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NARP Comments to STB on On-Time Performance Policy Statement

February 8, 2016

NARP to STB on On-Time Performance

[Click here for PDF of statement]


Ms. Cynthia T. Brown,

Chief, Section of Administration

Office of Proceedings

Surface Transportation Board

395 E. Street, SW

Washington, DC 20423

Re: Ex Parte 726: On -Time Performance under Section 213 of the Passenger Rail Investment and Improvement Act of 2008

Dear Ms. Brown:

The National Association of Railroad Passengers, the nation’s oldest and largest organization speaking for the nearly 40 million Americans who rely on passenger rail every year, appreciates the opportunity to comment on the STB’s Notice of Proposed Rulemaking (NPRM) to address on-time performance (OTP).

Overall NARP is pleased to see the Board working to address the continuing problem of OTP. Late trains are the single most significant cause of passenger dissatisfaction. Our members are neither naïve nor intransigent, and recognize that a crucial issue contributing to freight-caused delays of passenger trains is the lack of capacity in the face of growing shipping and passenger traffic. While sympathetic, the fact remains that our members rely on – and pay for – timely and regular service on those routes.

Many irreplaceable personal moments have been disrupted by these delays, with crucial medical transports affected, weddings and funerals missed and rare home visits by deployed service-members cut short or even cancelled altogether. Each of these hundreds of stories – and we supplied more than 1,300 of them to STB in October of 2014 – add up to more than mere temporary inconvenience and in many cases impose real dollar costs on vulnerable travelers.

Coming at a time of record ridership, these delays on freight railroads nationwide may well permanently discourage new and first-time riders from exercising their choice to travel by rail, a choice more Americans each year say that they want. Chronic delays not only hurt our members and the rail-riding public but diminish Amtrak’s ability to generate annual revenue improvements that reduce the amount of subsidy that is provided by taxpayers – both a statutory requirement and policy goal at both ends of the political spectrum.

This is why NARP applauds STB’s interest and welcomes STB’s focused regulatory attention to this thorny problem. However, we believe that the OTP proposal as laid out in the NPRM is inadequate in several ways, most especially in its apparent inapplicability to 90% of the stations served by Amtrak through using only end-point OTP as a triggering metric. STB’s discussion of its proposed OTP standard sidesteps many important concerns for the fare-paying public, such as what truly constitutes an “end point,” the effect on connections, and the reality of the 30-minute standard when set against existing schedule padding.

NARP also finds it baffling that STB chose the 1973 Interstate Commerce Commission (ICC) rule as its starting point for writing an OTP standard, given that by 1974 ICC recognized its mistake and replaced the standard with one that included intermediate OTP measurements, saying “The public should be able to rely upon train schedules at intermediate stops as well as the ‘final terminus’ of a route.” Why would STB choose to turn back the clock on the standard set by its predecessor agency – especially when that standard was the result of public hearings that included some 300 witnesses – without any real clear explanation?

Moreover, NARP believes the process STB has started misses an opportunity to create a framework that engages all stakeholders – from regulators to host railroads, operators (including Amtrak), shippers and passengers – to work together on how to improve dispatching, coordination and infrastructure so that all parties benefit.

In this comment paper, NARP offers several recommendations along with background and detailed discussion on key points driving our recommendations.

Recommendation One

NARP urges regulators to measure on-time arrivals at all stations, not just at the end points; to use a single 15-minute standard at each point along a train’s route, and; to trigger an automatic investigation if trains on a route dip below the OTP standard more than 20% of the time.


The proposed definition would consider a train to be “on time” if it arrives at its final terminus no more than five minutes after its scheduled arrival time for each 100 miles the train operated, or 30 minutes after its scheduled arrival time, whichever is less. Thirty minutes would be the maximum tolerance allowed, even for national network trains which can travel more than 2,000 miles between end points.

As we noted earlier, poor on-time performance is one of the biggest problems faced by America’s rail travelers, and NARP believes the STB's proposed rule-making offers the opportunity to provide a significant service improvement for passengers, generating additional revenues for Amtrak while also reducing operating costs.

On the other hand, ignoring OTP at intermediate stations – measured today using the All-Stations OTP (ASOTP) metric – could permanently hobble Amtrak from taking action on behalf of the 65% of its passengers in 24 states who get on and off at an intermediate station. Under STB’s proposal, some 90% of Amtrak stations’ OTP would never be measured.

