“When the facts change, I change my mind. What do you do, sir?” — John Maynard Keynes
When I was working at the Surface Transportation Board, I often felt trapped in a game of “Whack a Mole.” That was because STB rarely had time or staff to do more than react to the latest rate case, stakeholder petition or Congressional request. There is a sense of Whack a Mole in some of the flurry of STB regulatory reform proposals, particularly STB’s tinkering with the industry Cost of Capital calculation.
Recently, I purchased movie tickets on line. As I was checking out, I noticed I was getting charged a “convenience fee,” which for me begged the question: Just whose convenience? After all I was saving the theater the cost of printing the tickets and their employees’ time selling me the ticket. In my mind this convenience fee was really a profit center for the theater.
For a sleep inducer, consider working with the Uniform Rail Costing System (URCS), long a general costing system indispensable for determining maximum reasonable rail rates. Worse, its second side-effect is indigestion, as this 30-year-old accounting relic is much like a classic car lacking modern GPS and satellite radio. Practitioners too often become frustrated with its built-in averages from a time when railroads, rather than shippers, owned most of the freight car fleet and line hauls were shorter as the modern merger movement had not yet run its course.
Surface Transportation Board (STB) staff recently released a rate reform report with a series of recommendations. Readers should remember that before any of those recommendations become regulations, the Board must conduct rulemakings. This process could extend beyond 2020 and into the next Administration.
