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Take all the proposed legislation, mix 'em together, and you almost have Open Access!

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Posted by greyhounds on Thursday, March 16, 2006 9:09 PM
QUOTE:
The presumably sane people at AAR, STB and even at GAO, routinely calculate the average revenue received per ton-mile received by American railroads on an annual basis.


This has absolutely nothing to do with allocating fixed costs, something that is not possible to do in any meaningful way. But hey, it makes a good line of lawyer BS. They calculate an average? So what? This is just some name dropping of organizational initials in an attempt to attempt to legitimize an illigitimate argument.

QUOTE:
Fixed costs were substantially divorced from variable costs.


They still are - you're using the wrong verb tense. If a cost varies with the level of business, it's not a fixed cost. Of course, an enterprise can take on additional fixed cost to increase capacity. Such as laying a third track through Nebraska. But once they've done that, the cost of owning that track is 'fixed'. It's called 'investment' or 'capital expenditure' or whatever. Once you make that decision, you've got a new, increased, but entirely "fixed" cost to cover.

QUOTE:
Today, with very large transactional organizations operating near or at capacity, the old rate reasoning is no longer true.


"Transactional Organizations"? OK, what's a "Non-Transactional Organization" in a railroad context? One that doesn't haul things and send out bills for doing so? You're laying out a line of total BS. "Transactional Organizations" my left foot. The Methodist Church is a "Transactional Organization". They buy Hymnals and such. Railroads have been "Transactional Organizations" from the get go. For that matter, so has the Methodist Church.

You're using phrases that some people aren't familiar with in an effort to convince them that you know what you are talking about. It's like you're trying to impress people by using big words. It isn't working.

QUOTE:
In any case, the 180% variable cost thresh-hold of rate reasonableness is based precisely on just such an allocation of fixed and variable costs for the average freight movement, and even though Greyhounds insists that it's "bogus," the rest of the rail industry recognized the usefulness of just such an allocation over two decades ago, and it is, in fact, part and parcel of the legislation that governs the industry today.


And why is that? If 180% of variable cost is based on an allocation, as you falsely claim, and it supports the falicy of allocating fixed costs, as you falsely claim, then what would a 170% of variable cost standard imply?

They don't seem to have mentioned fixed cost allocation. They put a cap on rail rates at 180% of variable cost - and you stoop to use that as a justification for fixed cost allocation. Again, where is their mention of fixed cost allocation. It seems they didn't deal with that - probably because it's bogus.

But you use it to promote some entirely wierd political agenda that has no freaking basis in reality.

I don't know what you're going for, but whatever it is, it doesn't seem to involve reality or truth. Maybe you like the arguments? Maybe you're seeking that status of "an authority" that has otherwise escaped you?

But anyone who can get out here and claim that: 1) fixed costs can be meaningfully "allocated", or 2) the Milwaukee Road was in receivership because "it had too much business", is, in my humble opinion, not dealing from a full deck.

And you've done both those things.
"By many measures, the U.S. freight rail system is the safest, most efficient and cost effective in the world." - Federal Railroad Administration, October, 2009. I'm just your average, everyday, uncivilized howling "anti-government" critic of mass government expenditures for "High Speed Rail" in the US. And I'm gosh darn proud of that.
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RE
Posted by MichaelSol on Thursday, March 16, 2006 11:40 PM
QUOTE: Originally posted by MP173

So, are you saying MIchael, that the establishment of 180% of variable costs are based on average costs?

Having had a background in transporatation pricing, I would think the 180% threshold would be based on actual costs of the movement, not just averages.

The actual costs can very easily be determined, based on cost accounting data, including switching costs, linehaul, transfer costs in yards, etc.

The formula was derived based on an assessment of averages or, if you like, a non-linear regression of a series of analytical exercises of fixed and variable costs. Like any algorithm or mathematical equation, the result obtained is then applied substituting actual numbers relevant to the individual situation and comparing those to the hypothetical 180% derived from known numbers or averages of those numbers. Note that the 180% of the variable cost of service is 180% of whatever the variable cost of service actually is: that is exactly your "actual cost of movement." There is nothing hypothetical about that part: the variable costs of the service are the actual variable costs of service, case by case.

And you can't read a precision into the 180% threshold that is not intended to be there. It is the point at which the burden of proof ostensibly shifts under the legislation -- although the Federal Courts have considerably altered that Congressional guideline. It is possible for the railroad company to prove, above the 180% threshold, that its fixed costs exceed the proportion included in the base assumption of 180%. Variable costs, of course, can't be any different under that assumption than the 100% of variable costs implicit therein. Only fixed costs can meet or rebut the presumption. That's how the formula works. And those have to be "allocated" otherwise the formula makes no sense at all.

As it is, 100% of variable costs is about as far as you can go with variable costs in that formula. 100% is 100%. You just can't get any more variable costs than 100% of them.

Anything above that has to be something else. Fixed costs and profit are about all that is left to consider.

