The National Grain and Feed Association (NGFA) is strongly supporting the federal Surface Transportation Board's (STB) proposal to require Class I rail carriers to permanently report certain rail service performance metrics on a weekly basis.
Currently, the STB requires - on an interim basis - that the major rail carriers report, among other things, weekly average train speeds, weekly average terminal dwell times, weekly average cars online, the number of trains held short of destination or scheduled interchange points, and various loading metrics for grain, coal, automotive and other categories of service.
"We believe strongly that providing a more standardized, timely, user-friendly and permanent reporting of rail service performance data will be invaluable to rail users and their customers, as well as to the STB and other relevant policymakers," the NGFA said. "Access to such service metrics would facilitate shippers' and receivers' ability to better manage rail-dependent business obligations and operations in a more market-based and anticipatory manner than occurred during the severe service disruptions of 2013-14, when rail carriers clearly did not anticipate, communicate or respond well to service degradation."
The NGFA pointed out that while the most severe service disruptions have abated for the time being, there still is projected to be an extended period of freight transportation capacity challenges confronting multiple modes, including rail and motor carrier. "These expected capacity constraints necessitate the STB requiring Class I railroads to submit sufficient amounts and types of data to enable the agency, industry stakeholders and other policymakers to determine - in a highly concentrated rail marketplace characterized by regional duopolies in the East and West - whether and to what extent rail carriers are skewing their resource allocations (e.g., locomotives, crews, railcars and track investment) toward certain commodities that maximize their profits versus their traditional statutory obligation to provide reasonable service upon reasonable demand across all customer segments."
In its 10-page statement submitted this month, the NGFA commended the STB for proposing to expand and refine the rail service performance data that Class I rail carriers would be required to report, and recommended that the agency add several service metrics that would be useful to shippers and receivers of agricultural commodities and products. The NGFA also made several recommendations that would make the service performance data easier for rail users to access and analyze, including the following:
- Require that service data be delineated by all significant business segments served by rail, including grains, oilseeds and derived processed products; fertilizer; coal; crude oil; chemicals; intermodal; automotive and other relevant business categories of traffic.
- Require the Canadian National Railway Co. (CN) and Canadian Pacific Railway Ltd. (CP) to delineate separately - or in separate reports - their respective rail performance data associated with their U.S. and Canadian rail operations.
- Require data to be reported in a standardized format so it can be viewed and compared more easily, including through use of Excel spreadsheets, bar graphs or other standardized formats. Currently, carriers can - and most do - provide such data as PDF files that make the information difficult to compare and analyze across different carriers or different reporting time periods.
- Upgrade and reorganize the STB website to make the required rail service performance data easier to locate and utilize.
The NGFA generally supported each of STB's proposed changes concerning specific rail service performance metrics that Class I railroads would be required to report. These include: 1) system-average train speeds; 2) weekly average terminal dwell time; 3) weekly average cars in service; 4) weekly average dwell times at origin and interchange location (although NGFA proposed adding dwell time at destination to this metric); 5) weekly total number of loaded and empty trains held short of destination or scheduled interchange for longer than six consecutive hours, sorted by train type; 6) daily average of loaded and empty cars currently in service, including those loaded and billed to an origin or destination; 7) weekly total number of grain cars loaded and billed, reported by state and aggregated by Standard Transportation Commodity Codes (STCC) (e.g., corn, soybeans, soymeal, etc.); 8) total number of overdue orders, average number of days late, total number of new orders received during the previous week, total number of orders filled during the previous week, and number of orders canceled by the shipper and carrier, respectively, again aggregated by STCC commodity type; and 9) weekly total coal unit train loadings or car loadings for the reporting week by coal-reporting region.
But in each of these reporting categories, NGFA urged that carriers be required to report more granular data for each business traffic category, such as grains, oilseeds, crude oil, fertilizer, intermodal, autos, etc. In addition, in the case of car-order data, the NGFA also said the STB should consider whether to require "a modicum" of reporting by shortline railroads (which are excluded from the agency's current or proposed reporting), particularly those shortlines that haul significant quantities of commodities and products. Further, NGFA recommended that the STB add a requirement that Class I carriers submit summary data on "Industry Spot and Pull (ISP)" reports that most or all currently compile internally that provide a better reflection of the quality and consistency of service received at the facility level. These data would be useful to smaller shippers and grain processors that utilize manifest shipments.
The NGFA also recommended that the agency require carriers to submit data on velocity and cycle times for unit train shipments by traffic corridor (e.g., Pacific Northwest, Texas Gulf, etc.), again broken down by business traffic category.
Finally, the NGFA strongly supported the STB's proposal to require quarterly reporting by rail carriers of rail infrastructure projects amounting to $25 million or more. However, the association requested that the agency also require carriers to report any scheduled curfew hours on traffic movement affected by such infrastructure projects that could result in traffic stoppages or slowdowns on affected tracks.
The next step in this STB proceeding [EP 724, (Sub-No. 4)] is the filing of reply comments by April 29 in response to statements submitted by rail carriers and other parties.