April 29, 2020 

Comments upon Metrics and Minimum Standards for Intercity Passenger Rail Service 

RIN: 2130-AC85 

Document Number: 2020-07624 

FRA Docket Number: 2019-0069-0004 & 2019-0069-0005 

Virgil G. Payne, PE 

Personal Work 

Greetings: 

Introduction 

I am a licensed professional engineer who has had a part in recent Interstate Highway planning, design, 

and construction who now supports high-volume manufacturing after a period of designing infill 

buildings and sites and briefly working in utility and railroad operations. Perhaps a broader consideration 

of transportation financing is needed to address the rulemaking. 

An amicable path forward is available to address questions of operational reliability and efficiency on the 

General Railway System that the proposed Metrics and Minimum Standards seek to address should 

federal policy be reversed to move toward a market economy. While performance based metrics can play 

some part in ordering goals for the public good they should not be developed using existing assumptions 

when competitive modes are financed under differing methods and cost recovery rates. The FRA and the 

USDOT could guide the metrics and minimum standards by considering the differences between 

infrastructure and operations in greater detail relative to other surface transportation programs. 

The Financial Assumptions behind the 1973 3R Act Infrastructure Consolidation are not Durable 

Discussion: 

With the benefit of hindsight, it can be seen that the drastic reduction in system infrastructure route 

reliability that was the hallmark of various plans to reduce overall capacity in the eastern General Railway 

System to meet a lower marketplace demand under past observed conditions was predicated on an 

incorrect financial model of infrastructure investment. The United States Department of Transportation 

(USDOT) at its 1967 founding as an agency inherited a concept of infrastructure financing from the 

Department of Commerce, Bureau of Public Roads that does not actually advocate for incremental user 

funding of highway infrastructure, but instead promotes a little understood concept of leveraging 

highways as a public investment. This leveraging arises when excise taxes collected during the use of the 

much broader locally financed road network are devoted at the federal level through the fuel (gas) tax to 

intercity highways, significantly funding this type of infrastructure with minimal incremental cost 

recovery. 
While many focus on the $141 Billion transferred to the Highway Trust Fund (HTF) from general funds1

by the last authorizing legislation the much larger incremental funding gap is actually this leveraging atop 

locally financed road assets. Governments ultimately survive on some form of excise taxation warranted 

for public good projects, yet marketplace distortions occur when only one mode is beneficially funded in 

a long-term program of consistent formulaic investment. 

Net Present Value studies that I have conducted, using historic corporate bond interest rates though with 

no equity load nor property tax burden, show that the nationwide Interstate Highway system has only 

recovered around 1/8th of its direct financial long-run average costs over the last six-decades from 

incremental fuel taxes and fees prorated by mileage and only 1/16th for newer projects similar to those I 

helped organize at MDOT. The basic charts are enclosed with this comment. 

Certainly, this incremental highway funding gap could be corrected by a fuel tax increase, targeted by 

perhaps creating a new class of chemically marked diesel fuel. However, this is politically unlikely 

leaving few solutions to establish a competitive infrastructure basis outside of urban areas where toll lanes 

could be expanded to throttle congestion. 

While the USDOT as a whole should look to reform their methodologies for project justification perhaps 

the only option to restore the marketplace that is available solely to the Federal Railroad Administration 

(FRA) is to research this topic and publish data that supports a form of assignable Tax Credit for mainline 

General Railway System infrastructure equal to the highway leveraging per person-mile and/or 

intermodal freight highway container/trailer-mile converted to a train-mile basis2

, claimable only with 

operation of consumer beneficial transportation (both passenger and highway competitive intermodal 

freight routes) to balance the funding of intercity infrastructure. The FRA could thus advocated for a 

Shadow Toll of this amount. 

Ultimately, it must be acknowledged that the only real solution to many of the on-time and financial 

metrics is for the nation to encourage the shareholder owned railroads to provide for resilient mainline 

infrastructure in a manner that is beneficial to their owners though there is some residual duty that such 

railroads have to provide for common carrier service in their partially deregulated state. While this is 

somewhat out of the scope of the rulemaking the FRA must ask itself how will more reliable 

infrastructure be funded and what can they do to through basic research to advance concepts that would 

serve as the foundation for legislation such as an infrastructure Tax Credit. 

Proposed Addition to Rule Section II. Background – Modal Equity Rationale Statement: 

Overall, incremental changes to the Amtrak route level performance and goal achievement should be 

evaluated using a Metric of $17.2 per train-mile as an acceptable level of Public Good Below-the-Rail 

Infrastructure Investment that is not covered by incremental consumer revenue which shall be subtracted 

from existing costs. This investment is roughly equivalent to the gap between the incremental consumer 

fuel taxes and prorated fees and the long-run average financial cost of the last six-decades of nationwide 

Interstate Highway spending. An additional fixed amount for the Northeast Corridor infrastructure will 

exist in such an analysis that is justified at the federal level as the most efficient method to provide for 

intercity transportation capacity where no room remains for economical highway expansion.

                                                            

1 Government Accountability Office, “Funding the Nation's Surface Transportation System—High Risk Issue 2017,”

https://www.gao.gov/key_issues/funding_nations_surface_transportation_system/issue_summary 2 Virgil G. Payne, “Tax Credit Policy Summary” 2020, https://www.scribd.com/document/442430149/Policy‐

Summary‐National‐Railway‐Infrastructure‐Plan
Financial Efficiency Metrics must be Open, Consistent, and Encourage Competition

Discussion: 

The metrics proposed in Section 273.9 Financial - state that “Adding frequency variable and route 

variable costs to calculate avoidable operating costs (ed. as proposed by the rule) does not make any 

distinction between short- and long-term avoidable costs, but results in a single avoidable cost figure for 

a single route at a future time. This approach represents a maximum saving, or cost avoided, and may be 

lower depending on the specific context of each individual route”. 

