July 12, 2006

The Honorable W. Douglas Buttrey, Chairman
Surface Transportation Board
Washington, DC

Dear Chairman Buttrey:

The National Association of Railroad Passengers (NARP) has over 20,000 members dedicated to preservation, improvement, and expansion of America’s passenger rail system.  Our members are increasingly alarmed at the on-time performance of many Amtrak trains operating on tracks of the freight railroads—especially CSX and Union Pacific.  This threatens repeat business and the very survival of the service.  We urge you to take every action you can—including, but not limited to, investigation and public hearings—to bring about improved performance.

Amtrak Acting President and CEO David J. Hughes told our board in April that on-time performance of Amtrak trains on freight railroad tracks dropped 50% from 1999 to 2005.  Our observations, and the data we have seen from Amtrak, indicate that things are worse this year. 

In June, 2006, for example, just 15% of trips of the Los Angeles-Seattle Coast Starlight, which primarily uses UP, reached final destinations less than four hours late; the comparable figure for the Sunset Limited (UP) was 32%.  On the shorter New York-Florida line (mostly CSX), only 57% of trips (including Auto Train) reached final destination less than three hours late.  During the month, more than 100,000 passengers rode Amtrak trains that reached their final destinations over four hours late; the overwhelming majority of these passengers were on routes that use CSX or Union Pacific exclusively or primarily.  By contrast, the Chicago-Los Angeles Southwest Chief (BNSF) and Chicago-Seattle/Portland Empire Builder (BNSF and CP) were on time (no more than 30 minutes late) 63.3% and 80.0%, respectively.

This suggests that UP and CSX do not take seriously 49 USC 24308(c), which requires that Amtrak trains be given “preference over freight transportation…except in an emergency” or where the Secretary of Transportation, in response to a railroad’s application for relief, has “established the rights of the carrier and Amtrak on reasonable terms.”

Any investigation and related public hearings should:

• Identify specific, detailed causes of the freight train interference issues;
• Determine whether and how much freight train interference delay results from actions which might have been reasonably avoided; and
• Most importantly, identify short and long term remedial actions.

Host railroads cause the majority of delay minutes.  Amtrak’s April report, available on-line, shows that 54% of all delay minutes on long-distance trains that month were in two categories: “freight train interference” and “slow orders.” The comparable percentages for the Coast Starlight and Sunset Limited were 61% and 70%, respectively. 

Amtrak mechanical and personnel issues also can delay trains, but the root causes of many such delays are relentless, terrible on-time performance.  This unreasonably stretches Amtrak crews and equipment, leaving inadequate time for crew rest and equipment maintenance between trips.

Union Pacific and CSX are the worst offenders and appear to have a corporate culture that views Amtrak as a costly nuisance.  These railroads appear uninterested in earning incentive payments from Amtrak, or in reaping other benefits from a positive relationship with Amtrak.

Amtrak obviously can provide much more detailed data, and some insight into which delays (a) might have been reasonably avoided, and (b) might be addressed in the short term.  Dispatcher-related delays could stem from lack of skill on the dispatcher’s part or from dispatchers picking up cues—tacit or explicit—from the above-referenced “corporate culture.”

Consider the Coast Starlight (Los Angeles-Oakland-Sacramento-Eugene-Portland-Seattle).  The major issue here is the disrepair into which Union Pacific has allowed a major freight route to fall.  We understand that the segment between Sacramento and Eugene has over 100 slow orders, many at 10 mph.  One southbound run of the Starlight lost 3 hours 33 minutes due to slow orders between Sacramento and Portland plus 4 hours 52 minutes meeting other trains. 

It is appalling that a route so important to both freight and passengers has been allowed to deteriorate so much.  This did not happen overnight.  One must question why Union Pacific permitted a primary route to fall into such disrepair.  Indeed, if parallel Interstate 5 suffered from such conditions, remedial action would be taken immediately.

Conversely, where track is in good condition, there may be opportunities to raise speed limits while doing little or nothing to further improve track conditions.  Other issues include shortage of freight railroad crews and—the most problematic for short-term considerations—track capacity. 

Given the shockingly poor service Amtrak is getting from Union Pacific and CSX, it is essential that the STB move quickly to (a) identify where existing track capacity is not being properly used, and (b) apply pressure for longer-term solutions regarding track capacity.  It is vital that other major lines not experience the same, alarming “slow-order creep” that parts of the Starlight route have experienced. 

All freight railroads which handle passenger trains must know that the Surface Transportation Board takes Amtrak performance seriously, just as you have served notice on the railroads regarding their ability to handle peak shipping freight demands.  Where short term solutions exist, the very existence of a high-profile STB investigation—or even the knowledge that you care—may stimulate noticeable improvement in Amtrak on-time performance in surprisingly short order.

Thank you for considering our views.  If we can provide more information, please let me know.

Sincerely,

Ross B. Capon
Executive Director

cc:
The Honorable Francis P. Mulvey
The Honorable Maria Cino
The Honorable Joseph H. Boardman
The Honorable Ted Stevens
The Honorable Trent Lott
The Honorable Daniel K. Inouye
The Honorable Don Young
The Honorable Steve LaTourette
The Honorable James L. Oberstar
The Honorable Corinne Brown