BN states that the large fleet of RS cars was taken into consideration when the 1958 and 1962 rate reductions were effectuated. With the obsolesence of the RS and RSB cars the carriers, it is asserted, no longer have a surplus of equipment. Thus, it is contended an improvement in revenue is necessary if "meaningful" transportation service is to be provided in the future. It is pointed out that the proposed rates would apply on cars officially listed as having an inside length not exceeding 54 feet, 8 inches, in contrast to the present rates which are restricted in their application, insofar as mechanical refrigerator cars are concerned, to cars not exceeding 44 feet, 7 inches inside length dimension. The change will make the rates applicable on an additional 2,200 jumbo mechanical refrigerator cars.

The proposed rates are opposed by the Red River Valley Potato Growers Association, which has a membership of about 1,500 growers, merchandisers, and processors of potatoes grown in the Red River Valley, and the Grand Forks Chamber of Commerce, a nonprofit North Dakota corporation organized for the purpose of fostering and promoting the business and civic interests of Grand Forks, N. Dak., as well as its trade area. Grand Forks is located in the center of the Valley and its potato growing area.

These protestants supported by the North Dakota Public Service Commission, propose that a uniform graduated scale rates should be devised for potatoes that would be applied from all shipping points so that each area could enjoy the advantages of its proximity to markets while paying for the mileage involved for its transportation. They also contend that until the RS and RSB refrigerator cars are phased out for their traffic the present 50,000-pound rates on potatoes, as increased by ex parte increases, should be continued. This, they argue would enable shippers to continue to use the RS cars on 50,000 to 60,000-pound loads, the maximum for that equipment. The proposed uniform scale of rates would apply for higher minimum weights for shippers able to obtain the larger mechanical refrigerator cars for loading and able to sell heavier loads.

One of the principal objections of these protestants to the proposed rates is that the largest increases would be on movements to their largest markets, such as Chicago, Kansas City, and St. Louis. They are also concerned with the effect that the proposed rate scale will have on competitive relationships among producing areas. It is noted for example, that greater increases are proposed from the Red River Valley than from Idaho in some instances. The differences in the proposed increases are shown for the named important destinations from representative origins, Grand Forks and Idaho Falls, Idaho, in the table below:

It is also shown that the existing rate spread between Grand Forks and Idaho Falls to most destinations would be adversely affected. For example, to Chicago, on shipments of 60.000 pounds (using the 50,000-pound rate from Grand Forks) the present rate spread, Idaho Falls over Grand Forks, is 83 cents. This would become 56 cents under the proposed rates. On 80,000-pound shipments the corresponding spread would be reduced from 58 to 44 cents. However, rates somewhat lower, subject to a minimum of 90.000 pounds are proposed for Grand Forks and not from Idaho.

The Red River Valley protestants also show the relationship that the present and proposed rates bear to first-class rates from Grand Forks and Idaho Falls for shipments of 60,000 and 80,000 pounds. The percentage relationship of the present and proposed rates from Idaho Falls are lower than the corresponding relationship of the Grand Forks rates.

Comparisons are made of the car-mile earnings of the present and proposed rates from Grand Forks and Idaho Falls on shipments of 60,000 and 80,000 pounds. The car-mile earnings of the present as well as the proposed rates from Grand Forks are higher. Comparisons of the present and proposed rates for shipments of 60,000 and 80,000 pounds to destinations of comparable distances are shown, indicating that the Red River Valley rates are higher than Idaho rates on shipments of similar distances. For example, although Idaho Falls is 263 miles more distant from Dallas than Grand Forks, the proposed Idaho Falls rate is 23 cents lower than the proposed Grand Forks rate on 60,000 pounds, and 28 cents lower on 80,000 pounds. In addition to the Idaho potato origins, these protestants are concerned with potato shipments from Maine to markets in the eastern and southern markets because the rates from Maine are not being increased.

Dry Onions and Potatoes-Idaho and eastern Oregon.-Southwest Idaho and adjoining Malheur County, Oreg., is a major onion producing region of the U.S. The region grew 11,200 acres of onions in 1974, an increase over 8,300 acres grown in 1969. Yield per acre has also increased from 450 hundredweight in 1969 to 508 hundredweight in 1973. The region's 1973 production amounted to the equivalent of 12,000 carlots (40,000 pounds). These onions are marketed throughout the U.S., with 20 percent of the production going to New York terminals alone. Philadelphia, Boston, and other large eastern cities are also important markets for this product. Fifteen years ago virtually all of the onions were shipped by railroad. In 1974 approximately 42 percent of the shipments were by truck, though because of increased production the number of carloads handled by the railroads has remained at about 6,500 per year. Since a large portion of the onion crop is stored the shipping season extends from August through mid-April.