As such the proposed avoidable cost metric is deficient to the original legislative intent to report 

avoidable loss/cost as it is not actually the avoidable cost as Congress requested in Section 207 “Such 

metrics, at a minimum, shall include the percentage of avoidable and fully allocated operating costs 

covered by passenger revenues on each route...”3

 and lacks transparency. Further Congress has clarified 

elsewhere they desire to see reports including loss/cost that are on the “short-term avoidable” basis that 

have yet to be provided as required.4

Combining frequency variable and route variable costs together cannot work for this purpose as many 

physical rail lines have many routes, some even with differing state or federal sponsorship, such that the 

data is not parsed for determining this result. It appears that the FRA is simply using the recently 

developed Amtrak methods as a way to meet the statutory requirements to report these costs without 

performing detailed oversight of the grant to Amtrak even though the FRA previously determined that 

both short and long-term avoidable loss/costs were needed under the metrics determination and proceeded 

to report they did not have this data for a decade every quarter5

. I take this position after filing detailed 

Freedom of Information Act requests with both Volpe and the FRA6

 for any underlying data that they had 

developed under the original PRIIA financial metrics study funded almost a decade ago by federal 

spending but yet was told that neither group had such data. 

At the very least the FRA should provide some discussion and analysis 

I have included my own breakdown of a US private operator’s information from Security and Exchange 

Commission (SEC) filings to show the distinctions between Above-the-rail and Below-the-rail costs in 

the Appendix to demonstrate why a consumer service agency must be guided by such business metrics as 

well as why the public good is served by such a division. Congress clearly wanted additional information 

similar to this analysis as many are business oriented. At the very least the FRA should require reporting 

much more information, including the cost recovery as both a percentage of the frequency variable cost 

and as a percentage of the frequency and route variable cost if no additional data analysis is budgeted. 

However, a much more sensible way that the rule should adopt is to compare the revenue to the costs of 

only above-the-rail operations as a refined type of long-term avoidable cost as this would first be 

consistent with other United States modes such as highway and aviation and secondly is the path 

                                                            

3 49 USC Subtitle V, Part C (Ch. 241, §24101 ‐Section 207) 4 49 USC Subtitle V, Part C (Ch. 241, §24315) Reports and audits (a) Amtrak Annual Operations Report...(1) for each

route on which Amtrak provided intercity rail passenger transportation during the prior fiscal year, includes

information on‐ (A) ridership; (B) passenger‐miles; (C) the short‐term avoidable profit or loss for each passenger‐

mile; (D) the revenue‐to‐cost ratio; (E) revenues; (F) the United States Government subsidy; (G) the subsidy not

provided by the United States Government; and (H) on‐time performance. 5 FRA quarterly Metrics Statement ‐ 2010, https://cms8.fra.dot.gov/elibrary/rail‐service‐metrics‐and‐performance‐

quarter‐ended‐december‐31‐2010‐first‐quarter‐fiscal 6 FRA FOIA Request 2020‐102
increasingly taken by other western democracies as their competitive railway deregulation schemes 

mature and they see that infrastructure is a core government function. 

This is important as Section 208 required FRA to consider “(4) the methodologies of Amtrak and major 

intercity rail passenger transportation service providers in other countries for determining intercity 

passenger rail routes and service”7

In these countries the highway fuel tax is around ten times that in North America, so the effects of 

undercharging highway users are not as pronounced as here, however the European democracies are 

starting to consider infrastructure funding – and not just limited to capital - to support services instead of a 

mixed bag of general subsidies as they are extending the funding to the track usage fee that they 

previously tried to recover from fares for certain intra-state connectivity services. Track usage fees are 

Capital Leases or in other words the long-run average costs of infrastructure (below-the-rail). 

Investing in infrastructure only - though the average cost of both capital and operations - appears to be a 

much preferred way to accomplish governmental investment as the operator them becomes competitive in 

their service provisions toward the customer8

, who then is free to provide immediate feedback through 

purchases and as such the Customer Service metrics proposed in this rulemaking will require less agency 

oversight. 

In the United States highway infrastructure has such a low cost recovery rate (around 1/8th of the longterm average cost where even capital is variable with respect to use) that the division of costs between 

above-the-rail operations and below-the-rail infrastructure when combined with the assignable Tax Credit 

for infrastructure per operated train-mile would allow for beneficial modal neutrality to accomplish the 

USDOT’s efficiency goal below the point where commercial aviation becomes efficient which is a much 

longer trip than is commonly assumed when considering connecting at airports relative to overnight rail 

services when considering the Base Airfare to Trip Length chart in the Appendix. 

I have included an analysis of Amtrak’s cost centers for existing train operations indicating that the true 

revenue gap is already being spent on below-the-rail infrastructure facilities such as mainline leases, 

terminal yards, platforms, and risk protection. Incremental additions to service away from the congested 

corridor regions is already equivalent to the gap seen in highway funding due to leveraging on a personmile metrics. 

Thus an amicable path forward is to expand passenger capacity and volume per train-mile by running at 

least two round trips a day per route, utilizing the declining cost curve with respect to volume, so that all 

operational costs for a quality service are accounted for above-the-rail including ultimately equipment 

lease/ depreciation costs – everything that the average customer sees. Notably, this distance based metric 

could become a refundable or assignable federal tax credit, nimbly bringing the funds forward for 

reconstructing the shareholder owned general railway system mainlines and publicly held commuter lines 

and terminals as worked out in more detail for both freight and passenger rail operations in a recent 

paper9

. One can see that this method is both easily understood and can be rather easily defined by parsing 

the financial metrics in this rule. 

