Several coal shipper groups on Dec. 23 filed joint comments with the U.S. Surface Transportation Board urging that the board impose their suggested data collection rules that are designed to improve rail system performance.
Much of U.S. coal production moves via rail to customer power plants, including coal moving via the originating BNSF Railway and Union Pacific railroads out of the Powder River Basin of Wyoming and Montana.
The Western Coal Traffic League (WCTL), American Public Power Association (APPA), National Association of Regulatory Utility Commissioners (NARUC), National Rural Electric Cooperative Association (NRECA), Edison Electric Institute (EEI) and Freight Rail Customer Alliance (FRCA) filed the comments.
Following the comments in this case filed on March 2 and April 29 by these groups, called the “Coal Shippers/NARUC,” the U.S. Department of Agriculture (USDA), other interested shipper groups, the Class I railroads, and the Association of American Railroads (AAR), the board requested that interested parties meet in person with board staff to discuss their specific data reporting proposals and answer questions from the staff.
Coal Shippers/NARUC representatives met with the board staff on Nov. 19. The USDA, other shipper groups, the AAR, and certain Class I railroads had similar meetings in the days that followed. On Dec. 16, the board requested that interested parties file written comments addressing the summaries by Dec. 23.
In their March 2 and April 29 comments in this proceeding, Coal Shippers/NARUC urged the board to adopt their proposed data collection plan with certain modifications and additions. Specifically, Coal Shippers/NARUC asked the board to:
- Modify its proposal so that carriers report interchange dwell times at each of their 10 largest interchange locations;
- Modify its proposal so the “Other” category in the train held short reporting is more specific;
- Modify its proposal to retain the weekly coal loadings versus plan reporting currently in effect under an Interim Data Order;
- Expand its proposal to include weekly average cycle times for coal trains over any portion of the carrier’s ten (10) most frequently used coal train corridors (e.g., Powder River Basin mines to Kansas City);
- Expand its proposal to include the weekly average number of coal trainsets in service broken down between shipper-supplied (private trainsets) and carrier-supplied trainsets;
- Expand its proposal to include any restrictions on the utilization of shipper-provided equipment in coal service;
- Expand its proposal to include general restrictions on the availability of crews for coal service; and
- Expand its proposal to include general restrictions on the availability of locomotives for coal service.
During the meeting with board staff, the staff raised several questions regarding the mechanics of Coal Shippers/NARUC’s proposed modifications and additions, including questions about measuring cycle times versus transit times and planned coal loadings versus actual coal loadings. In each instance, Coal Shippers/NARUC provided their feedback on the specific service metrics that the railroads should report, the mechanics of such reporting, and the importance of that data to Coal Shippers/NARUC’s stakeholders.
Coal Shippers/NARUC, therefore, said they continue to assert that such reporting is not only possible, but vital. Thus, Coal Shippers/NARUC urge the board to include their proposed additions and modifications in its supplemental Notice of Proposed of Rulemaking (NPRM) with further revisions as reflected in the summary of the Coal Shippers/NARUC meeting (i.e., transit times versus cycle times, a yes or no option for shortages of crews and locomotives, etc.).
Through their meetings, USDA and other shipper groups continued to urge the board to adopt its NPRM, and most continued to propose additional metrics that the Class I railroads should report, including commodity-specific reporting for a number of metrics. Coal Shippers/NARUC have no comments at this time with respect to the specific issues raised in those meetings. However, Coal Shippers/NARUC noted that the clear and continued interest of USDA incontrovertibly demonstrates that if such metrics are valuable to a federal cabinet-level department seeking to carry out its duties, such data should be equally, if not more, valuable to the board and the shipping community.
The Class I railroads’ and the AAR’s meeting summaries indicate that the carriers continue to strongly resist all but the most basic system-level reporting (e.g., velocity, terminal/system dwell, and cars online). The carriers also suggest that (i) commodity-level and/or granular-level data would somehow muddy the picture of how their railroads are performing vis-à-vis the system-level metrics; (ii) that differences between railroads somehow diminishes the value of such data; and (iii) that reporting such data might impose unquantified and unexplained burdens on the railroads. “Coal Shippers/NARUC continue to disagree with the carriers on all three points,” they added.
They concluded: “Coal Shippers/NARUC again urge the Board to adopt the performance data reporting proposal with the modifications that Coal Shippers/NARUC proposed in their Opening and Reply Comments, with modifications as necessary based on their meeting with Board staff.”
Union Pacific responds to points raised by coal shippers
The Union Pacific said in its own Dec. 23 fling that it disagrees with WCTL’s request for reporting of cycle times over 10 key coal corridors.
“First, WCTL’s criticism of train speed (aka velocity) relative to cycle time was either mistaken or misleading,” said the railroad. “Union Pacific coal train velocity does reflect stop and hold time between terminals. While velocity does not include unloading or loading time, and cycle time does, unloading and loading time are not the responsibility of a railroad and therefore do not reflect railroad performance. For the same reason, there can be no meaningful calculation of cycle time by coal corridor. With perhaps one exception, no Union Pacific coal trains are loaded and unloaded on the same corridor. Most coal trains run from one segment to the next. The calculation of cycle time on a coal corridor could only be attempted when a coal train terminates and is unloaded along a corridor. However, if unloading time for such trains is excluded, then the result is transit time which does not satisfy WCTL’s request for cycle time because the transit time would not reflect unloading. But if the unloading time for trains to that destination is included, the result will make it appear that the running time for all coal trains moving beyond that corridor are slower than reality.
“Second, coal customers already know their specific ‘all-in’ cycle times for each of their plants which includes time spent loading and unloading a train. This number is typically more relevant to coal customers in planning because it provides the whole picture of equipment utilization.
“Third, Union Pacific does not have 10 key coal corridors that it could report on without potentially revealing sensitive customer information. Union Pacific’s largest coal routes run between the Powder River Basin area of Wyoming to Kansas City and through Omaha/Council Bluffs to Chicago. As coal trains move beyond those points, they disperse often with only one or very few customers’ trains moving over the next segment. If information on these lower density coal routes is publicly reported, it might be possible to determine commercially sensitive information about the customers whose trains operate over these routes.”