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August 15, 2007: 

Congressional Requesters: 

Subject: Freight Railroads: Updated Information on Rates and Other 
Industry Trends: 

Over 25 years ago, Congress transformed federal freight rail 
transportation policy. At that time, after almost 100 years of economic 
regulation, the railroad industry was in serious economic decline, with 
rising costs, losses, and bankruptcies. In response, Congress passed 
the Railroad Revitalization and Regulatory Reform Act of 1976 and the 
Staggers Rail Act of 1980. Together, these pieces of legislation 
substantially deregulated the railroad industry. In particular, the 
1980 act encouraged greater reliance on competition to set rates and 
gave railroads increased freedom to price their services according to 
market conditions, including the freedom to use differential pricing-- 
that is, to recover a greater proportion of their costs from rates 
charged to those shippers with a greater dependency on rail 
transportation. At the same time, the 1980 act anticipated that some 
shippers--commonly referred to as "captive shippers"--might not have 
competitive alternatives and gave the Interstate Commerce Commission 
(ICC), and later the Surface Transportation Board (STB), the authority 
to establish a process through which shippers could obtain relief from 
unreasonably high rates. This process establishes a threshold for rate 
relief, allowing a rate to be challenged if it produces revenue equal 
to or greater than 180 percent of the variable cost of transporting a 
shipment. 

Since the passage of the Staggers Rail Act of 1980, we have issued 
several reports on the freight railroad industry. On October 6, 2006, 
we issued our most recent report,[Footnote 1] in which we reported that 
industry rates and the rates for many commodities (e.g., coal and motor 
vehicles) had generally declined from 1985 through 2004. We also 
reported that freight railroad companies do not consistently report 
revenues raised from fuel surcharges. Some railroads report fuel 
surcharges as part of their general revenues, others categorize the 
surcharges separately as "miscellaneous revenue," and still others may 
not report revenue collected from fuel surcharges at all. This 
inconsistent reporting led us to recommend that STB review its method 
of data collection to ensure that all freight railroads are 
consistently and accurately reporting all revenues collected from 
shippers. Furthermore, we reported that while it is difficult to 
determine precisely how many shippers are "captive" to a single Class I 
railroad, the percentage of traffic traveling at rates over 180 percent 
of revenue to variable cost (R/VC)--that is, the traffic STB regards as 
potentially captive--and the revenue generated from that traffic have 
declined. We also reported that traffic traveling substantially over 
the statutory threshold for rate relief (rates over 300 percent R/VC) 
has increased since 1985. 

You asked us to update our October report using 2005 data, which became 
available after we issued our report. This report provides that update, 
including changes in industry and commodity rates, other costs to 
shippers (such as railcar ownership and miscellaneous revenue), and 
data on traffic traveling at rates equal to or greater than 180 percent 
R/VC. Also, we are providing additional information and analysis of 
these data--including rates, tonnage, and revenue from 1985 through 
2005--in the form of an e-supplement, which can be viewed at GAO-07- 
292SP.[Footnote 2] 

To update our October 2006 report, we examined STB's Carload Waybill 
Sample[Footnote 3] from 1985 through 2005 (the latest year for which 
data were available at the time of this review). This database includes 
information on rail rates across the industry and by commodity, as well 
as tonnage, federal regulation, and other statistics. STB disguises 
some revenues to avoid disclosing confidential business information to 
the public, but we obtained a version of the Carload Waybill Sample 
that does not disguise revenues. Data derived from this database have 
been aggregated at a level sufficient to protect confidentiality. We 
used rate indexes and average rates to measure rate changes over time. 
A rate index attempts to measure rate changes over time by holding 
constant the underlying collection of items that are shipped. For 
issues related to R/VC ratios, we used data from the Carload Waybill 
Sample to identify the specific revenues and variable costs and to 
compute R/VC ratios for the commodities and markets we examined. Using 
this information, we then identified those commodities and areas whose 
R/VC ratios were above or below the 180 percent R/VC level, as well as 
those areas above the 300 percent R/VC level. 