                                                            

7 49 USC Subtitle V, Part C (Ch. 241, §24101 ‐Section 208) 8 David Burroughs, “Subsidies could harm overnight train revival, AllRail warns,” July 18, 2019,

https://www.railjournal.com/regions/europe/subsidies‐could‐harm‐overnight‐train‐revival‐allrail‐warns/ 9 Virgil G. Payne, “National Railway Infrastructure Plan for Shareholder and Publicly Held Railways,” 2020,

https://www.scribd.com/document/443778048/National‐Infrastructure‐Plan‐for‐Shareholder‐and‐Publicly‐Held‐

Railways
Proposed Section 273.9 Financial Rule Revision: 

Define the Financial Metrics Thus: 

Short-Term Avoidable Cost = Amtrak’s Frequency Variable Cost Definition 

Long-Term Avoidable Cost = Above-the-Rail Operations * + Off-book Equipment Lease/Depreciation 

Long-Term Infrastructure Average Cost = Below-the-Rail Infrastructure Investment* 

Common System Fixed Cost = Amtrak’s Common System Fixed Cost Definition 

* Breakdown defined by FY2018 Amtrak Performance Tracking Cost Centers in Appendix 

Operational On-Time-Percentage Metrics for Monitoring Need Simple Enforcement Boundaries 

Discussion: 

Preference as exists in current law perhaps might not need to be mediated through the performance based 

metrics proposed in Section 273.5 On-Time Performance and Train Delays - as it is rather complicated 

to assign corrective infrastructure or operations action. While I take no issue with the all Customer OTP 

metric proposed in the metrics for monitoring, perhaps the FRA should work to define in very realistic 

terms what minimum boundary actions exhibit preference in the current operating environment, thus 

would be investigative targets for enforcement should the monitoring metrics fall out of bounds. The FRA 

could do so by publishing a paper of best practices. 

The first example might be that auto-routing of dispatching decisions authorizing train movements must 

be coded to create a plan of the next 90 minutes for train movements that provides a clear path assuming 

all goes well, continually reset against where the train is now compared to a table of pure running plus 

dwell time between upcoming control points. Should a train be unable to move, the established 

dispatching path might only be kept open for 15 minutes unless earlier consent to end it is given by the 

operating conductor by means of an update. Once movement is again possible the clear path decision tree 

test is again reinstated but it would only apply for the next future 90 minutes, staring just then. This test 

would not penalize a host railroad should their equipment function incorrectly or should there be 

interference at grade crossings but would penalize them for deficiencies in infrastructure configuration 

and maintenance timeliness. 

The second example might be that there needs to be some type of industry wide dispatching data transfer 

standard to hand off this 90 minute future look countdown clock at interchanges between railroads so that 

each dispatching plan provides for these movements. 

At some level the FRA is likely going to have to coordinate such data transfer and investigative 

methodology within the rule. These approaches could be easily auditable and could generate easily 

understood and assignable corrective action items at particular infrastructure points. The clear path could 

also vary, such that a railroad that meet the metrics consistently could see the 90 minutes drop to 60, 

while one that didn’t would see the 90 minutes increase. 

Proposed Section 273.5 On-Time Performance and Train Delays Addition: 

Include a statement of best practices in dispatching software code in the final rule. 

Appendix Charts Follow
Year

Interstate

Total VMT

(Millions)

Table VM‐

202, 203 &

VM‐1

Interstate

Combo &

Single Truck

VMT  

(Millions)

VM‐201&

VM‐1

HVUT, Trailer

& Truck tire

fees

(estimated)

prorated to

VMT          

Table FE‐101

1956‐1985    

Estimates

1986‐Current

Interstate Federal

Capital Expenditure

(Millions) Table FA‐

204 & FA‐3       1956

Reimbursement of

costs prior to 1956

per Sec. 1014 of

ISTEA 1991  

Interstate

Federal

Maintenance

Expenditure

(IM) (Millions)

Table FA‐204

& FA‐3 to

2011

Interstate Federal‐

State Capital    

(Millions)          10%

Match   Assumed    

Prior to 1981   Table

SF‐212A 1981‐1995  

Table SF‐12B 1994‐

2008   Table SF‐

12/A 2009‐2015

Interstate Federal‐

State Maintenance  

(Millions)   None

Assumed Prior to

1981            Table SF‐

212A 1981‐1995    

Table SF‐12B 1994‐

2008  Table SF‐12/A

2009‐2015

Resulting Federal‐

State user fees for

each year based on

VMT, Federal tax,

and MPG

Resulting Federal‐State

user capital repayment for

each year based on VMT,

Federal tax, MPG, and Fee

Test Ratio

Inflation

Factor Capital Cost ($2018) CPI Index

User Federal

Incremental

Taxes per

Automobile

VMT ($2018)

User State

Incremental

Taxes per

Automobile

VMT ($2018)

User

Federal &

State

Taxes per

Truck

VMT

($2018)

Aaa

Corporate

Bond Rate

(Est. prior

to 1976) Year

1‐Yr

Treasury

Rate

NPV Aaa Corporate

Bond Rate

NPV 1‐YR Treasury +

1% Rate

NPV Investor WACC

Rate

Rural Urban

1956 14.3 5.0 $4,967 $4,967 $4,967,000,000 9.2463 $45,926,216,418 26.8 1956

1957 3,243 3,563 14.3 5.0 $0.030 $0.030 $0.056 $0.056 $0.004 $400 $444 $40,836,000 $403,608,444 8.9783 $3,990,338,164 27.6 $0.019 $0.035 $0.190 5.61% 1957 3.11% $5,245,648,700 $5,171,143,700 $5,335,054,700

1958 6,264 6,658 14.3 5.0 $0.030 $0.030 $0.057 $0.057 $0.004 $1,700 $1,889 $78,164,545 $1,810,724,343 8.6643 $16,365,967,366 28.6 $0.018 $0.034 $0.186 4.07% 1958 1.57% $5,879,181,910 $5,718,023,275 $6,075,522,671

1959 9,775 10,222 14.3 5.0 $0.030 $0.030 $0.059 $0.059 $0.004 $2,200 $2,444 $123,897,497 $2,320,546,948 8.5448 $20,887,356,322 29.0 $0.018 $0.035 $0.187 5.81% 1959 3.31% $8,136,689,807 $7,853,236,640 $8,486,390,412

1960 10,514 13,365 14.3 5.0 $0.040 $0.040 $0.059 $0.059 $0.004 $2,487 $2,763 $165,984,098 $2,597,349,235 8.4573 $23,370,443,686 29.3 $0.024 $0.035 $0.204 5.71% 1960 3.21% $11,054,344,974 $10,602,099,877 $11,618,538,356

1961 13,091 16,952 14.3 5.0 $0.040 $0.040 $0.061 $0.061 $0.004 $1,782 $1,980 $211,981,727 $1,768,018,273 8.3154 $16,464,563,758 29.8 $0.023 $0.035 $0.204 4.45% 1961 1.95% $14,259,194,601 $13,588,832,862 $15,104,380,566