However, at an "average," presumably of line haul, rate, train size, etc, 180% of the variable cost of service defines the combination of operating costs, variable and fixed, below which the railroad's rate is presumed "reasonable".

Now, the question might be, and I think it answers the proposition of the other gentleman that believes everyone is a troll, has a political agenda, or is not dealing from a full deck if they disagree with him, if the 180% variable cost of service threshold is not specifically designed to set "rate reasonableness" -- and rates must cover fixed costs, variable costs, plus profit exactly what, then, does that 180% threshold suggest as a mandated reasonable rate standard?

Congress could have said, rate reasonableness occurs when rates "1) cover all of the variable costs of the service, 2) covers the proportionate fixed costs allocated to the service, and 3) promises a ___% return on investment to the railroad."

Congress didn't do that.

It didn't say "100% of the variable costs of the service, plus more,' instead it set "180% of the variable cost of the service" as the threshold for rate reasonableness. You might suspect that there was a specific calculation involved, regarding an average allocation of fixed costs and profits, that was utilized in arriving at that percentage and that it was not merely a random act of Congress that threw a dart, missed 170% and 190%, and just happened to hit 180%. Indeed, the legislative history will show that the railroads objected to the originally proposed 160%, based on their argument that their fixed costs were a higher percentage of the total costs, justifying the 180% figure instead.

Indeed, it is the difficulty of allocating fixed costs on a case by case basis that is the reason for the variable cost formula, based on studies and averages of such costs and their relationship to variable costs.

It is only a footnote that some are attempting to now argue on this thread that rates measured by that variable cost reference are not designed to cover variable costs, fixed costs, and generate a profit. Yet, that position has to beg the question in rational minds as to why Congress saw fit to set rate reasonableness solely on the basis of a percentage of variable costs of service, if that percentage did not also include a provision of payment of fixed costs and a reasonable rate of return to the railroad company.

It seems odd to have to point out that the 180% variable cost threshold is considerably above the actual variable cost (100%) and if that additional "80%" does not or cannot be meant to cover fixed costs and provide a profit, then what is it designed to do?

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Posted by bobwilcox on Friday, March 17, 2006 5:51 AM
QUOTE: Originally posted by MichaelSol

It seems odd to have to point out that the 180% variable cost threshold is considerably above the actual variable cost (100%) and if that additional "80%" does not or cannot be meant to cover fixed costs and provide a profit, then what is it designed to do?

Best regards, Michael Sol




The threshold is not a germaine issue to anything except who has the burden of proof in a rate case.

Having put together many price/service packagers for chemical companies the issue never came up! Equally customers never brought brought up the threshold as we negotiated the deal. Even though they ran varible cost estimates on every significant move they did not find the issue important enough to put on the table. These contracts ranged up to $50 million in value.
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Posted by MichaelSol on Friday, March 17, 2006 8:38 AM
QUOTE: Originally posted by bobwilcox
The threshold is not a germaine issue to anything except who has the burden of proof in a rate case.

If someone has not understood by now that it represents a change in the burden of proof, then they haven't been reading. And the burden of proof shifts, of course, at that particular point for a particular reason.

One side of the percentage represents a non-rebuttable presumed reasonable rate of return and coverage of costs; the other side of the percentage does not enjoy the presumption. Since the legislation specifically identifies the percentage as a threshold of rate reasonableness, it is quite germane to the issue of rate reasonableness --hence the millions and millions of dollars spent on rate cases with that percentage as a central element. Congress said it was germane, and Congress retains the authority to decide that its not germane.

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Posted by CSSHEGEWISCH on Friday, March 17, 2006 10:20 AM
I've brought up this issue previously, and it seems to have been sidestepped or ignored at the time. Any discussion of "open access" also has to consider labor's point of view on the matter. I would think that it would be viewed primarily as a union-busting tactic, and not without cause, considering Springfield Terminal with Guilford and the Winona Bridge RR proposal by BN. "Open access" is going to be difficult if not impossible to implement witihout bringing labor into the discussion. FM may find this fact difficult to deal with, but it needs to be addressed.
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Posted by bobwilcox on Friday, March 17, 2006 10:41 AM
QUOTE: Originally posted by CSSHEGEWISCH

I've brought up this issue previously, and it seems to have been sidestepped or ignored at the time. Any discussion of "open access" also has to consider labor's point of view on the matter. I would think that it would be viewed primarily as a union-busting tactic, and not without cause, considering Springfield Terminal with Guilford and the Winona Bridge RR proposal by BN. "Open access" is going to be difficult if not impossible to implement witihout bringing labor into the discussion. FM may find this fact difficult to deal with, but it needs to be addressed.


In the 20th century if you wanted to make major regulator changes two out of three groups had to sign up. The groups were rail management, rail shippers and the Brotherhoods.

