 1 service rules providing no benefit with regard to driver hours-of-service regulations. Port infrastructure ... Locks/dams, channels, bridge clearances ... Many of the underutilized ports that would 15, 16, 17, 18, 33, 34 benefit from increased NAMH operations do not have sufficient infrastructure (berths, cranes, access) ... Ground storage capacity is currently at a premium at most ports. The current policy of managing capacity through surcharges will discourage growth of comparatively low-revenue domestic transportation ... Information systems support to coordinate "hand-offs" between motor carriers, ports, and ocean carriers would be a critical service component to ensure a seamless service ... Initial capital costs, including vessel procurement costs and port infrastructure-related costs, are much higher in NAMH than in trucking, which deters carriers to invest in such business ... Potentially insufficient terminal capacity and added congestion on port access routes ... Diverting over-the-road truck volume into port areas for marine highways service use may compound existing traffic congestion issues in and around the ports ... Port infrastructure constraints do not appear to be a major obstacle to expanded services ... However, bringing shippers physically closer to carriers by creating warehouse and processing sites near the water may be an important incentive for development of NAMH and this could be difficult given municipal tax policy in British Columbia, zoning rules, environmental permitting requirements in coastal areas, and community opposition to port expansion in both Canada and the United States.
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69 Government/Regulatory Issue Comments References Harbor Maintenance Some trucks move by water from the United States to Canada, but return to the United 1, 17, 19, 20, 21, 22, 23, 24, Tax States by bridge to avoid paying the tax ... Horizon is "waiting to see what happens with 26, 27, 28, 31, 34, 36, 40, 43 the Harbor Maintenance Tax." ... HMT is an identified cost of anywhere from US$75 to US$120 on a 20-ft box ... This tax may amount to around 2.5% of the total cost of a NAMH movement along the Atlantic Coast. It adds to the cost of the NAMH mode as well as introducing the "annoyance factor" of an additional layer of administrative paperwork that does not encumber a trucking movement ... HMT still accounts for 6% 10% of the total costs per trailer load on the Pacific Coast ... To use a NAMH carriage alternative, the highway carrier must contact every shipper with freight in the trailer to seek permission to subject each shipment to the HMT at the expense of the shipper or importer. The domestic shipper/importer will calculate the added cost (HMT) of shipping by water and make a business decision whether the time and money saved on the congestion avoidance route is worth the added tax and document filing obligation. If it agrees to incur the added costs associated with HMT, the domestic shipper/importer will need to declare accurately the shipment contents and value of the merchandise shipped ... A vessel that carries multiple cargoes such as the DetroitWindsor Truck ferry is unable to attract additional business such as UPS trucks because each shipper in the truck will have to pay the tax, creating a paperwork issue on less-than-truckload cargoes ... It serves to stimulate rather than discourage a shift to the use of land modes, and therefore works at variance with the thrust of the arguments for encouraging NAMH ... HMT is the prime example on the U.S. side exemplifying this situation. Application of this tax encourages cross-border traffic to move by land rather than by water ... The single most important impediment to the development of NAMH in the United States is the Harbor Maintenance Tax. Costs vs. public benefit There is no mechanism to credit a potential operator with these external benefits ... If 4, 25 coastal shipping produces economies, it is not clear where the savings will be realized--the carrier, the cargo owner, or the consumer. Thus, it is hard to determine who should invest to make the necessary improvements to enhance the efficiency of coastal shipping. Customs clearance Advance notice of 24 hours is required by U.S. Customs and Border Protection (CBP) 12, 21, 26, 27, 28, 33, 40, 43 for cargo traveling from Canada (or Mexico) by water ... In the case of a truck trailer, a shipper must provide CBP with advance notice of only 1 hour prior to arriving at the border crossing. For shipments moving by rail, the notice requirement is 2 hours. For a similar shipment moving into the United States via water where there is no driver on board, however, CBP requires at least 24 hour's advance notice prior to the cargo being loaded onto the vessel ... Customs clearance was perceived to be more difficult for shipping than for trucking and this perception may be more of a barrier to service adoption than expected ... Inconsistencies in the application of rules and procedures (particularly in relation to customs) are another consideration. Differentials in the timeliness or availability of services or differences in cargo inspection procedures (that delay loading or unloading of cargo or passengers) ... This problem is exacerbated by the non-availability to marine movements of customs services on a 24/7 basis, while such services are available for most land-mode border crossings ... There is currently an imbalance in the way security and customs rules are being applied on both sides of the border and harmonization of these procedures may be critical to development of a viable NAMH service. The application of 24-hour rules is the most often cited example of this inequity ... Because the DetroitWindsor Ferry operates a truck ferry service, Animal and Plant Health Inspection Service (APHIS) agricultural quarantine inspection (AQI) fees are collected twice--once on the vessel ($490.00) and then again on the truck ($5.25). If a truck crosses a bridge or tunnel, the fee only applies to the truck ($5.25) ... A serious challenge to developing NAMH within the Great Lakes region will be the Canadian government policy of charging any new international marine operation the full cost recovery of customs services. These identical services are provided to bridges and tunnels without charge ... Canadian Customs has limited the hours that they would clear vessels on cross-border trade. U.S. Customs charges overtime and travel expenses to clear vessels. Truck and rail operators are able to have 24-hour service with no recovery charges ... Anything that constitutes more demanding or lower-quality customs treatment in comparison with that applied to land alternatives disadvantages marine movements in relation to an all-land route ... Administrative barriers because of rather complex documentation and procedures in ports and the veterinary checks ... Canadian cost recovery fees ... Clearly, the service would benefit from more harmonized documentary procedures (including, of course, the use of a single waybill). (continued on next page)
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70 Issue Comments References Federal policies Inequity in infrastructure-related subsidies to land-mode operators (e.g., through the 15, 29, 31, 40 provision of "way" facilities [i.e., roads and railways], the cost of which is not fully recovered from users of that infrastructure) ... "In this country, of course, state and local governments take their lead--and their approach to funding--from the federal government. Unlike the European model, we continue to consider the U.S. Department of Transportation reauthorization as essentially a "highway" bill, with virtually no attention given to the marine transportation system or to stimulating SSS" ... Industry involvement with DOT/Metropolitan Planning Organization (MPO) planning efforts can be limited. State DOTs and MPOs often conduct long-range planning on a 20- to 30-year timeframe, while the private-sector freight industry often conducts long-range planning on a 6- to 18-month timeframe. This mismatch in planning horizons complicates efforts to fully engage the private-sector freight community in a process that they perceive to be long, cumbersome, and overly bureaucratic. Security New security requirements and customs rules (advance manifest requirements) will 4, 14, 33 make cross-border services less attractive as compared to trucking and as compared to domestic marine services. This is a particular concern for southbound movements from Canada into the United States ... While these new security regulations are designed to prevent terrorist activities on vessels and ports serving international trade, the increased costs and potential cargo shipment delays resulting from these rules may make cross- border NAMH operations less attractive to potential shippers and operators ... In North America, as elsewhere, one of the major impediments to the further development of coastal shipping is the limit on cabotage. In the United States, the Jones Act (1920) is widely recognized as a serious constraint ... Marine highways are not yet being considered as part of transportation improvement plans developed at the state level. Cabotage Cabotage rules (Coasting Trade Act in Canada and Jones Act in United States) do not 30, 31, 33, 38 seem to be a significant barrier in cross-border NAMH services. There were only a few carriers who indicated that multi-port per country services would be necessary to generate economical services given demand patterns and distances between ports. Some carriers approved of the cabotage restriction so that cross-border NAMH did not become the vehicle by which domestic shipping was undercut by the other country's carriers (similar concerns as those expressed by motor carriers) ... No carriers that were interviewed noted that the Coasting Trade Act or the Jones Act were a specific concern or hindrance to them with regard to cross-border NAMH ... The Jones Act, which requires that ships engaged in domestic maritime trade be U.S.-built, U.S.-owned, U.S.-flagged, and U.S.-operated, was cited by many interviewees as a key obstacle to expanding the use of NAMH operations in the region ... Canadian cabotage restrictions and duties create sunk costs that can not be recovered if the service is unsuccessful ... Duties, in conjunction with other maritime fees, make new entry into NAMH services extremely costly and risky. Municipal issues (In Canada) the following municipal factors were listed as being factors that hinder 33 NAMH: · Municipal levies on waterfront property (see next section), · Zoning restrictions and land use planning, · Municipalities acting locally rather than regionally, and · Governance electoral cycle. The British Columbia (B.C.) Port Competitiveness Committee, which was formed in 1999, concluded that excessive municipal property taxes were making many terminal operators unprofitable and discouraging new investment in infrastructure. In some jurisdictions, taxes on port tenants equaled the rent paid to port authorities. Property taxes for B.C. terminals are 3% to 6.9% of assessed value. Operational Constraints Issue Comments References Lockage and speed In several areas of the Great Lakes, for instance, gains from higher speeds will be lost while 1 restrictions traveling through locks and restricted-speed zones. For example, traversing the 27-mi Welland Canal between Lake Ontario and Lake Erie requires approximately 11 hours. Winter shutdown Suggestions to shippers that they use NAMH for 9 months, and then temporarily switch to 1, 8, 31 other modes during the winter, are difficult to sell.