1962 22,001 22,180 14.3 5.0 $0.040 $0.040 $0.062 $0.062 $0.004 $2,178 $2,420 $314,519,287 $2,105,480,713 8.2600 $19,989,200,000 30.0 $0.023 $0.036 $0.204 5.60% 1962 3.10% $16,924,736,795 $15,986,482,031 $18,120,956,353

1963 27,536 27,674 14.3 5.0 $0.040 $0.040 $0.062 $0.062 $0.004 $2,370 $2,633 $394,577,762 $2,238,755,571 8.1513 $21,465,131,579 30.4 $0.023 $0.035 $0.203 5.86% 1963 3.36% $20,145,388,254 $18,880,772,320 $21,775,782,145

1964 33,595 33,833 14.3 5.0 $0.040 $0.040 $0.063 $0.063 $0.004 $2,567 $2,852 $486,141,734 $2,366,080,488 8.0194 $22,873,160,734 30.9 $0.022 $0.035 $0.201 6.35% 1964 3.85% $23,805,536,958 $22,143,824,994 $25,971,722,540

1965 40,310 40,380 14.5 5.0 $0.040 $0.040 $0.064 $0.064 $0.005 $2,652 $2,947 $579,298,552 $2,367,368,115 7.9423 $23,403,333,333 31.2 $0.022 $0.035 $0.201 6.65% 1965 4.15% $27,912,030,006 $25,772,165,614 $30,732,347,384

1966 48,900 50,414 8,918 14.5 5.0 $0.040 $0.040 $0.064 $0.064 $0.005 $2,765 $3,072 $876,663,512 $2,195,558,710 7.7925 $23,940,146,751 31.8 $0.021 $0.035 $0.198 7.70% 1966 5.20% $32,610,911,777 $29,884,184,820 $36,244,188,471

1967 54,847 56,317 9,887 14.5 5.0 $0.040 $0.040 $0.065 $0.065 $0.005 $2,955 $3,283 $983,797,041 $2,299,536,293 7.5319 $24,729,787,234 32.9 $0.021 $0.034 $0.193 7.38% 1967 4.88% $37,375,188,009 $33,966,032,449 $41,968,515,972

1968 62,300 63,973 10,597 14.5 5.0 $0.040 $0.040 $0.066 $0.066 $0.005 $3,362 $3,736 $1,124,815,155 $2,610,740,400 7.2669 $27,145,767,351 34.1 $0.020 $0.033 $0.190 8.19% 1968 5.69% $42,924,084,221 $38,691,735,291 $48,690,430,686

1969 71,821 73,195 11,268 14.5 5.0 $0.040 $0.040 $0.068 $0.068 $0.005 $3,752 $4,169 $1,302,460,509 $2,866,428,380 6.9607 $29,018,277,154 35.6 $0.019 $0.033 $0.187 9.62% 1969 7.12% $49,915,274,750 $44,656,236,717 $57,159,764,825

1970 79,516 81,532 12,035 13.5 5.5 $0.040 $0.040 $0.070 $0.070 $0.005 $3,940 $4,378 $1,522,306,231 $2,855,471,546 6.5556 $28,698,765,432 37.8 $0.019 $0.034 $0.167 9.40% 1970 6.90% $57,743,183,224 $51,276,955,639 $66,749,126,843

1971 89,542 90,117 13,600 13.5 5.5 $0.040 $0.040 $0.071 $0.071 $0.006 $3,920 $4,356 $1,717,021,300 $2,638,534,256 6.2261 $27,118,257,956 39.8 $0.018 $0.033 $0.162 7.39% 1971 4.89% $65,076,895,358 $57,320,827,147 $76,001,260,982

1972 99,024 100,556 15,668 13.5 5.5 $0.040 $0.040 $0.073 $0.073 $0.006 $3,964 $4,404 $1,958,183,410 $2,446,261,034 6.0292 $26,555,263,585 41.1 $0.018 $0.033 $0.160 7.45% 1972 4.95% $72,760,229,120 $63,526,943,406 $85,913,976,297

1973 107,085 108,462 18,354 13.5 5.5 $0.040 $0.040 $0.075 $0.075 $0.006 $3,964 $4,404 $2,182,553,767 $2,221,890,678 5.8169 $25,620,219,092 42.6 $0.017 $0.032 $0.158 9.82% 1973 7.32% $82,591,767,487 $71,462,175,050 $98,627,696,909

1974 104,621 109,304 19,205 13.5 5.5 $0.040 $0.040 $0.076 $0.076 $0.007 $2,543 $2,826 $2,202,869,047 $622,686,508 5.3176 $15,025,164,521 46.6 $0.016 $0.030 $0.148 10.70% 1974 8.20% $93,888,719,589 $80,462,999,774 $113,455,786,035

1975 111,980 118,232 20,347 13.9 5.5 $0.040 $0.040 $0.077 $0.077 $0.008 $2,965 $3,294 $2,343,964,050 $950,480,394 4.7562 $15,669,161,868 52.1 $0.014 $0.026 $0.137 9.28% 1975 6.78% $103,282,064,582 $87,394,152,675 $126,718,367,300

1976 117,885 132,698 22,723 13.9 5.5 $0.040 $0.040 $0.077 $0.077 $0.008 $3,235 $3,594 $2,586,971,895 $1,007,472,549 4.4568 $16,019,844,125 55.6 $0.013 $0.025 $0.131 8.43% 1976 5.88% $113,019,348,518 $94,422,743,825 $140,703,837,044

1977 126,149 141,639 25,231 13.9 5.5 $0.040 $0.040 $0.078 $0.078 $0.009 $3,112 $3,458 $2,812,708,328 $645,069,450 4.2359 $14,646,792,023 58.5 $0.012 $0.024 $0.127 8.02% 1977 6.08% $123,171,772,117 $102,186,675,694 $155,944,793,529