The last time open access changes were given serious debate was just after the UP+SP merger fiasco. Rail managements were against open access, rail shippers were for open access on a Candian model and the Brothers were on the fence. Rail magement offered and end to merger cram downs and the Brothers came out very strongly against open access. They said open access would transfer money from the rail companies to shippers. Suprise! The Brothers perfer to see some of that money transferred to their members pockets.
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Posted by edblysard on Friday, March 17, 2006 2:31 PM
Precisely, Mr. Wilcox...thank you.

We are not a public utility.

We are a business, and the employees do prefer that some of the money end up in their pockets...

Now, of course, FM or M Sol will whip out their version of the common carriers act....and try and convince us it is a duty to offer un-profitable service under the law...or argue there is a moral obligation to provide service...
Ed

23 17 46 11

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Posted by MichaelSol on Friday, March 17, 2006 3:10 PM
QUOTE: Originally posted by edblysard

Precisely, Mr. Wilcox...thank you.

We are not a public utility.

We are a business, and the employees do prefer that some of the money end up in their pockets...

Now, of course, FM or M Sol will whip out their version of the common carriers act....and try and convince us it is a duty to offer un-profitable service under the law...or argue there is a moral obligation to provide service...
Ed

An interesting perspective. The UTU complained in its October 20, 2005 newsletter that Staggers Act deregulation of railroads in the United States had occured "on the backs of the employees," that "Deregulation Shortchanged Employees."

Employees are complaining of long hours and unsafe conditions. There were 428,583 Class I employees in 1980, earning (in 2004 dollars) an average of $76,516 per year. Now there are less than 157,699 employees, and they earn an average (2004 dollars) of $65,550 per year.

When do the employees get that money "in their pockets"? I guess the "Brothers" are a pretty sharp bunch. Perhaps they are honoring a moral obligation to the railroads?

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Posted by MP173 on Friday, March 17, 2006 3:40 PM
I think that money went to the shippers in the form of reduced rates.

Not just in the railroad industry, but also trucking. I talked to a CEO client of mine today (very successful trucking company) and he indicated the shippers are feeling quite a bit more frisky these days and are putting pressure on reducing freight charges....this is the first time in about 2-3 years per my client.

ed
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Posted by MichaelSol on Friday, March 17, 2006 3:53 PM
QUOTE: Originally posted by MP173

I think that money went to the shippers in the form of reduced rates.

Not just in the railroad industry, but also trucking. I talked to a CEO client of mine today (very successful trucking company) and he indicated the shippers are feeling quite a bit more frisky these days and are putting pressure on reducing freight charges....this is the first time in about 2-3 years per my client.

ed

Of course, BobWilcox above said that it was Open Access, not Deregulation, that would "would transfer money from the rail companies to shippers. Surprise! The Brothers perfer to see some of that money transferred to their members pockets."

I guess the surprise is on somebody, apparently on the employees as the preceeding comments suggest that neither of the gentlemen commenting are aware of what actually happened, although Bob has specifically acknowledged that it was a "race to the bottom" as far as railroad rates were concerned, a point I agree with entirely.

The puzzling part is that while he states that the fear was that it would happen under Open Access, he acknowledges this actually did happen under Deregulation. And both of these gentlemen insist that Open Access would have been detrimental to employees, whereas because Deregulation actually did substantially hurt employees, it remains the better alternative!

And look to CSSHEGEWISCH above: now we see that open access was a "union-busting" tactic! Cutting employee (union) numbers by two-thirds and cutting wages to 85% of their former levels, in his world, is not.

To me, this collision of facts with the contentions of these gentlemen underscores an ongoing unreality of what passes for discussion on these forums. At the most fundamental level, these gentlemen don't even know or understand what actually happened under Deregulation, as the above exchange conclusively shows. Yet each pretends to offer informed opinions on the topic.

Your comment is interesting, however, from the standpoint of the rail industry coming off of its contracts with an expansionist attitude that now they can raise rates, but shippers apparently feeling somewhat differently, at least those dealing with the trucking industry.

Might be interesting tmes ahead.

Best regards, Michael Sol

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Posted by Anonymous on Friday, March 17, 2006 8:56 PM
QUOTE: Originally posted by CSSHEGEWISCH

I've brought up this issue previously, and it seems to have been sidestepped or ignored at the time. Any discussion of "open access" also has to consider labor's point of view on the matter. I would think that it would be viewed primarily as a union-busting tactic, and not without cause, considering Springfield Terminal with Guilford and the Winona Bridge RR proposal by BN. "Open access" is going to be difficult if not impossible to implement witihout bringing labor into the discussion. FM may find this fact difficult to deal with, but it needs to be addressed.


I have addressed this issue in the past, and (suprise, suprise) I mostly agree with your assessment of labor's ostensibly disdainful view of OA, precisely because it might allow non-union transporters to enter a heretofor solid union shop.

That's not to say it has to be that way. If OA is mandated from the federal level, it is highly possible that a prevailing union contract might have to be upheld, even by so-called non-union operators. Kind of like a Davis-Bacon Act for railroad transport employees. Remember, OA would have to win the support of pro-labor politicians as well as pro-shipper politicians to have a chance of being implemented.