We determined that the data used in this report were sufficiently 
reliable for the purpose of our review. However, during our work we 
noted anomalous tonnage data estimated by one carrier in 2005 for one 
commodity (miscellaneous mixed shipments, including intermodal 
shipments). This carrier reported a significant number of waybill 
records with a single tonnage value rather than the range of values 
reported by other carriers and by this carrier in years prior to 2005. 
This lack of variation caused us to question the reliability of these 
records and to work with STB officials to investigate further. STB 
officials stated that the anomaly resulted from a change this carrier 
instituted in its methodology for estimating the tonnage of certain 
railcars and that despite the lack of variation STB had no basis for 
believing these data were in error. STB provided us additional 
information on this new methodology; however, we remained concerned 
about the lack of conformity with the reporting practices of other 
railroads for similar movements. As a result, we explored with STB 
various options for handling these 2005 data, including excluding them 
from our analysis. However, we determined that because a significant 
number of waybill records would be excluded, excluding these data would 
dramatically understate the amount of overall industry tonnage. We also 
discussed with STB not reporting 2005 data for some of the records in 
question. However, STB believed that any such action to exclude 
selective data in this manner represented a significant distortion of 
the data. We therefore decided to include these 2005 data because 
despite the lack of variation in the reporting, the average tonnage 
transported is relatively consistent with prior year data and data 
reported by other carriers and thus, we believe, provides a more 
accurate estimate than would the alternatives of excluding or modifying 
these data. We conducted our review from October 2006 to June 2007 in 
accordance with generally accepted government auditing standards. 

Results in Brief: 

In 2005, industry rail rates increased 7 percent over their 2004 
levels, the largest annual increase over the past 20 years, outpacing 
the rate of inflation for only the second time in 20 years. Rates also 
increased for the commodities we reviewed--including such commodities 
as coal and grain. Freight railroad companies continued a 20-year trend 
of shifting other costs to shippers, including railcar ownership. 
Revenues railroads reported as miscellaneous revenue--a category that 
includes fuel surcharges--nearly tripled from $633 million[Footnote 4] 
in 2004 to $1.7 billion in 2005. While it remains difficult to 
precisely determine how many shippers are captive to a single Class I 
railroad because available proxy measures can overstate or understate 
captivity, 2005 data indicate that potentially captive traffic 
continued to drop. At the same time, traffic traveling at rates 
significantly above the threshold for rate relief increased in 2005. 

Industry Rates Rose in 2005: 

In 2005, industry rail rates rose 7 percent over their 2004 
levels.[Footnote 5] This represents the largest annual increase in 
rates during the 20-year period from 1985 through 2005, and outpaced 
changes to inflation--5 percent in 2005. Despite this increase, rates 
for 2005 remain below their 1985 levels. Because the set of rail rate 
indexes we used to examine trends in rail rates over time does not 
account for inflation we also included the price index for the gross 
domestic product (GDP) in figure 1. While rate increases in 2005 
outpaced inflation for just the second time since 1985, over the long 
term, rate increases have lagged behind inflation rates. 

Figure 1: Trends in Industry Rail Rates, 1985-2005: 

[See PDF for Image] 

Source: GAO analysis of STB data. 

[End of figure] 

While Generally Declining over the Long Term, Rates for Several 
Commodities Have Increased in Recent Years: 

Similar to overall industry trends, rates for individual commodities 
have increased. In 2005, rates increased for all 13 commodities that we 
reviewed. Despite this increase, 2005 rates for several commodities 
remain lower than in 1985. In 2005, the largest rate increase (for 
fireboard and paperboard) exceeded 12 percent, while the smallest 
increase (for motor vehicles) was about 2 percent. Figure 2 depicts 
rate changes for coal, grain, miscellaneous mixed shipments, and motor 
vehicles from 1985 through 2005. 

Figure 2: Rate Changes for Coal, Grain, Miscellaneous Mixed Shipments, 
and Motor Vehicles, 1985-2005: 

[See PDF for Image] 

Source: GAO analysis of STB data. 

[End of figure] 

Railroads Continued to Shift Costs to Shippers: 

In 2005, freight railroad companies continued a 20-year trend of 
shifting other costs to shippers. With the addition of the 2005 data, 
our analysis shows a 20 percent shift in railcar ownership (measured in 
tons carried) since 1987. In 1987, railcars owned by freight railroad 
companies moved 60 percent of tons carried. In 2005, they moved 40 
percent of tons carried, meaning that freight railroad company railcars 
no longer carry the majority of tonnage (see fig. 3). 

Figure 3: Tonnage Carried by Railcar Ownership, 1987-2005: 

[See PDF for Image] 

Source: GAO analysis of STB data. 

