Docket ID: DOT-OST-2024-0006
The comment was received on: 2024-01-30T05:00:00Z
Original comment on regulations.gov
We are pleased to hear the Department is considering changes to the RRIF program to improve accessibility. RRIF Express was a great move in that direction, but it doesn't go far enough, particularly for startup operations, small entities, and organizations interested in establishing rail facilities or service. Most of these smaller projects can be fully ficed with $100,000-$5,000,000 of capital. Our conversations with the Department suggest that only after operating for two years (and showing the associated revenue) would our projects likely qualify for RRIF ficing. Even though the projects are statutorially eligible (i.e. transload facility, track improvements), have a solid business plan, and RRIF includes a Credit Risk Premium and the ability to defer payment for up to 60 months, these projects still have trouble getting ficing through the RRIF. Thus we are left with the proverbial question of "Who came first, the chicken or the egg?" We suggest the Department establish an RRIF Microloan Revolving Loan Fund to serve as construction/bridge ficing for small entities and small projects (<$5M) that otherwise meet RRIF eligibility criteria. The duration of these loans would be for 24-60 months and convert into a traditional RRIF loan once the facility has been operational for two years and can cover loan payments. During this time the projects can go through the full underwriting process. Implementing a program such as this would instantly attract more small entity applicants to the RRIF program, fostering economic development, modal shift, and improve the movement of multimodal freight in the US.