The best example of why fears of non-union railroaders applying downward pressure on wages and benefits might be nothing more than unfounded hyperbole is to look at the trucking industry, which has both union and non-union drivers. So far, the presence of non-union drivers hasn't had a negative effect on union drivers, for the reason that the trucking industry is in constant demand for qualified drivers. It is doubtful there will ever be a situation of too many drivers, and the same can probably be said for an OA railroad system, e.g. demand for quality railroad employees will always keep it a seller's labor market, unless the macro rail industry contracts instead of constantly expanding.
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Posted by Anonymous on Friday, March 17, 2006 9:17 PM
QUOTE: Originally posted by daveklepper

How could trucking be restricted to its natural short-haul market when most analysists that have any impartiality at all write that trucking pays onlly one-third to one-half the costs trucking imposes on the highway system? And on top of that the truckers get the highway without paying any real estate taxes on the land the highways occupy while railroads pay real estate taxes on their rights of way?

But traffic is returning to the railroads because of highway congestion and lack of qualified drivers. But I am not sure that open access would, in the long run, result in the inequities being any less than they are now, just different, nor the traffic greater, in the long run. Unless increased subsidy of railroads in one way or another is part of the open access arrangement.


The idea that trucking only pays "one-third to one-half the costs" of their *actual* road damage is a fallacy. It makes no sense to include city streets, country roads, commuter lanes, bike paths, etc. in determining an actual allocation of the costs imposed by trucks on cross country highways. If we limit said highways to only those actually used for interstate transportation, then truckers do pay their fair share of road costs.

That's only logical when we are trying to compare truckers' ROW costs vs railroad ROW costs. We shouldn't even count short haul trucker's road damage, because there is no railroad equivelent of a local distribution network. The railroads are totally dependent on trucks to get the goods from the point of origin and/or to the final destination, for all but maybe coal.

If it was cheaper for trucks to haul over the highway rather than by TOFC, there would be no such thing as TOFC. The only times trucks go over the road is because there is no TOFC service being offered for that particular point to point haul. Since TOFC exists, it must mean that the costs truckers pay to use highways are higher than the costs to use the railroad. Assuming the railroads are charging a rate that covers their variable costs, an allocation of fixed costs, and some level of profit (which is debatable), then even the one true inequity between truckers and railroads (e.g. the fact that railroads pay property taxes on the ROW) does not amount to all that much comparitively.

Could it be that (from a purely interstate highway perspective) truckers are actually paying more than their fair share of highway costs?
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Posted by Anonymous on Friday, March 17, 2006 10:16 PM
Not an expert, but it appears to me that there's been a bloodletting of union truckers in recent years. Their cost structure has been too high as in other businesses, and they haven't had gov't regulation to keep lower cost/better service competitors or divisions from serving customers.
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Posted by MP173 on Friday, March 17, 2006 10:33 PM
Union truck drivers typically are Teamsters and are usually in the LTL industry, UPS, or perhaps private fleets that are unionized.

LTL trucking over the past 25 years has come under tremendous pricing pressure due to the deregulation of the industry and the developement of non union carriers such as the Conway system, Overnite, and several others.

Now, with Yellow Freight beginning to accumulate market share thru recent acquisitions of Roadway and the USF system of regional carriers, it will be interesting to see if LTL rates climb. I think the rates will indeed move higher. Truckload, which is probably close to 100% non union is going to be much more dependent on the availability of drivers. A very strong economy strengthens the rates for truckload carriers in a couple of ways...more freight being handled pushes up the rates, plus more drivers will go to the union LTL jobs as the economy expands due to higher overall pay and better work conditions, thus reducing the number of drivers available and reducing capacity.


Right now, despite what the economists say, freight is beginnign to soften and shippers sense this, thus putting their freight up for bid. They dont do this unless they know their rates will go down. You are hearing it here first...the economy is softening.

How this will pan out with the big shippers and the rails is beyond my abilities, but remember this...dont ever feel too sorry for the shippers, they will carve up any carrier they can...it is their job. Thus, I find their cries for rail re-regulation extremely interesting ... they have lost control, at least for now.

ed
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Posted by Anonymous on Saturday, March 18, 2006 2:01 AM
QUOTE: Originally posted by futuremodal

The idea that trucking only pays "one-third to one-half the costs" of their *actual* road damage is a fallacy. It makes no sense to include city streets, country roads, commuter lanes, bike paths, etc. in determining an actual allocation of the costs imposed by trucks on cross country highways. If we limit said highways to only those actually used for interstate transportation, then truckers do pay their fair share of road costs.

That's only logical when we are trying to compare truckers' ROW costs vs railroad ROW costs. We shouldn't even count short haul trucker's road damage, because there is no railroad equivelent of a local distribution network. The railroads are totally dependent on trucks to get the goods from the point of origin and/or to the final destination, for all but maybe coal.