OTP at route end points is irrelevant to most passengers. Three out of every four passengers using Amtrak’s trains depart from and arrive at stations strung between end point cities, and never set foot in an end point station. The percent of passengers traveling between intermediate points exceeds 50% on three fourths of Amtrak’s 47 routes (see accompanying table with NARP’s route-by-route analysis). Intermediate stations’ ridership is an important statistic throughout the system, and is significant on short, medium and long distance routes.

A random review of the Spring/Fall 2015 timetable shows significant padding on a number of routes prior to end point arrival. This “pad” can be as much as an hour or more. As a result, a train could arrive at the final station on time – and thus meet the new proposed standard – yet have been significantly late at many stations before it and inconvenienced hundreds of passengers on that trip.

Schedule adherence standards should be the same regardless of route length. In the same way that many passengers travel between intermediate points on a route, so too do passengers make trips that are significantly shorter than the route itself. They care about – and have paid for – the train arriving at their destination, not at the end of the route.

This standard is what Congress has already legislated into law: according to 49 USC sec. 24101(c)(4) “Amtrak shall…operate Amtrak trains, to the maximum extent feasible, to all station stops within 15 minutes of the time established in public timetables.”

Recommendation Two

NARP recommends that regulators look more closely at what constitutes an “end point” station, given that there are routes at which intermediate stations constitute end-points for many individual services.


As many routes are currently operated, the very first and very last stations are not always the “end points” on any given frequency. Take as an example the Pacific Surfliner service. Technically, the end points are San Diego and San Luis Obispo. Yet 11 trains a day operate only between San Diego and Los Angeles. Only two serve San Luis Obispo. Santa Barbara has five trains each way per day.

There are similar issues on many other routes, including the Capitol Corridor in California, the Cascades in Washington, New York State’s Empire Service and the Northeast Corridor. Without a clear regulatory definition of where OTP will be measured, a large section of the route network could be completely devoid of any scrutiny and that would be a disservice to the travelling public.

Recommendation Three

NARP believes collected and published data should include the effect of degraded OTP on connections, and should require statistical reporting by Amtrak detailing when late trains cause passengers to miss connections or when Amtrak is forced to delay departure of trains for connecting passengers. Collected and published data should also include OTP at key “chokepoints” where passenger trains are handed off from one host railroad to another.


Passengers who use more than one route to complete a trip represent a significant portion of Amtrak’s business. In FY 2015, 2.3 million passengers generating more than $220 million in revenue made connections between trains.

When trains arrive at transfer stations many hours late it can lead to either of two unacceptable outcomes. The connecting train departs late because it waits for the connecting passengers, or the passengers miss the connection and, in cases where there is only one departure a day, arrive at their final destination as much as 24 hours after they had planned.

There are all sorts of consequences from these scenarios. Hotel rooms are cancelled and deposits forfeited, or extra expense is imposed on the traveler. Arrivals that had been scheduled for daylight hours can instead transform into dangerous night-time arrivals at thinly staffed or unstaffed stations; this can be especially troublesome for elderly or disabled travelers, posing a real safety risk which is magnified by these populations’ outsize reliance on trains as their only practical means of long-distance travel.

STB should be aware of these very real consequences of seriously late trains and consider additional metrics that track not just the percentage of trains that meet the schedule adherence standard but also the amount of delay and how that delay disrupted connections.

Recommendation Four

NARP believes that while Amtrak-caused delays contribute only a small fraction of the total delays reported, it is fair to use the OTP rulemaking to establish a minimum standard Amtrak must meet to avoid delays caused by equipment failures.


When Amtrak experiences an equipment failure en route, it adversely affects both its passengers and the host railroad’s operations, sometimes in significant ways. Congress has put significant pressure on Amtrak to cut operating expenses, and this pressure creates significant incentives for Amtrak to defer maintenance, deploying equipment that is not in a state of good repair and subject to en route failures.

To the extent that the relatively small fraction of delays is caused by Amtrak equipment problems, it can be viewed as a policy failure revealing what happens when Congress mandates performance by the national operator while systematically starving that same operator of the resources it needs to ensure that the equipment performance does not adversely affect host railroads.

