The National Grain and Feed Association (NGFA) on April 29 submitted reply comments to the federal Surface Transportation Board (STB) reiterating its strong support for the agency's proposal to require Class I rail carriers to permanently report certain rail service performance data on a weekly basis.
The STB's Dec. 30 proposal (EP 724, Sub-No. 4) would amend and make permanent its Oct. 8 order that required, on an interim basis, that Class I railroads and Class I railroads whose tracks transit or interchange traffic through Chicago file weekly rail service reports containing specific performance data. Currently, the STB requires 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.
In its reply comments, the NGFA opposed and refuted comments submitted by rail carriers that urged the STB to withdraw and abandon its proposal, and instead rely on only "macro-level reporting metrics" previously provided by railroads that proved insufficient to predict or monitor the serious degradation in rail service that occurred in 2013-14. Other railroads urged the STB not to act on grounds that their own company-specific service reporting to customers was sufficient to meet the needs of rail customers.
"Clearly, both approaches (suggested by the railroads) are grossly deficient and would not achieve the objectives clearly articulated by the (STB) and supported by rail customers in this rulemaking - namely, providing the agency with sufficiently precise, standardized and timely rail service performance data across different carriers to perform its proper oversight functions and provide rail customers with sufficient actionable information on which to adjust logistical plans in the event of a future significant disruption in rail service," the NGFA said in its reply comments to the STB.
Further, the NGFA said while it commended some carriers that have developed and implemented "robust, ongoing communications outreach and specific tools for use by their customers to monitor rail service performance, such systems were "far from universal across all carriers and have varying levels of capability and utility." Indeed, the NGFA added, one of the principal problems during the 2013-14 rail service meltdown was the "lack of systematic, ongoing, accurate communication from some Class I carriers with their customers - a repeated complaint of NGFA member companies."
The NGFA also opposed a proposal from the Association of American Railroads (AAR) that reporting of rail service performance data "should end once service returns to normal levels because they will not be relevant or useful to a future service disruption." To the contrary, the NGFA said, continuous reporting of service performance data is needed to allow the STB and rail customers to better identify and mitigate future regional or national service trends and detect disruptions more quickly, and assist government agencies in building a baseline of factual information on rail service performance that can be used as a barometer for comparative analysis to evaluate future trends. "There is no way to accomplish this core objective without having such data being collected, compiled and submitted in an ongoing, permanent and systematic basis," the NGFA said.
The NGFA's reply comments also encouraged the STB to retain its proposed requirement that sufficient commodity-specific reporting of rail service performance data be submitted by rail carriers, rather than the railroads' proposal to provide only generic "macro-level" reporting metrics limited to cars-on-line, train speed and terminal dwell times.
The STB now will consider the reply comments submitted in this proceeding and determine whether, and if so, when, to issue a final rulemaking on permanent rail service data reporting. (See earlier press release.)