If it was cheaper for trucks to haul over the highway rather than by TOFC, there would be no such thing as TOFC. The only times trucks go over the road is because there is no TOFC service being offered for that particular point to point haul. Since TOFC exists, it must mean that the costs truckers pay to use highways are higher than the costs to use the railroad. Assuming the railroads are charging a rate that covers their variable costs, an allocation of fixed costs, and some level of profit (which is debatable), then even the one true inequity between truckers and railroads (e.g. the fact that railroads pay property taxes on the ROW) does not amount to all that much comparitively.

Could it be that (from a purely interstate highway perspective) truckers are actually paying more than their fair share of highway costs?


Why would you not include city streets or country roads? That makes no sense, even more so when you consider that often times these routes are the only access points to many industries for OTR trucks. To factor in just the interstate highways would be doing nothing but turn the trucking industry into the railroad industry.

Since OTR trucks have access to most any road, on a local delivery basis, they have the most open access of any transportation mode available. The problem is, it doesn't make much sense to put one or two drivers in front of one container, when you could put two in front of a hundred. That is unless the two that are in front of a hundred aren't going anywhere soon.

Another problem facing the trucking industry is just plain finding drivers to drive the trucks. If a driver isn't going to make money without half killing themselves, killing someone else, or running the risk of fines, they just won't do it. With the new government regulations affecting the on and off duty hours, a driver would have to break the law to make what they did in the past, it would seem to me.

Also, how much fuel would it cost a trucking company to haul 100 containers as opposed to a railroad hauling the same thing over a given distance?
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Posted by MichaelSol on Saturday, March 18, 2006 11:29 AM
QUOTE: Originally posted by NS2317
Why would you not include city streets or country roads? That makes no sense, even more so when you consider that often times these routes are the only access points to many industries for OTR trucks. To factor in just the interstate highways would be doing nothing but turn the trucking industry into the railroad industry.

Since OTR trucks have access to most any road, on a local delivery basis, they have the most open access of any transportation mode available.

Wow, this turns the theory upside down. One of the key points of Open Access is that users or beneficiaries can tap into the system but provide supporting transportation structure and overhead at their own cost, rather than imposing those costs on the OA system. That's exactly what cities, towns and counties do. Naturally, those costs are not factored into an OA cost study -- they are not part of the specific cost structure. Railroads use the same system for intermodal. Do railroads go out and factor in the cost of maintaining the streets and highways as part of their rate structure? No, it's just not part of their rate structure except in the tangential way that we all support those transportation systems as users and beneficiaries -- property, sales and income taxes and that varies considerably locality by locality.

For use of the Open Access Interstate Highway System, trucks pay the diesel tax of 24.4 cents per gallon, whereas the average automotive user pays only 18 cents per gallon (the gasoline tax rate). In addition, truckers pay a tire tax. The tire tax for tires between 40 and 70 pounds is 15 cents per pound, 70-90 pounds, $4.50, plus 30 cents per pound over 70 pounds, and $10.50 per tire over 90 pounds, plus 50 cents per pound for each pound over 90 pounds.

In addition, a 12% federal sales tax is assessed against the retail price of all truck trailers, and a heavy vehicle "use" tax is levied annually of $22, and for trucks over 55,000 pounds, the rate is $110 plus $22.00 for each 1,000 pounds over 55,000 pounds.

Passenger vehicles, which account for 93 percent of total highway travel, pay 64 percent of total Federal highway user fees. Combination trucks, on the other hand, pay over 25 percent of total highway user fees even though they travel less than 5 percent of total mileage. Among the truck classes, user fees vary substantially by vehicle weight. Single unit trucks registered at 50,000 pounds or more pay 2.5 times as much per mile in Federal user fees as single unit trucks registered at 25,000 pounds or less.

According to the 2003 Oregon Highway Cost Allocation Study, "under existing tax rates and fees, light vehicles are projected to to underpay their [allocated share of] responsibility by 0.8%, and heavy vehicles are expected to exceed their projected allocated share of responsibility by 1.6%."

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Posted by Anonymous on Saturday, March 18, 2006 12:03 PM
QUOTE: Originally posted by tomtrain

Not an expert, but it appears to me that there's been a bloodletting of union truckers in recent years. Their cost structure has been too high as in other businesses, and they haven't had gov't regulation to keep lower cost/better service competitors or divisions from serving customers.


Remember, trucks pay a higher labor rate per unit of cargo than railroads. You basically have one unit of labor per 35 tons (max) for trucks, whereas railroads (counting all "hands on" units of labor to make up a typical train) might use at most 10 units of labor per 3500 tons (minimum), or 350 tons per unit of labor. That's 10 times the labor efficiency at a minimum, and the average is probably even greater. Thus, to continue having a total unionization of OA rail transporters will not make that much of a dent in profit potential vs non-unionization of OA rail transporters, so what would be the point in trying to bust up unionization of railroaders for the sake of establising OA? That's why I would not oppose an OA Davis-Bacon type of requirement for OA transporters, at least on the cost side.