STB should be aware of this issue and its importance both to passengers and to the railroads over which Amtrak trains operate.

STB should also recognize the larger environment in which these problems take place. Conflicts over OTP are in some ways just a window into larger issues our nation faces in infrastructure investment and priorities. Our national network is neglected and inadequate for the demands of a 21st Century economy, and is groaning under the strain of trying to serve the growing needs of shippers and rail passengers.

The American people are already voting for more trains with their wallets. Public use of trains is growing far faster than air or road travel or even the population itself. In FY 2014, Amtrak carried 30.9 million passengers – the eleventh year of record ridership in the last 12 years.

Growing congestion in other modes and rapidly dwindling transportation options in small- and mid-sized communities are driving this surge, making train travel more vital than ever to local economies across the nation. As surely as mobility powers economic growth, congestion constrains it. Millions of Americans today face loss of personal mobility: airlines are cutting back the number of flights and have reduced or discontinued service to literally hundreds of smaller cities. Millions more find flying to be too expensive, too inconvenient, or simply too unpleasant. An increasing number of young people don’t own automobiles, either as a personal choice or because they are unaffordable. Many older citizens are unable or unwilling to drive their personal automobiles for more than just a few miles; this population will grow dramatically during the next few decades in the U.S., and their needs must be accounted for.

NARP believes that these people—and indeed all Americans—have the right to choose how they travel. A regulatory system that ignores on-time performance at 90% of destinations served effectively deprives taxpaying Americans of that right.

As recognized by the House Committee on Transportation itself: “By 2039 the U.S. population will exceed 400 million and the population concentration in our urban areas is increasing. Transportation solutions for these people are paramount in order to support an expanding U.S. economy. The costs of congestion and poor transportation infrastructure continue to rise for commuters: almost $121 billion each year is wasted in time and fuel, up from only $24 billion in 1982. In addition, Americans spend a staggering 5.5 billion hours annually stuck in traffic.”

Many economists, planners and local governments have concluded that a seamless national network, using rail to tie other modes together, is the only way to provide travel options for a growing population. We agree. NARP's vision is for an expanded national network of passenger trains (short, medium, and long-distance), putting 80% of Americans within 25 miles of a train station served frequently by fast, modern and reliable trains providing top-notch customer service. NARP members also want to see at least one high-speed rail line with trains operating at a maximum speed of at least 200 mph in operation by 2025. Finally, NARP envisions enhanced connectivity between intercity trains and airports, intercity buses, local transit, cycling and walking, and car rental and sharing service for a seamless multi-modal transportation network, coast-to-coast – connecting “flyover country” to the nation’s larger economy and prospects.

This idea has been endorsed by number of different economic groups, including a coalition of 42 individual State Chambers of Commerce: “One of America’s greatest strengths is our ability to create diverse networks of transportation infrastructure to cheaply and efficiently move goods and services around the nation. In order to compete with our economic advantage, other nations are making historic investments in their own transportation infrastructure. China, India, and Europe spend about 9%, 8%, and 5% of their gross domestic product, respectively, on infrastructure investment. Meanwhile, infrastructure investments in the United States have declined to a mere 2.4% of GDP.”

These realities underscore why NARP believes the process STB has started misses an opportunity to create a framework that engages all stakeholders – from regulators to host railroads, operators (including Amtrak), shippers and passengers – to work together on how to improve dispatching, coordination and infrastructure so that all parties benefit.

NARP recommends that the STB use its position to lead the effort to create such a framework to address issues that have plagued our national network for decades. As part of this more constructive approach, NARP believes that STB could profitably move to set not only a minimum OTP standard, but a target for exceeding minimum standards that could offer significant financial incentives to host railroads that not only deliver superior OTP but reduced trip times and greater frequencies. This could take the form of bonus payments that rise on a scale calibrated to OTP performance, incentivizing private investments in a rail network that can serve not only freight customers but passenger trains at high service levels.

Again, NARP appreciates the opportunity to comment on behalf of the nearly 40 million Americans who rely on rail each year for travel for work, school and leisure.


Jim Mathews

President & CEO

National Association of Railroad Passengers

505 Capitol Court NE, Suite 300

Washington, DC 20002

Attachment: Stations Analysis By Amtrak Route