The German Shippers Council said its members fear the planned P3 Network among the container carriers Maersk, MSC and CMA CGM "could lead to monopolistic market conditions and rising prices for the shippers."
The comments were part of a new batch of letters on the P3 alliance posted on the FMC's website.
Most of those comments were supportive of the P3, including letters sent by CSX, the Georgia Ports Authority, the American Maritime Officers union (whose members crew some Maersk Line Ltd. ships), and shippers such as Barnes and Noble.
The German Shippers Council, part of the Federation of German Industries or Budesverband der Deutschen Industrie (BDI), said that "setting up the P3 harbors the risk of bringing about considerable market shake-out affecting smaller shipping lines or ship owners" and that the move "put the P3 in a position to expand still more its already dominant market shares." It says these market shares amount to approximately 35 percent in the transatlantic, between 45 percent and 50 percent in Asia-Europe lane, and 29 percent in the transpacific.
It also said, "There is the expectation that P3 will be able to not only restrict competition by controlling capacity within the three partners but even beyond these three partners," giving as an example what it expects will be a deterioration in transit time on the P3 string between North Europe and Mexico, leading to reduced competition for Hapag-Lloyd.
The group acknowledged, however, there may be "limited advantages" to the P3 consortium, such as stabilization of service frequency. But it added, "Taking a long term view, the market power created by P3 can ultimately lead to deterioration in quality and service."
Another letter from Eni F.H. Faleomavaega, who represents American Samoa in the House of Representatives, said "the proposed alliance is a serious concern, particularly to the Asia Pacific region."
He said, "Careful consideration must be given this matter, and the process must be conducted in a way that facilitates and encourages comment." He even proposed "open hearings" by the FMC or Congress. He said, "As this issue has been raised with my colleagues, it has been apparent that key congressional leaders are not aware of what is taking place."
Among the concerns he raised was the ability of the P3 to "steer volume to family terminals, undermining other container terminals that must operate on high fixed costs and can ill afford any loss of volume."
Faleomavaega also said the "scale advantages" of the P3 "may force other container lines to form similar alliances to compete. This could drive further consolidation of the shipping industry.
"Ultimately, there is the possibility of having only two or three main alliances sharing the bulk of worldwide volumes. If regulators accept P3 today, would they also allow P3 to become P4, P5 or P6? How can regulators prevent the creation of a duopoly or collusive oligopoly on liner shipping, with a long-term increase in prices for shippers?"