So, though it may be true that union truckers might start feeling the pressure of non-union hires when and if the economy starts to slow, since there is no cost reason to try to de-unionize railroad transporters under OA there would be no real effect on union railroaders during economic slowdowns if the Davis-Bacon approach is used.
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Posted by Anonymous on Saturday, March 18, 2006 12:40 PM
QUOTE: Originally posted by MichaelSol

Passenger vehicles, which account for 93 percent of total highway travel, pay 64 percent of total Federal highway user fees. Combination trucks, on the other hand, pay over 25 percent of total highway user fees even though they travel less than 5 percent of total mileage. Among the truck classes, user fees vary substantially by vehicle weight. Single unit trucks registered at 50,000 pounds or more pay 2.5 times as much per mile in Federal user fees as single unit trucks registered at 25,000 pounds or less.



Using this, is it safe to say that there are 9 passenger vehicles for every combination truck?

If so, give those 9 autos an average weight of 3087lbs each, and the combination vehicle an average 70,000lbs. That single combination vehicle is still two and a half times the weight of those nine automobiles.

BTW, while I did find the average automobile weight, I could not find the average combination vehicle weight.
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Posted by MichaelSol on Saturday, March 18, 2006 1:38 PM
QUOTE: Originally posted by NS2317

QUOTE: Originally posted by MichaelSol

Passenger vehicles, which account for 93 percent of total highway travel, pay 64 percent of total Federal highway user fees. Combination trucks, on the other hand, pay over 25 percent of total highway user fees even though they travel less than 5 percent of total mileage. Among the truck classes, user fees vary substantially by vehicle weight. Single unit trucks registered at 50,000 pounds or more pay 2.5 times as much per mile in Federal user fees as single unit trucks registered at 25,000 pounds or less.



Using this, is it safe to say that there are 9 passenger vehicles for every combination truck?

No.

Commercial vehicles generally are on the road. Automobiles generally sit in garages or parking lots. Relative highway mileage would be a poor measure of vehicle numbers. A commercial truck might easily do 200,000 miles per year, although the average is probably closer to 60,000 miles annually. According to the EPA, the average American automobile travels about 12,500 miles per year.

Additionally, when they are moving, the over-the-road trucks spend more time proportionately on highways, whereas automobiles no doubt spend more time proportionately off the highways, on streets and other roads.

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Posted by greyhounds on Saturday, March 18, 2006 2:08 PM
QUOTE: Originally posted by MichaelSol

The formula was derived based on an assessment of averages or, if you like, a non-linear regression of a series of analytical exercises of fixed and variable costs. Like any algorithm or mathematical equation, the result obtained is then applied substituting actual numbers relevant to the individual situation and comparing those to the hypothetical 180% derived from known numbers or averages of those numbers. Note that the 180% of the variable cost of service is 180% of whatever the variable cost of service actually is: that is exactly your "actual cost of movement." There is nothing hypothetical about that part: the variable costs of the service are the actual variable costs of service, case by case.

And you can't read a precision into the 180% threshold that is not intended to be there. It is the point at which the burden of proof ostensibly shifts under the legislation -- although the Federal Courts have considerably altered that Congressional guideline. It is possible for the railroad company to prove, above the 180% threshold, that its fixed costs exceed the proportion included in the base assumption of 180%. Variable costs, of course, can't be any different under that assumption than the 100% of variable costs implicit therein. Only fixed costs can meet or rebut the presumption. That's how the formula works. And those have to be "allocated" otherwise the formula makes no sense at all.

As it is, 100% of variable costs is about as far as you can go with variable costs in that formula. 100% is 100%. You just can't get any more variable costs than 100% of them.

Anything above that has to be something else. Fixed costs and profit are about all that is left to consider.

However, at an "average," presumably of line haul, rate, train size, etc, 180% of the variable cost of service defines the combination of operating costs, variable and fixed, below which the railroad's rate is presumed "reasonable".

Now, the question might be, and I think it answers the proposition of the other gentleman that believes everyone is a troll, has a political agenda, or is not dealing from a full deck if they disagree with him, if the 180% variable cost of service threshold is not specifically designed to set "rate reasonableness" -- and rates must cover fixed costs, variable costs, plus profit exactly what, then, does that 180% threshold suggest as a mandated reasonable rate standard?

Congress could have said, rate reasonableness occurs when rates "1) cover all of the variable costs of the service, 2) covers the proportionate fixed costs allocated to the service, and 3) promises a ___% return on investment to the railroad."

Congress didn't do that.

It didn't say "100% of the variable costs of the service, plus more,' instead it set "180% of the variable cost of the service" as the threshold for rate reasonableness. You might suspect that there was a specific calculation involved, regarding an average allocation of fixed costs and profits, that was utilized in arriving at that percentage and that it was not merely a random act of Congress that threw a dart, missed 170% and 190%, and just happened to hit 180%. Indeed, the legislative history will show that the railroads objected to the originally proposed 160%, based on their argument that their fixed costs were a higher percentage of the total costs, justifying the 180% figure instead.