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71 Issue Comments References Local port Massachusetts: The law requires barge tankers to have tugboat escorts and follow specified 3, 4, 7, 9, 10,12, 32, 33, 34, 40, operational routes and sets minimum staffing requirements and mandatory drug and alcohol testing ... 41 requirements Gate charges are not often counted as a cost when comparing trucking to marine ... The Right Whale Rule kills exposed water marine highway services and drives cargo to trucks ... "With the new port security, many of my truckers are not authorized to go into the ports, and they actually are not willing to go into a port" ... Drayage to and from the ports ... Drayage costs, port charges, and handling costs are viewed as significant obstacles and NAMH services are viewed as not being able to meet shipper requirements in many cases ... Handling costs are likely to be a major cost component for every type of service that is envisioned. Many of the existing domestic NAMH services that are successful are operating out of private facilities or in situations in which lower skilled labor (often non-union) can be employed ... Since ocean-going containerships are the primary customers of these ports, they typically have preference when it comes to berth, labor, and equipment availability. This is a particular concern for lift-on/lift-off ships, which require a significant amount of labor and equipment for loading and off-loading cargo ... Deepwater ports often require the use of other services, including pilotage, tug assist, and line-handling services ... Drayage costs to the load point and from the delivery point to the receiver are also significant costs ... Delays in ports are a serious issue ... Port charges that are sometimes very high and not transparent ... Shippers see ports as obstacles to just-in-time business ... The ratio of terminal costs to total costs tend to be too high, to the point where intermodal options are rendered non-competitive. Labor issues ILA assessments can be high ... "We tend to avoid anything that has to do with the 3, 10, 12, 15, 31, 33, 34, 43 International Longshore and Warehouse Union (ILWU)" ... Perceived risk of potentially costly delays for traffic moving through ports due to the involvement of longshore labor as part of the transportation service ... Waterfront labor practices on the Pacific Coast were seen as presenting a major potential hurdle with a possible lack of concessions on labor productivity ... A number of carriers mentioned that the use of unionized labor for on-dock handling activities is an obstacle to NAMH, given the tremendous pressure to keep handling costs down to be competitive with trucking. These carriers argue that the types of handling operations associated with NAMH operations frequently require lower skill levels as compared to deep sea container operations and the current union rules do not take this into account ... The cost of labor for rehandling at each origin and destination port has the potential to offset any gains in per ton-mile cost savings of the waterborne option ... Restrictive labor regulations and practices ... Labor rules and requirements were an often-cited obstacle to cross-border NAMH. This complaint by carriers may be based on comparison of costs when shipping from private terminals, which may not be unionized, as opposed to public ports ... High union labor rates can potentially act as a barrier against increased NAMH operations ... High stevedoring cost. Container chassis Motor carriers are looking to the ocean carriers to assume the responsibility for chassis 34 management supply and coordination. Vessel-Related Issues Issue Comments References Lack of vessels that While many nations protect their coastal fleets through laws similar to the Jones Act, none-- 15, 22, 31, 35, 38 qualify under the other than the United States--require that their ships be domestically built ... There is a lack Jones Act or of vessels that are appropriate for use in NAMH operations ... There is a shortage of vessels Canadian cabotage suitable for use in NAMH trade ... There are few adequate vessels sailing under the law Canadian flag. Vessel costs and A key constraint on the development of NAMH services is the very high cost of suitable 6, 14, 15, 19, 23, 24, 31, 34, availability new vessels from U.S. shipyards that make them unemployable in any other service thereby 36, 37, 38, 39, 43 creating a significant business risk for any investor contemplating such a start-up service ... Lack of capital financing guarantees for new ship construction through the Title XI program ... Ocean carriers perceived that the high capital cost of U.S.-built ships was the single largest obstacle to successful implementation of domestic coastal NAMH services ... Initial capital costs, including vessel procurement costs and port infrastructure-related costs, are much higher in NAMH than in trucking, which deters carriers to invest in such business ... Amazingly, the Jones Act was barely mentioned by marine operators ... High U.S. shipyard construction costs ... The capital investment by the transport operator is so much greater that there is considerable work on the part of all players to make the mode a viable alternative ... The extremely high cost of commercial vessels built by U.S. shipyards must be addressed ... The risk capital just isn't there to make it happen right now ... These vessels are expensive to construct and maintain, requiring a long-term commitment by shippers who would use a NAMH service ... Many of us believe that the principal problem is the absence of available financing ... There will be no 20-year or 25-year vessel financing without a Title XI program or some similar government guarantee ... The larger challenge for shipbuilding in the United States is the ability to secure series production ... The cost of equipment is another important discriminator between truck and coastal shipping. The high number of vessels envisioned for an NAMH service, and the infrastructure to support them, would take a large third-party logistics provider (3PL), trucking company, or consortia of small service providers in order to amass sufficient capital and market share for a service to be successful. (continued on next page)