1978 136,125 156,793 28,145 13.9 5.5 $0.040 $0.040 $0.078 $0.078 $0.009 $3,263 $3,626 $3,114,405,673 $511,149,883 3.9648 $14,374,602,667 62.5 $0.011 $0.022 $0.121 8.73% 1978 8.34% $134,626,051,836 $112,436,230,140 $174,400,393,995

1979 133,597 159,452 29,230 13.9 5.5 $0.040 $0.040 $0.080 $0.080 $0.010 $3,280 $3,644 $3,207,841,703 $436,602,741 3.6281 $13,222,449,976 68.3 $0.010 $0.021 $0.115 9.63% 1979 10.65% $148,150,914,245 $126,105,749,796 $197,366,687,881

1980 135,084 161,242 30,651 15.9 5.7 $0.040 $0.040 $0.082 $0.082 $0.011 $3,261 $170 $4,992 $3,049,892,751 $1,942,315,249 3.1851 $15,900,631,650 77.8 $0.008 $0.017 $0.104 11.94% 1980 12.00% $166,328,866,514 $142,992,858,367 $227,006,968,450

1981 139,304 166,479 32,539 15.9 5.7 $0.040 $0.040 $0.092 $0.092 $0.013 $3,519 $170 $4,496 $3,426,444,788 $1,069,491,212 2.8483 $12,805,665,986 87.0 $0.007 $0.016 $0.102 14.17% 1981 14.80% $192,115,208,219 $167,834,931,047 $268,378,929,337

1982 142,546 175,879 33,705 15.9 5.7 $0.040 $0.040 $0.091 $0.096 $0.014 $3,519 $268 $4,198 $3,607,648,216 $590,152,784 2.6278 $11,030,912,914 94.3 $0.007 $0.015 $0.099 13.79% 1982 12.27% $219,824,869,483 $191,318,039,093 $312,511,667,121

1983 145,250 192,470 35,241 15.9 5.7 $0.090 $0.090 $0.098 $0.103 $0.014 $3,162 $780 $4,586 $5,259,174,048 $672,856,048 2.5337 $11,620,548,061 97.8 $0.014 $0.016 $0.122 12.04% 1983 9.58% $246,952,990,948 $212,212,078,578 $356,485,208,072

1984 149,139 204,304 37,118 15.9 5.7 $0.090 $0.150 $0.106 $0.114 $0.015 $3,599 $1,901 $5,959 $6,162,819,512 $203,341,512 2.4318 $14,492,234,037 101.9 $0.014 $0.016 $0.149 12.71% 1984 10.91% $277,582,340,046 $236,733,543,933 $408,436,998,888

1985 154,357 216,188 37,252 17.4 5.7 $0.090 $0.150 $0.111 $0.116 $0.015 $3,640 $2,758 $7,386 $6,157,081,609 $1,229,180,391 2.3488 $17,348,964,205 105.5 $0.012 $0.015 $0.146 11.37% 1985 8.42% $308,916,990,668 $258,811,347,490 $461,263,209,470

1986 159,498 232,017 38,863 17.4 5.7 $0.090 $0.150 $0.118 $0.121 $0.016 $3,483 $2,930 $7,391 $6,677,491,375 $713,082,625 2.2609 $16,709,710,193 109.6 $0.012 $0.015 $0.143 9.02% 1986 6.45% $338,121,355,688 $279,413,547,208 $512,404,568,575

1987 170,493 244,836 41,245 17.4 5.7 $0.091 $0.151 $0.128 $0.133 $0.016 $2,623 $2,541 $7,564 $7,421,901,097 $141,671,903 2.2284 $16,854,796,667 111.2 $0.012 $0.016 $0.147 9.38% 1987 6.77% $370,617,108,627 $301,892,468,971 $570,258,432,837

1988 181,315 258,695 42,871 17.4 5.7 $0.091 $0.151 $0.134 $0.140 $0.017 $2,771 $2,543 $7,344 $8,047,905,421 $703,835,421 2.1417 $15,729,131,772 115.7 $0.011 $0.017 $0.145 9.71% 1988 7.65% $406,759,458,119 $328,160,094,060 $637,057,060,980

1989 191,085 270,735 44,719 17.4 5.7 $0.091 $0.151 $0.142 $0.148 $0.018 $2,421 $2,543 $8,149 $8,712,476,042 $563,939,042 2.0462 $16,673,884,960 121.1 $0.011 $0.017 $0.143 9.26% 1989 8.53% $443,656,373,360 $358,662,840,087 $711,239,273,143

1990 200,173 278,901 46,123 20.2 5.9 $0.091 $0.151 $0.155 $0.160 $0.019 $2,733 $2,508 $8,707 $8,551,206,582 $156,282,418 1.9451 $16,936,544,538 127.4 $0.009 $0.015 $0.139 9.32% 1990 7.89% $484,388,649,197 $389,933,893,348 $792,744,121,683

1991 205,011 285,325 47,369 21.1 5.9 $0.141 $0.201 $0.176 $0.176 $0.020 $2,754 $2,528 $8,331 $10,600,975,072 $2,270,463,072 1.8410 $15,336,559,239 134.6 $0.012 $0.015 $0.154 8.77% 1991 5.86% $527,039,522,118 $416,850,361,824 $875,409,620,152

1992 205,557 303,265 48,857 21.0 5.9 $0.141 $0.201 $0.180 $0.183 $0.020 $1,630 $2,339 $9,363 $11,190,614,959 $1,827,356,959 1.7944 $16,800,979,959 138.1 $0.012 $0.015 $0.153 8.14% 1992 3.89% $567,485,260,452 $434,852,855,800 $953,817,215,194

1993 208,308 317,399 49,009 20.5 5.9 $0.141 $0.201 $0.183 $0.186 $0.021 $1,218 $2,795 $8,931 $11,775,281,051 $2,844,025,051 1.7377 $15,520,092,825 142.6 $0.012 $0.016 $0.150 7.22% 1993 3.43% $606,498,404,124 $452,208,528,440 $1,032,947,075,779