Indeed, it is the difficulty of allocating fixed costs on a case by case basis that is the reason for the variable cost formula, based on studies and averages of such costs and their relationship to variable costs.

It is only a footnote that some are attempting to now argue on this thread that rates measured by that variable cost reference are not designed to cover variable costs, fixed costs, and generate a profit. Yet, that position has to beg the question in rational minds as to why Congress saw fit to set rate reasonableness solely on the basis of a percentage of variable costs of service, if that percentage did not also include a provision of payment of fixed costs and a reasonable rate of return to the railroad company.

It seems odd to have to point out that the 180% variable cost threshold is considerably above the actual variable cost (100%) and if that additional "80%" does not or cannot be meant to cover fixed costs and provide a profit, then what is it designed to do?

Best regards, Michael Sol



You're dancing. Bobbing and weaving. Floating like a butterfly, but not stinging like a bee.

Yes congress could have said any rate will cover a proportional amount of fixed costs. But they didn't, did they. Congress can say anything it wants to say. They could pass a law that water will run uphill. Ain't gonna' happen, but they sure could say that it will.

Thankfully they didn't say that rates had to cover a "proportional" amount of fixed costs. That would have been "allocating" those fixed costs, something that you tried to do in order to advance your weird agenda.

One more time: Fixed costs can not be allocated in any meaningful way. That doesn't mean you don't have to cover them, you do. It just means that you can't assign them on a proportional basis to a line of business. And that's what you specifically tried to do to prove a bugus point for whatever your own weird reason was.

In this case, at least, congress got it right. You didn't.

"By many measures, the U.S. freight rail system is the safest, most efficient and cost effective in the world." - Federal Railroad Administration, October, 2009. I'm just your average, everyday, uncivilized howling "anti-government" critic of mass government expenditures for "High Speed Rail" in the US. And I'm gosh darn proud of that.
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Posted by Anonymous on Saturday, March 18, 2006 2:43 PM
QUOTE: Originally posted by MichaelSol

QUOTE: Originally posted by NS2317

QUOTE: Originally posted by MichaelSol

Passenger vehicles, which account for 93 percent of total highway travel, pay 64 percent of total Federal highway user fees. Combination trucks, on the other hand, pay over 25 percent of total highway user fees even though they travel less than 5 percent of total mileage. Among the truck classes, user fees vary substantially by vehicle weight. Single unit trucks registered at 50,000 pounds or more pay 2.5 times as much per mile in Federal user fees as single unit trucks registered at 25,000 pounds or less.



Using this, is it safe to say that there are 9 passenger vehicles for every combination truck?

No.

Commercial vehicles generally are on the road. Automobiles generally sit in garages or parking lots. Relative highway mileage would be a poor measure of vehicle numbers. A commercial truck might easily do 200,000 miles per year, although the average is probably closer to 60,000 miles annually. According to the EPA, the average American automobile travels about 12,500 miles per year.

Additionally, when they are moving, the over-the-road trucks spend more time proportionately on highways, whereas automobiles no doubt spend more time proportionately off the highways, on streets and other roads.

Best regards, Michael Sol


I guess it should have been asked like this, considering the response.

"Using this, is it safe to say that there are 9 passenger vehicles for every combination truck on the highways at a given moment in set section of highway?"

If passenger vehicles account for 93% of highway travel, they are not in garages or on other roads. That statement was the basis for my nine out of ten reasoning.

When you talk about the ratios of user fees, I would assume that these involve the ratio of weight that travels over these highways, which is the reason for maintanance of the roads and the percentages charged to the users. The fact that a railroad uses it's own roads to haul goods, makes it able to analize the costs incurred from this usage better. Because the trucks use a highway system that is shared with the traveling public, the actual cost of physical plant repair due to comercial vehicle use would be somewhat less clear. The railroad knows what caused the rail to wear, but one can only speculate what caused the highway's wear and tear.
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Posted by MichaelSol on Saturday, March 18, 2006 4:27 PM
QUOTE: Originally posted by greyhounds
One more time: Fixed costs can not be allocated in any meaningful way. That doesn't mean you don't have to cover them, you do. It just means that you can't assign them on a proportional basis to a line of business. And that's what you specifically tried to do to prove a bugus point for whatever your own weird reason was.

And of course the fact that it cannot be allocated to any particular line of business no doubt explains why Congress set it as a "threshold" for all lines of business. That is also why it is a "burden of proof" standard. However, arriving at that standard required some analysis as to what that standard should be, on the average, across all lines of business.

And that's the part you don't get: first, Congress had to set a standard.

The analysis to find that, then, required only an assessment of fixed costs and profitability. Variable costs were not considered. The formula automatically grants the railroads 100% of whatever the variable costs are. The threshold is, in fact, designed specifically around fixed costs and profitability, based on studies of what was necessary, on the average, to ensure coverage of fixed costs and profitability, and with considerable slack built in, before implications of "market dominance" can be raised, and before presumptions of "rate reasonableness" are rebutted.

