Court of Appeals for the D.C. Circuit March 15, 2018, Civil Action No.: 16–1019 (RC) (Am. Great Lakes Ports Ass'n v. Zukunft)

RUDOLPH CONTRERAS, United States District Judge

I. INTRODUCTION

In 2016, the Coast Guard promulgated new rules for calculating the rates that international shippers must pay American maritime pilots on the waters of the Great Lakes. Throughout the notice-and-comment process, Plaintiffs-representatives of the international shipping community-criticized the proposed rules on a variety of grounds.