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72 Issue Comments References Vessel operating Manning levels for self-propelled vessels engaged in domestic commerce are much higher 34, 39 requirements than for tug-barge combinations moving an equivalent amount of freight ... Horizon advocates moving the ubiquitous 53-ft trailers off the highways. They admit, however, that this will be a difficult thing to do with existing domestic marine assets. Other Issue Comments References Flow imbalance Flows are significantly imbalanced--northbound flows of 51.8 million trailer-loads versus 21, 33, 34, 40, 41 26.4 million trailer-loads southbound ... Possibility of a high volume of empty equipment repositioning ... The trade imbalance also creates an obstacle based on the difficulty of generating back-haul loads. Reducing cabotage obstacles might be one way of expanding back haul markets ... However, this is a problem faced by competing modes so its differential impact on NAMH may not be that significant a factor ... This affects regularity of service ... We also concluded that the trade is unbalanced and, without the opportunity to engage in cabotage on the return leg, it is highly likely there will be poor capacity utilization northbound. Rate competition Recognizing that coastal competition constitutes only a small percentage of the business of 33, 40 land-mode operators, there is a risk of non-compensatory pricing on those routes that compete with NAMH so as to discourage diversion ... Shippers seem to expect services discounted below truck rates and these cost goals are difficult to achieve. Resistance from Some ports perceive NAMH services as adding to congestion and emission problems in 14 port authorities their area, even though they might be beneficial from a systems perspective ... A redistribution of emissions from inland to coastal communities are a roadblock to acceptance. Miscellaneous The risk of loss or damage is enhanced by the inclusion of additional handling points ... (In 12, 15, 21, 30, 31, 33, 36, 40, Canada) truckers are generally paid per kilometer driven, rather than on overall mileage; 42, 43 thus there is a disincentive to use Ro/Ro services ... Developing a national transportation policy also conflicts with the local nature of infrastructure development. Most intermodal infrastructure projects begin at the local level and must meet state environmental regulations. Funding comes largely from state and local sources and the private sector ... Difficulties in competitive pricing ... To sum up, the shorter the distance, the less likely NAMH is competitive against the truck mode on cost. The longer the distance, the less likely NAMH will be truck-competitive on transit time. In short, NAMH has difficulty meeting the service and price requirements of shippers ... NAMH would be much more competitive if more manufacturing plants and consumer markets were within 5 mi of water ... Bringing the shippers closer to the load points could help make NAMH more cost competitive (as was the case in the past). However, many of the bulk raw materials shippers that traditionally used this service are in decline or restructuring of the industries has moved production locations farther from water loading points ... The more common operation for bulk transport is to load directly on barge from a production site with appropriate bulk handling equipment ... There is a lack of "port partnering." ... Canadian icebreaking fees, even when there's no ice ... NAMH operations are subject to "way" charges (one example being pilotage and another being marine services fees), to which competing modes (e.g., road, rail) are not subject. REFERENCES 1 Higginson, James K. Great Lakes Short Sea Shipping and the Domestic Cargo-Carrying Fleet. Transportation Journal, Vol. 46, No. 1, Winter 2007, pp. 3850. 2 Frost, J., D., D. Hawkins, P. Morin, and R. Hodgson. Short Sea Shipping Market Study. Transport Canada, September 2005. Available at http://www.tc.gc.ca/innovation/tdc/projects/marine/a/5563.htm as of July 1, 2009. 3 Kruse, B. Comments on Potential Short Sea Shipping Market for the West Coast. Presented at NSRP Short Sea Shipping Workshop, Orlando, FL, April 1920, 2007. Available at http://advancedmaritimetechnology.aticorp.org/short-sea-shipping/nsrp-pdmt-short-sea-shipping-workshop-april-19-20-2007- presentations/2B_Kruse_Markets.pdf as of July 1, 2009. 4 Comtois, C. and B. Slack. Restructuring the Marine Transportation Industry: Global Overview of Sustainable Development Practices. Ministère des Transport Quebec, Montreal, QC, Canada, April 2007. Available at http://www.mtq.gouv.qc.ca/portal/page/portal/Librairie/Publications/en/ministere/etudes/rtq0701.pdf as of July 1, 2009. 5 In the Fast Lane, Ports & Harbors, July 2006, pp. 2629. 6 Glass, P. Short Haul. Work Boat, December 2004, pp. 3637. 7 Marketing Barge Feeder Service Is a Tough Job. American Shipper, No. 11, November 1987, p. 86.
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