Why you might think that a formula delineating a "rate reasonableness" reasonableness standard cannot take into account fixed costs, but that rates judged by that standard must by necessity cover fixed costs, is inexplicable. I think its irrational.

"Generally, the nature of a railroad’s fixed costs (e.g., physical plant such as rail, bridges, and signalling) is such that the costs of providing it are (1) incurred before any traffic moves and (2) insensitive to the level of rail traffic. Fixed costs are also largely unattributable to any particular shipper. For a railroad to be profitable, it must recover all of its costs—fixed as well as variable costs. Differential pricing is a pricing mechanism in which a railroad’s fixed costs can be recovered collectively from all shippers but not necessarily proportionately from each shipper. Under differential pricing, shippers without effective alternatives to a railroad’s transportation generally pay proportionately greater shares of the railroad’s fixed costs, while shippers with more alternatives pay proportionately less." General Accounting Office, Railroad Regulation: Changes in Railroad Rates and Service Quality Since 1990, April, 1999.

The ability to price above 180% of the variable costs raises the question, by law, that the shipper is paying a disproportionately high share of the those fixed costs, since the railroad is automatically granted a pass on 100% of its variable costs. The proportion of fixed costs paid by the shipper is the only portion of costs that can make a rate unreasonable, because, by definition, there is no such thing as an unreasonable variable cost under this approach.

Your agitated posts suggest that this bothers you. Yet, it is also clear that the entire regulatory structure that still exists is constructed around that threshold and that ultimately, the entire concept of "rate reasonableness" is in fact structured around a "reasonable" distribution or allocation of fixed charges among shippers.

Indeed, under 49 USC 10704, rates under the jurisdiction of the STB must be sufficient to cover total operating expenses, including depreciation and obsolescence, plus a reasonable and economic profit or return (or both) on capital employed in the business. This clearly demonstrates the connection between fixed charges, economic profit and the "rate reasonableness" standard defined by reference to the 180% R/VC standard set forth at 49 USC 10707.

Calling me a bunch of names doesn't, for some reason, change any of that.

Best regards, Michael Sol
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Posted by MichaelSol on Sunday, March 19, 2006 11:31 AM
QUOTE: Originally posted by NS2317
"Using this, is it safe to say that there are 9 passenger vehicles for every combination truck on the highways at a given moment in set section of highway?"

The railroad knows what caused the rail to wear, but one can only speculate what caused the highway's wear and tear.

According to the U.S. Census Bureau's Vehicle Inventory and Use Survey, the average truck, as defined by the Federal Government, has a capacity of between 6,000 and 8,500 lbs. That is, 95% of all trucks are rated under 8,500 lbs.

If you want to skew the results by eliminating the two lowest weight categories, 53% of all trucks are still under 16,000 lbs, that is, the average truck on the road is just about 12,000 lbs capacity if you eliminate all trucks under 8,000 lbs.

If that doesn't support a particular argument, you can further skew the results by taking only trucks classified over 10,000 lbs. In that instance, 82% of all trucks are under 40,000 lbs capacity, the average is about 19,500 lbs.

Only if you eliminate all trucks with less than 50,000 lbs capacity can you obtain an average weight capacity of trucks on the highway of just about 70,000 lbs.

Taken as a whole, only 1.24% of all trucks are rated over 80,000 lbs, and only 15.6% of all trucks are rated over 60,000 lbs.

Hope that is of some help in what you are trying to do.

Best regards, Michael Sol
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Posted by Anonymous on Sunday, March 19, 2006 2:56 PM
QUOTE: Originally posted by MichaelSol

QUOTE: Originally posted by NS2317
"Using this, is it safe to say that there are 9 passenger vehicles for every combination truck on the highways at a given moment in set section of highway?"

The railroad knows what caused the rail to wear, but one can only speculate what caused the highway's wear and tear.

According to the U.S. Census Bureau's Vehicle Inventory and Use Survey, the average truck, as defined by the Federal Government, has a capacity of between 6,000 and 8,500 lbs. That is, 95% of all trucks are rated under 8,500 lbs.

If you want to skew the results by eliminating the two lowest weight categories, 53% of all trucks are still under 16,000 lbs, that is, the average truck on the road is just about 12,000 lbs capacity if you eliminate all trucks under 8,000 lbs.

If that doesn't support a particular argument, you can further skew the results by taking only trucks classified over 10,000 lbs. In that instance, 82% of all trucks are under 40,000 lbs capacity, the average is about 19,500 lbs.

Only if you eliminate all trucks with less than 50,000 lbs capacity can you obtain an average weight capacity of trucks on the highway of just about 70,000 lbs.

Taken as a whole, only 1.24% of all trucks are rated over 80,000 lbs, and only 15.6% of all trucks are rated over 60,000 lbs.

Hope that is of some help in what you are trying to do.

Best regards, Michael Sol



Thanks for the numbers. I had no idea that there were that few combination vehicles (semi-tractor trailers) roaming the highways.

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