1994 215,568 330,577 51,618 20.7 5.9 $0.184 $0.244 $0.185 $0.189 $0.021 $1,061 $2,782 $9,651 $1,373 $13,705,299,950 $2,681,299,950 1.6949 $16,357,850,889 146.2 $0.015 $0.015 $0.160 7.97% 1994 5.32% $651,765,633,085 $477,764,340,002 $1,130,126,056,953

1995 223,382 341,528 55,136 21.1 5.9 $0.184 $0.244 $0.185 $0.190 $0.022 $1,329 $2,775 $9,949 $1,377 $14,173,055,421 $2,846,861,421 1.6487 $16,402,716,244 150.3 $0.014 $0.014 $0.157 7.59% 1995 5.94% $698,349,834,021 $508,053,803,032 $1,237,145,131,860

1996 232,565 351,579 58,710 21.1 5.9 $0.183 $0.243 $0.185 $0.190 $0.022 $1,000 $2,427 $10,522 $1,474 $14,787,839,706 $2,792,422,706 1.6049 $16,886,258,778 154.4 $0.014 $0.014 $0.154 7.37% 1996 5.52% $746,761,541,681 $538,146,434,205 $1,350,692,597,341

1997 240,255 361,433 62,283 21.1 5.9 $0.183 $0.243 $0.185 $0.190 $0.023 $1,082 $2,404 $11,007 $1,329 $15,417,397,742 $3,081,070,742 1.5575 $17,143,509,552 159.1 $0.014 $0.014 $0.150 7.27% 1997 5.63% $798,055,673,924 $570,847,982,461 $1,474,791,497,076

1998 251,520 374,622 64,000 21.1 5.9 $0.183 $0.243 $0.187 $0.195 $0.023 $595 $2,490 $10,924 $1,334 $16,103,486,023 $3,846,209,023 1.5334 $16,750,504,092 161.6 $0.013 $0.014 $0.150 6.53% 1998 5.05% $846,886,444,770 $602,116,809,878 $1,600,308,483,387

1999 260,166 383,259 66,000 21.1 5.9 $0.183 $0.243 $0.191 $0.202 $0.024 $329 $3,199 $12,953 $1,479 $16,769,299,195 $2,337,021,195 1.5082 $19,536,542,951 164.3 $0.013 $0.014 $0.150 7.05% 1999 5.08% $902,474,572,367 $634,645,453,387 $1,741,133,685,667

2000 268,180 393,465 67,849 21.1 5.9 $0.183 $0.243 $0.200 $0.200 $0.025 $217 $3,597 $14,112 $1,724 $17,521,141,665 $1,685,001,665 1.4680 $20,716,424,982 168.8 $0.013 $0.014 $0.146 7.62% 2000 6.11% $968,728,032,571 $677,265,561,721 $1,909,476,945,056

2001 274,024 399,890 68,685 21.1 5.9 $0.183 $0.243 $0.193 $0.204 $0.025 $158 $3,793 $14,263 $1,725 $17,730,055,871 $1,742,891,871 1.4152 $20,184,255,348 175.1 $0.012 $0.013 $0.143 7.08% 2001 3.49% $1,035,509,677,495 $705,914,127,203 $2,068,885,895,091

2002 279,962 408,618 69,520 21.1 5.9 $0.183 $0.243 $0.202 $0.197 $0.026 $128 $4,414 $15,320 $1,806 $18,263,941,819 $1,137,309,819 1.3992 $21,436,370,656 177.1 $0.012 $0.013 $0.140 6.49% 2002 2.00% $1,100,858,250,011 $725,296,372,392 $2,222,054,699,882

2003 269,945 432,633 79,427 21.1 5.9 $0.183 $0.243 $0.191 $0.200 $0.026 $79 $3,893 $15,093 $1,900 $19,097,379,193 $2,103,881,193 1.3638 $20,584,196,394 181.7 $0.012 $0.012 $0.138 5.66% 2003 1.24% $1,161,965,145,406 $740,380,225,574 $2,369,541,181,806

2004 266,996 454,385 89,334 22.5 5.9 $0.183 $0.243 $0.191 $0.194 $0.027 $117 $3,822 $13,685 $1,658 $19,533,770,082 $4,190,243,082 1.3380 $18,310,830,441 185.2 $0.011 $0.011 $0.135 5.63% 2004 1.89% $1,225,161,453,389 $759,612,530,734 $2,531,595,403,037

2005 258,790 469,070 91,771 22.9 5.9 $0.183 $0.243 $0.193 $0.200 $0.028 $20 $4,082 $15,063 $2,213 $19,863,778,218 $2,587,774,218 1.2994 $19,572,796,811 190.7 $0.010 $0.011 $0.134 5.23% 2005 3.62% $1,284,828,004,606 $790,322,797,342 $2,714,079,305,070

2006 257,915 477,287 90,322 22.5 5.9 $0.183 $0.243 $0.203 $0.205 $0.029 $6 $4,373 $16,752 $2,281 $20,519,607,354 $1,486,617,354 1.2496 $20,934,130,254 198.3 $0.010 $0.011 $0.131 5.59% 2006 4.94% $1,353,917,459,266 $834,526,483,497 $2,931,935,792,310

2007 256,438 483,315 119,778 22.9 6.0 $0.183 $0.243 $0.193 $0.205 $0.029 $4 $4,000 $19,375 $2,104 $22,634,079,501 $1,155,759,501 1.2243 $23,720,721,113 202.4 $0.010 $0.010 $0.127 5.56% 2007 4.53% $1,427,625,996,722 $879,106,970,740 $3,163,361,275,381

2008 243,221 476,114 114,358 23.7 6.0 $0.183 $0.243 $0.205 $0.208 $0.031 $3 $4,901 $20,010 $2,505 $21,996,877,623 $517,777,377 1.1740 $23,490,749,710 211.1 $0.009 $0.010 $0.124 5.63% 2008 1.83% $1,506,780,511,577 $902,797,230,517 $3,380,713,917,027

2009 242,178 474,798 105,758 23.5 6.0 $0.183 $0.243 $0.208 $0.214 $0.032 $46 $4,622 $14,782 $4,118 $21,600,390,360 $2,700,565,360 1.1736 $17,348,248,641 211.1 $0.009 $0.010 $0.127 5.31% 2009 0.47% $1,587,335,828,098 $916,593,738,511 $3,589,988,939,217