[End of figure] 

Reported Miscellaneous Revenue, Including Fuel Surcharges, Nearly 
Tripled in 2005: 

In 2005, the amount of industry revenue reported as miscellaneous 
nearly tripled over 2004 levels, rising from about $633 million to over 
$1.7 billion (see fig. 4). This miscellaneous revenue includes some 
fuel surcharges[Footnote 6] and other charges for providing rail 
service. In 2004, miscellaneous revenue accounted for 1.5 percent of 
freight railroad revenue reported, while in 2005 this percentage had 
risen to 3.7 percent. Also, in 2005, 20 percent of all tonnage moved in 
the United States generated miscellaneous revenue. STB has proposed to 
more closely track and otherwise monitor revenues associated with fuel 
surcharges, but it is too soon to tell whether STB's proposal will 
affect the reporting and tracking of miscellaneous revenue in the 
Carload Waybill Sample.[Footnote 7] 

Figure 4: Miscellaneous Revenue Tracked in Carload Waybill Sample, 2000-
2005: 

[See PDF for Image] 

Source: GAO analysis of STB data. 

[End of figure] 

Captive Shippers Remain Difficult to Identify, but Some Measures 
Indicate Captivity Is Dropping in the Railroad Industry: 

It remains difficult to determine precisely how many shippers are 
captive to one railroad because the proxy measures that provide the 
best indication can overstate or understate captivity. One measure of 
potential captivity--traffic traveling at rates equal to or greater 
than 180 percent R/VC--is part of the statutory threshold for bringing 
a rate relief case before STB.[Footnote 8] STB regards traffic at or 
above this threshold as "potentially captive." Like other measures, R/ 
VC levels can understate or overstate captivity. In 2005, industry 
revenue generated by traffic traveling at rates over 180 percent R/VC 
dropped by roughly half a percent. Tonnage traveling at rates over 180 
percent R/VC dropped by a smaller percentage. This continued the 
generally downward trend since 1985 (see fig. 5). 

Figure 5: Tonnage and Revenue Generated from Traffic Traveling at Rates 
Equal to or Greater than 180 Percent R/VC, 1985-2005: 

[See PDF for Image] 

Source: GAO analysis of STB data. 

[End of figure] 

Amount of Potentially Captive Traffic Traveling at Levels Substantially 
above the Threshold for Rate Relief Increased in 2005. 

While traffic traveling at rates over 180 percent R/VC declined in 
2005, traffic traveling at rates substantially over the threshold for 
rate relief increased. In 2005, traffic traveling at rates over 300 
percent R/VC increased. This increase followed declines in 2003 and 
2004 but continued a general upward trend since 1985 (see fig. 6). 

Figure 6: Tonnage Traveling at Rates over 300 Percent R/VC, 1985-2005: 

[See PDF for Image] 

Source: GAO analysis of STB data. 

[End of figure] 

Concluding Observations: 

Data for 2005 confirm the trends and findings we reported and support 
the recommendations we made in October 2006. The 2005 data provide more 
definitive evidence that after a period of decline, rates are 
increasing in the freight rail industry as a whole as well as across a 
range of commodities. Moreover, the continued increases in traffic at 
higher thresholds shown in the 2005 data affirm our (1) conclusions 
that STB has the statutory authority and access to information to 
conduct a rigorous analysis of competition in the freight rail industry 
that would rely on more than sample data and (2) recommendation that 
STB undertake such an analysis to determine whether rail rates in 
selected markets reflect justified and reasonable pricing practices or 
an abuse of market power by the railroads. Finally, the continued 
increase in the amount of miscellaneous revenue reported in 2005 lends 
further support for our recommendation that STB review its method of 
data collection to ensure data are accurately and consistently 
reported. 

Agency Comments: 

We provided a draft of this report to STB and DOT for review and 
comment. STB provided written comments, which are reproduced in the 
enclosure to this letter. STB generally agreed with our updated 
assessment of the freight railroad industry. However, STB suggested 
that we present our findings on rates using inflation-adjusted measures 
in order to provide context. As in our October report, we developed and 
used a set of rail rate indexes to examine trends in rail rates over 
the 1985 through 2005 period that account for changes in traffic 
patterns over time but do not account for inflation. To account for 
inflation, we included the price index for the gross domestic product 
in our analysis (see figures 1 and 2). 

STB also stated that it intends to implement our recommendation that it 
undertake a rigorous analysis of competition in the freight railroad 
industry. STB stated that it has identified funding not available at 
the time of our October report that it intends to use to solicit 
proposals from analysts with no connection to the freight railroad 
industry or STB proceedings to conduct such a study. While we commend 
STB for taking this action, it remains to be seen whether these 
analysts would have STB's statutory authority and sufficient access to 
information to determine whether rail rates in selected markets reflect 
justified and reasonable pricing practices or an abuse of market power 
by the railroads. 

