ASLRRA to STB: No Uniform Service-Metrics Reporting
Written by Marybeth Luczak, Executive Editor
(TRRA SD60I. Photo: YouTube/BNSFguy617)
The American Short Line and Regional Railroad Association (ASLRRA) was among those responding to the Surface Transportation Board’s (STB) call for comments on issues regarding First-Mile/Last-Mile (FMLM) service; the deadline was Dec. 17.
In a Sept. 2 decision inviting comments, STB defined FMLM service as “the movement of railcars between a local railroad serving yard and a shipper or receiver facility. The Board seeks comment from the shipping community, carriers and the public concerning what, if any, FMLM issues they consider relevant. The Board also seeks comment on whether further examination of FMLM issues is warranted, and what, if any, actions may help address such issues, taking into account the information shippers already receive from carriers. The Board is particularly interested in knowing whether metrics to measure FMLM service that are not now being reported to the Board might have utility for the supply chain, and the potential burdens associated with any such reporting.”
The move was in response to various shipper groups within the past year raising “concerns to the Board about FMLM service and request[ing] greater transparency of FMLM data,” STB wrote. “In addition, in recent months, the Board has heard from various stakeholders regarding crew shortages and other issues stemming from the COVID-19 pandemic and worldwide supply chain complications, all of which have heightened the importance of the Board exploring FMLM service. As a result, the Board seeks comment on possible FMLM service issues, the design of potential metrics to measure such service, and the burdens associated with any suggestions raised by commenters.”
ASLRRA Responds
“As small local businesses that are generally focused entirely on the first and last mile of the shipment and that are dependent for survival on the business of generally a small number of customers, short lines provide flexibility and responsiveness to the unique needs of each customer,” ASLRRA General Counsel Sarah G. Yurasko told the STB in the association’s Dec. 16 response (download below). “Without providing flexible local service and working closely with their customers to provide high quality and cost-effective freight service, short line railroads would lose their business to other modes of transportation, most predominantly, trucking.”
Yurasko pointed out that “none of the commenters who brought FMLM concerns to the Board since the start of the COVID-19 global pandemic identified short line railroads as a cause of their concerns. Similarly, going back to the record of the STB Oversight Hearing on Demurrage and Accessorial Charges from May 2019, none of the concerns raised by shippers identified problems or challenges with their short line railroad service that needed fixing.”
Addressing the question of providing FMLM service metrics, Yurasko wrote that “[v]ariability in data collection, reporting systems, and abilities across the national network would result in inconsistent and nonmeaningful information for customers seeking to compare their service to others’.” She pointed to the Association of American Railroads’ Sept. 10, 2020 letter to the STB that said “the significant differences among railroads as to geography, network, customer base, traffic volumes, resources, and operating practices make fair comparisons of service data at the carload level impossible.” For short line railroads, she wrote, “capturing metrics to measure performance data ‘in the aggregate’ is made even more difficult by the fact that there are approximately 600 short line railroads and every short line captures that data somewhat differently.”
To determine how short lines capture service data and are responsive to customer concerns, ASLRRA surveyed a variety of members, Yurasko told the STB. The result: “Overall, short line railroads are very responsive to their customers and quickly address any identified service issues—that is in fact generally considered the very hallmark of short line service. While a number of short lines use various transportation management systems (“TMS”), our data gathering indicates that those who use a TMS do not all use these types of systems in the same way. For example, some railroads utilize the full suite of online asset management and metrics, others use only select functions of these type of programs to see only the information relevant to their particular operations, while others do not maintain any information in a TMS at all. This survey demonstrates that there is no single metric or set of metrics or data reporting process that would make sense for the STB to mandate of short line railroads.”
Yurasko also highlighted in the ASLRRA response how members—including Genesee & Wyoming, Watco, Pan Am Railways, OmniTRAX, Transtar, two Western Carolina Railway Service Corp. subsidiaries, and Terminal Railway Association of St. Louis—provide customer service. In sum, she wrote, their “service metrics are judged by customers daily, and any shortcomings are addressed and solved without delay. That daily interaction is the imperative of the short line marketplace and a new reporting requirement would not impact that imperative.”
Regarding the potential burden associated with reporting, Yurasko emphasized that “[m]ost short line railroads meet the definition of small businesses. On average, short line railroads employ fewer than 30 people, run an average of only 79 miles, and have $7.7 million or less in revenue. Most short line railroads must invest a minimum of 25% of their annual revenue back into their infrastructure, which is a percentage far higher than almost any other industry in the country. Further, although short line railroads participate in approximately 20% of all carload movements and have roughly 12% of the industry’s employees, they earn only approximately 6% of the revenue generated on the national rail system.”
In conclusion, Yurasko urged the STB “not to require short line railroads to create systems to track and report uniform metrics. Not only is it unclear what, if any, metrics are suggested or what, if any, benefits metrics would provide, the adverse effects of imposing such a mandate would be a serious financial blow to small railroads, and thus potentially to the customers that they serve. ASLRRA suggests that there is no indication that short line railroad FMLM service to short line customers is a problem that needs fixing, and also suggests that there is no particular set of data or metrics or particular tracking or reporting system that would be feasible or realistic to require of 600 different and distinct small businesses that are already laser focused on providing excellent customer service every day.”