2010 245,647 477,693 110,626 23.3 5.9 $0.183 $0.243 $0.218 $0.224 $0.032 $10 $5,000 $14,228 $5,971 $22,839,112,450 $2,639,420,450 1.1436 $16,271,439,516 216.7 $0.009 $0.011 $0.127 4.94% 2010 0.32% $1,662,916,244,717 $925,956,563,036 $3,798,651,404,844

2011 243,587 476,704 105,052 23.1 5.8 $0.183 $0.243 $0.214 $0.224 $0.032 $14 $5,000 $14,228 $5,971 $22,381,177,540 $2,181,485,540 1.1252 $16,010,177,931 220.2 $0.009 $0.010 $0.127 4.64% 2011 0.17% $1,737,313,668,913 $934,119,953,155 $4,010,562,581,753

2012 245,872 484,548 108,226 23.3 5.8 $0.183 $0.243 $0.216 $0.219 $0.032 $20,492 $3,533 $22,746,713,755 $1,278,852,245 1.0931 $22,399,758,029 226.7 $0.009 $0.010 $0.122 3.64% 2012 0.17% $1,798,290,994,848 $942,842,147,686 $4,210,884,509,193

2013 234,303 505,309 112,248 23.4 5.8 $0.183 $0.243 $0.219 $0.223 $0.032 $21,208 $3,668 $23,388,312,067 $1,487,687,933 1.0760 $22,819,550,152 230.3 $0.008 $0.010 $0.121 4.27% 2013 0.13% $1,876,411,479,564 $954,789,567,231 $4,440,209,885,827

2014 231,371 519,843 113,413 23.4 5.8 $0.183 $0.243 $0.226 $0.238 $0.032 $25,305 $3,843 $24,165,766,686 $4,982,233,314 1.0626 $26,889,275,300 233.2 $0.008 $0.010 $0.122 4.25% 2014 0.11% $1,957,709,882,116 $966,891,932,696 $4,681,282,740,889

2015 235,765 541,186 115,858 23.4 5.8 $0.183 $0.243 $0.250 $0.237 $0.032 $24,389 $3,324 $25,548,069,842 $2,164,930,158 1.0603 $25,860,480,103 233.7 $0.008 $0.011 $0.122 4.19% 2015 0.30% $2,044,928,915,067 $984,508,530,169 $4,940,916,612,902

2016 246,716 558,388 120,881 23.4 5.8 $0.183 $0.243 $0.251 $0.250 $0.032 $24,000 $3,200 $26,825,840,876 $374,159,124 1.0460 $25,104,263,402 236.9 $0.008 $0.011 $0.122 3.50% 2016 0.60% $2,118,742,129,808 $1,002,460,235,692 $5,197,155,934,373

2017 252,550 567,210 124,118 23.4 5.8 $0.183 $0.243 $0.251 $0.250 $0.032 $24,000 $3,200 $27,416,260,513 $216,260,513 1.0206 $24,494,233,937 242.8 $0.008 $0.011 $0.119 3.68% 2017 1.17% $2,197,099,768,365 $1,024,595,901,184 $5,482,146,841,417

2018 260,000 570,000 130,000 23.4 5.8 $0.183 $0.243 $0.251 $0.250 $0.032 $24,000 $3,200 $28,185,422,930 $985,422,930 1.0000 $24,000,000,000 247.8 $0.008 $0.011 $0.117 3.96% 2018 2.25% $2,283,880,094,763 $1,057,671,978,993 $5,815,012,683,000

Current 10,133,757 16,238,701 3,105,740 2006, 2016‐2018 Not Found, Estimated $1,243,506,153,327 $0.014 $0.020 $0.149

NPV AAA Corporate

Bond Rate

NPV 1‐YR Treasury +

1% Rate

NPV Investor WACC

Rate

29,478,198 Total Route Miles 46,876 $0.087 $0.036 $0.197

1956 Incorporated Toll Route Miles 2,300 % Fuel Tax Rate 293% 121% 668%

Federal‐State $2018 per Total Route M $26,527,565 $35,274,130 $23,503,822 $129,222,504

Test Ratio for Historical Fees 1.00

Truck (N‐1) Prorate

Total Cost Ratio

Automobile 100% $0.064 $0.024 $0.093

Class 8 Truck 400% $0.256 $0.095 $0.370

Mileage Rural 85% Rural 170% $0.109 $0.040 $0.157

Mileage Urban at 3x Cost per Mile 15% Urban 56% $0.036 $0.013 $0.052

Rural‐Urban Cost Assignment $2018 Adjusted Route Gap by Ownership Method (No Cost‐VMT elasticity)

Note: NHS category now used for major Interstate Capital and STP for bond financed new Interstate

routes, Capital costs after 1998 don't reflect this as the data is not broken out by FHWA, several values

extended 2016‐2018 due to lack of FHWA reports

Gap per Route Mile

Fee Gap per Total VMT

Additional funds per VMT to make up Gap ‐ add to existing fuel fees

Miles per Gallon   

VM‐1             

Gasoline      Diesel

Federal Fee per

Gallon              

Gasoline      Diesel

State Average Fee

per Gallon          

Table MF‐205       

(Not Pro‐rated by

Quantity)           

1957‐1995          

Gasoline      Diesel

Analysis of Original Interstate Highway Long‐run Average Construction and Rebuilding Costs relative to Fuel Taxes and Fees Collected for Use of System

Total Urban & Rural  VMT
Year

Interstate

Combo &

Single

Truck

VMT  

(Millions)

Est.