STB also stated that it has taken action to address our recommendation 
that it review its method of data collection to ensure that all freight 
railroads are consistently and accurately reporting all revenues 
collected from shippers. In January 2007, STB finalized rules 
requiring, among other things, that carrier fuel surcharges be based on 
factors directly affecting the amount of fuel consumed. Furthermore, 
STB stated it is in the process of finalizing new reporting 
requirements for fuel surcharges. We recognize STB's action in this 
area and modified our report to reflect these actions; however, STB has 
yet to finalize and implement standardized reporting of fuel 
surcharges. Furthermore, revenues other than fuel surcharges are 
included in reported miscellaneous revenues. Thus it remains for STB to 
review its method of data collection to ensure that all freight 
railroads are consistently and accurately reporting all revenues. 

DOT provided us with e-mail comments on the draft from the Federal 
Railroad Administration (FRA). Like STB, FRA suggested that we 
recognize STB's new rules regarding how carriers can calculate fuel 
surcharges. FRA provided additional technical comments that we have 
incorporated as appropriate. 

If you or your staffs have any questions about this report, please 
contact me at (202) 512-2834 or heckerj@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this report. Key contributors to this report were 
Steve Cohen (Assistant Director), Steve Brown, Matt Cail, and John 
Mingus. 

Signed by: 

JayEtta Z. Hecker: 
Director, Physical Infrastructure Issue: 

List of Congressional Requesters: 

The Honorable Daniel K. Inouye: 
Chairman: 
Committee on Commerce, Science, and Transportation: 
United States Senate: 

The Honorable Byron Dorgan: 
United States Senate: 

The Honorable Frank Lautenberg: 
United States Senate: 

The Honorable Trent Lott: 
United States Senate: 

The Honorable John McCain: 
United States Senate: 

The Honorable Mark Pryor: 
United States Senate: 

The Honorable Gordon Smith: 
United States Senate: 

[End of section] 

Enclosure: Comments from the Surface Transportation Board: 

Office of the Chairman: 
Surface Transportation Board: 
Washington, D.C. 20423-0001: 

June 25, 2007: 

Ms. JayEtta Z. Hecker: 
Director: 
Physical Infrastructure Issues: 
Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Ms. Hecker: 

The Surface Transportation Board has received the draft version of the 
Government Accountability Office (GAO) report entitled Freight 
Railroads: Updated Information on Rates and Other Industry Trends, (GAO-
07-291R). 

We have reviewed the draft and are submitting the agency's formal 
comments which are attached. If you have any questions, please contact 
William Huneke, Associate Director and Chief Economist, at 202-245-
0325. 

We appreciate the opportunity to work with you on this matter. 

Sincerely, 

Signed by: 

Charles D. Nottingham: 

Enclosure: 

cc: Steve Cohen, Assistant Director, GAO: 
Matt Cail, Analyst-in-Charge, GAO: 
Vice Chairman Buttrey: 
Commissioner Mulvey: 
Associate Director, William Huneke: 

Comments of the Surface Transportation Board: 

"Freight Railroads: Updated Information on Rates and Other Industry 
Trends" (GAO-07-291R): 

June 25, 2007: 

The STB welcomes the opportunity to comment upon GAO's update of last 
October's major study of the freight railroad industry. Significantly, 
GAO's findings demonstrate that despite an up tick in 2005 general 
industry rates remain at or below 1985 levels even in nominal terms 
(Figure 1). Moreover, for each of the four major categories of rail 
traffic separately tracked by GAO (coal, grain, motor vehicles, and 
miscellaneous mixed shipments), rates have not kept pace with inflation 
(Figure 2). 

We suggest that to present its findings in context GAO use inflation- 
adjusted measures. For example, although GAO reports that rates for 
shipments of motor vehicles increased 2% in 2005, those rates actually 
fell when adjusted for the 5% inflation rate that GAO reports in 2005. 
Furthermore, the general industry rate increase of 7% in 2005 was 
modest when compared to the 5% inflation rate. Moreover, the report 
notes that 2005 was only the second year since 1985 that the general 
industry rate increases exceeded inflation. 