The USDA in a November 1974 publication forecast a total fall potato production for the U.S. of 287,866,000 hundredweight, of which 80,045,000 hundredweight, or about 27.8 percent was attributed to Idaho production. Idaho harvested 300,000 acres of potatoes in 1972 and 323,000 acres in 1973.

There are three recognized potato producing areas in Idaho. The first, centered around Bingham, Bonneville, and Jefferson Counties in eastern Idaho accounts for 61 percent of the State's potato production. The second described as Twin Falls/Burley (Magic Valley) in central Idaho accounts for 27 percent of the Idaho potato production. The third area, centered around Elmore County in western Idaho grows about 12 percent of the State's potatoes.

More than 99 percent of the total Idaho potato production consists of the Russet Burbank variety. In 1972, 58.9 percent of the production was processed for food, 3 percent for starch and flour, with 23 percent of the crop going into the fresh market.

About 84.6 percent of the shipments are by railroad and 15.4 percent by truck, relatively few inbound trucks being available for exempt outbound movements of potatoes from Idaho.

The present rates on Idaho onions differ from the potato rates. Generally, the present onion rates are subject to a minimum of 40,000 pounds. However, from Idaho Falls and Payette there are onion rates subject to a minimum of 80,000 pounds to a few destinations. The proposed rates are generally the same for onions and potatoes. The following table shows the present and proposed onion rates at the Ex Parte No. 281 level, from Payette to representative destinations:

Since 1970 reduced rates on potatoes from Idaho were established subject to a minimum of 80,000 pounds. The reductions were made to meet truck competition and to encourage heavier loading. The then existing 50,000-pound rates were restricted to ice bunker cars and retained. Those rates, subject to a 60,000-pound minimum were made applicable for potato shipments in mechanical refrigerator cars. The proposed potato (and onion) rates are not related to type of equipment.

The proposed rates were designed to establish constant relationships among origins. Idaho Falls, a representative origin located in the largest shipping area was used as a base point and rates from other origins were developed in relation to the Idaho Falls rates. Thus, the proposed rates from Nampa are 8 cents over the proposed Idaho Falls rates, and the proposed rates, discussed below, from Moses Lake, Wash., and western Washington are 8 and 13 cents, respectively, over the proposed Nampa rates. In developing rate relationships among destinations, the proposed rates were first established for base or key destination points and rates to other destinations were related to the key points. The following table shows the present and proposed rates at the Ex Parte No. 281 level, from Idaho Falls to a representative destination in each major rate territory:

The Union Pacific Railroad (UP) is the only railroad originating onions and potatoes in Idaho. More than 90 percent of the cars used in this Idaho traffic are owned by the Pacific Fruit Express Company (PFE), a carline company jointly owned by UP and the SP. During 1973, PFE owned 13,070 mechanical refrigerator cars for the full year. On December 31, 1973, it had 2,776 RS (ice bunker) cars in service. UP represents the proposed rates as compensatory, and reasonably related as to origins and destinations. Additionally, it points out that if allowed, the proposed rates would result in tariff simplification, reducing the present hundreds of pages of tariff matter in several tariffs to 61 pages in one tariff.

The proposed onion rates are opposed by the Idaho-Oregon Fruit and Vegetable Association, Inc., whose membership accounts for about 90 percent of the fruit and vegetable production of southeast Idaho and Malheur County, Oreg. The protestant desires the continued use of the RS cars for the life of the RS car fleet, and hopes to adapt in the interim to the larger mechanical cars if markets permit. It regards the RS car with its ventilator service as the most desirable car for onion shippers, asserting that the larger mechanical refrigerator cars are not well suited for onions because their minimum weights are too large for most customers and are too costly. The western type of onion is large and soft, and hence prone to bruising which produces decay. Thus protestant states that high loading in a car subjects the bottom tier to excessive weight and damage. Onions are now shipped in bags, mostly 50-pound bags. Experiments with cartons, which would allow heavier loading, have been unsuccessful because cartons do not allow enough ventilation. Therefore, this protestant claims that an increase in the minimum weights will result in a potential loss of markets to the western onion shipper unless a diversion to trucking is possible. Idaho onion shippers are stated to prefer rail over truck service.

The proposed potato rates are opposed by the Idaho Grower Shippers Association, a voluntary, nonprofit trade association. Its members, consisting of growers, shippers, and processors of Idaho potatoes account for more than 90 percent of the potato shipments from Idaho.

Also appearing in opposition to the proposed rates is the Idaho Potato Commission, a State commodity commission created to further the production and consumption of potatoes grown in Idaho. Financing of its activities is provided by grower, shipper, and processor elements of the Idaho potato industry under a tax currently levied in the amount of 3 cents per hundredweight on potatoes entering commercial channels. For the fiscal year of 1975-76, it has budgeted $1,196,345 for advertising and $317,970 for