GAO repeats its previous recommendations that STB undertake a rigorous 
analysis of competition in the freight railroad industry and review its 
fuel surcharge reporting processes. While the STB's staff resources 
remain constrained, the STB has identified funding (not available at 
the time of GAO's initial report) to conduct a study responsive to 
GAO's recommendation. We intend to solicit proposals from analysts with 
no ties to the railroad industry or connection to any recent STB 
proceedings for a fixed-price contract to conduct an appropriate study. 

no ties to the railroad industry or connection to any recent STB 
proceedings for a fixed-price contract to conduct an appropriate study. 

Concerning GAO's other recommendation to the STB regarding data 
collection, prior to GAO's October report the Board had already taken 
action to address concerns related to railroad fuel surcharges. In 
August 2006, we proposed measures, finalized in January 2007, 
requiring, among other things, that if a carrier chooses to use a fuel 
surcharge program, the fuel surcharge must be based upon attributes of 
a movement that directly affect the amount of fuel consumed. We are now 
in the process of finalizing new reporting requirements, also first 
noticed for comment in August 2006, that will provide more accurate and 
timely data on the revenue collected through fuel surcharges and the 
amount of fuel cost increases absorbed by the railroads themselves. 

The new fuel surcharge reports should provide "accurately and 
consistently reported" data, as called for by GAO, on each Class I 
railroad's fuel surcharge program. As GAO notes, a fuel surcharge 
imposed on an individual shipment is not separately identified in the 
Waybill Sample, but rather may be grouped with other "miscellaneous" 
revenues. Once we are able to assess the impact of the recent reforms 
on how fuel surcharges are imposed and reported, we will be in a better 
position to weigh the potential benefits and burdens of revisiting how 
data are reported for the Waybill Sample on individual movements. The 
STB will remain vigilant in monitoring the railroad industry and will 
take such actions as necessary and appropriate to protect the public 
interest. 

[End of section] 

(544132): 

FOOTNOTES 

[1] GAO, Freight Railroads: Industry Health Has Improved, but Concerns 
about Competition and Capacity Should Be Addressed, GAO-07-94 
(Washington, D.C.: Oct. 6, 2006). 

[2] GAO, Freight Railroads: Electronic Supplement on Rates and Other 
Industry Trends, 1985-2005, GAO-07-292SP (Washington, D.C.: August 15, 
2007). 

[3] The Carload Waybill Sample is a sample of railroad waybills (in 
general, documents prepared from bills of lading that authorize 
railroads to move shipments and collect freight charges); the sample 
contains information on rail rates. 

[4] Dollar amounts in this update will not have exactly the same value 
as those we reported in October 2006. For our October report, 2004 was 
the most recent year for which data were available and we adjusted 
price levels for all years to 2004 levels. Because we use 2005 data for 
this update, we adjusted price levels to 2005 levels. 

[5] We constructed rate indexes to examine trends in rail rates over 
the 1985 through 2005 period. These indexes define traffic patterns for 
a given commodity in terms of census region to census region flows of 
that commodity, and we calculated the average revenue per ton-mile for 
each of these traffic flows. The index is calculated as the weighted 
average of these traffic flows in each year, expressed as a percentage 
of the value for 1985, where the weights reflect the traffic patterns 
in 2005. By fixing the weights as of one period of time, we attempted 
to measure pure price changes rather than calculating the average 
revenue per ton-mile in each year. Over time, changes in traffic 
patterns could result in a substitution of lower priced traffic for 
higher priced traffic, or vice versa, so that a decrease in average 
revenue per ton-mile might partly reflect this change in traffic 
patterns. The rate index for the overall industry was defined 
similarly, except that the traffic pattern bundle was defined in terms 
of broad commodity, census region of origin, and mileage block 
categories. For comparison, we also present the price index for gross 
domestic product over this period. 

[6] Fuel surcharges are associated with recouping the cost of fuel. How 
fuel surcharges are calculated varies among Class I railroads because 
some use a mileage-based system while others use a percentage of the 
base rate. 

[7] On January 25, 2007 STB finalized rules stating that it was an 
unreasonable practice for freight railroads to compute fuel surcharges 
as a percentage of the base rate, as well as "double dipping"--i.e., 
applying to the same traffic both a fuel surcharge and a rate increase 
based on a cost index that includes a fuel cost component. STB has 
proposed rules for railroads to report revenues raised from fuel 
surcharges, but these have not yet been finalized. 

[8] Another condition for bringing a rate relief case before STB is a 
railroad not facing effective competition from other rail carriers or 
other modes of transportation. 

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