HVUT, Trailer

& Truck tire

fees

(estimated)

prorated to

VMT

At 90%‐10%

Split Interstate

Federal Capital

Expenditure

(Millions)

Interstate

Federal

Maintenance

Expenditure

(Millions)

Resulting

Federal user

fees for each

year based on

VMT, Federal

tax, and MPG

Resulting Federal user

capital repayment for

each year based on VMT,

Federal tax, MPG, and

Fee Test Ratio

Inflation

Factor

Capital Cost in

2012 Dollars

AAA

Corporat

e Bond

Rate

1‐Yr

Treasury

Rate

NPV AAA Corporate

Bond Rate

NPV 1‐YR Treasury +

1% Rate

NPV Investor WACC

Rate

Rural Urban

2005 22.9 5.9 $0.183 $0.243 $0.032 $0 $0 1.0000 $0 2005 5.23% 2005 3.62% 0.0161 $0 $0 $0

2006 22.5 5.9 $0.183 $0.243 $0.032 $0.006 $0 $6,000 1.0000 $6,000 2006 5.59% 2006 4.94% 0.0065 $0 $0 $0

2007 22.9 6.0 $0.183 $0.243 $0.032 0.783 $0 $783,000 1.0000 $783,000 2007 5.56% 2007 4.53% 0.0103 $6,334 $6,332 $6,477

2008 23.7 6.0 $0.183 $0.243 $0.032 6.683 $0 $6,683,000 1.0000 $6,683,000 2008 5.63% 2008 1.83% 0.038 $833,773 $811,670 $844,030

2009 24.7 6.1 $0.183 $0.243 $0.032 14.116 $0 $14,116,000 1.0000 $14,116,000 2009 5.31% 2009 0.47% 0.0484 $7,915,914 $7,604,842 $7,991,749

2010 25.7 6.2 $0.183 $0.243 $0.032 66.755 $0 $66,755,000 1.0000 $66,755,000 2010 4.94% 2010 0.32% 0.0462 $23,120,290 $22,007,557 $23,410,337

2011 26.7 6.3 $0.183 $0.243 $0.032 24.577 $0 $24,577,000 1.0000 $24,577,000 2011 4.64% 2011 0.17% 0.0447 $94,045,504 $89,801,079 $95,261,482

2012 26.7 6.4 $0.183 $0.243 $0.032 34.023 $0 $34,023,000 1.0000 $34,023,000 2012 3.64% 2012 0.17% 0.0347 $122,940,363 $115,716,302 $125,892,722

2013 26.7 6.5 $0.183 $0.243 $0.032 101.622 $0 $101,622,000 1.0000 $101,622,000 2013 4.27% 2013 0.13% 0.0414 $163,665,698 $151,431,356 $168,573,559

2014 26.7 6.7 $0.183 $0.243 $0.032 140.696 $0 $140,696,000 1.0000 $140,696,000 2014 4.25% 2014 0.11% 0.0414 $276,562,426 $255,862,248 $284,769,908

2015 26.7 6.7 $0.183 $0.243 $0.032 88.898 $0 $88,898,000 1.0000 $88,898,000 2015 4.19% 2015 0.30% 0.0389 $434,741,554 $401,713,506 $448,585,725

2016 26.7 6.7 $0.183 $0.243 $0.032 63.343 $0 $63,343,000 1.0000 $63,343,000 2016 3.50% 2016 0.60% 0.029 $541,966,938 $498,461,290 $565,110,389

2017 26.7 6.7 $0.183 $0.243 $0.032 54.091 $0 $54,091,000 1.0000 $54,091,000 2017 3.68% 2017 1.17% 0.0251 $627,585,344 $573,995,443 $662,867,496

2018 104 13 26.7 6.7 $0.183 $0.243 $0.032 36.451 $24,870,601 $11,580,399 1.0000 $36,451,000 2018 3.96% 2018 2.25% 0.0171 $708,670,727 $648,499,252 $760,520,894

2019 111 13 26.7 6.7 $0.183 $0.243 $0.032 $26,362,837 $26,362,837 1.0000 $0 2019 4.00% 2019 2.00% 0.02 $749,061,171 $679,882,041 $818,427,371

2020 117 14 26.7 6.7 $0.183 $0.243 $0.032 $27,855,073 $27,855,073 1.0000 $0 2020 4.00% 2020 2.00% 0.02 $751,606,268 $673,124,780 $839,588,406

2021 123 15 26.7 6.7 $0.183 $0.243 $0.032 $29,347,309 $29,347,309 1.0000 $0 2021 4.00% 2021 2.00% 0.02 $752,701,243 $664,627,799 $860,437,333

2022 129 16 26.7 6.7 $0.183 $0.243 $0.032 $30,839,545 $30,839,545 1.0000 $0 2022 4.00% 2022 2.00% 0.02 $752,288,091 $654,338,904 $880,955,426

2023 136 16 26.7 6.7 $0.183 $0.243 $0.032 $32,331,781 $32,331,781 1.0000 $0 2023 4.00% 2023 2.00% 0.02 $750,306,488 $642,204,340 $901,122,834

2024 142 17 26.7 6.7 $0.183 $0.243 $0.032 $33,824,017 $33,824,017 1.0000 $0 2024 4.00% 2024 2.00% 0.02 $746,693,695 $628,168,736 $920,918,516

2025 148 18 26.7 6.7 $0.183 $0.243 $0.032 $35,316,253 $35,316,253 1.0000 $0 2025 4.00% 2025 2.00% 0.02 $741,384,465 $612,175,060 $940,320,169

2026 154 19 26.7 6.7 $0.183 $0.243 $0.032 $36,808,489 $36,808,489 1.0000 $0 2026 4.00% 2026 2.00% 0.02 $734,310,940 $594,164,571 $959,304,151

2027 161 19 26.7 6.7 $0.183 $0.243 $0.032 $38,300,725 $38,300,725 1.0000 $0 2027 4.00% 2027 2.00% 0.02 $725,402,549 $574,076,765 $977,845,401

2028 167 20 26.7 6.7 $0.183 $0.243 $0.032 $39,792,961 $39,792,961 1.0000 $0 2028 4.00% 2028 2.00% 0.02 $714,585,897 $551,849,320 $995,917,356

2029 171 21 26.7 6.7 $0.183 $0.243 $0.032 $40,787,785 $40,787,785 1.0000 $0 2029 4.00% 2029 2.00% 0.02 $701,784,653 $527,418,050 $1,013,491,859

2030 175 21 26.7 6.7 $0.183 $0.243 $0.032 7.600 $41,807,480 $34,207,480 1.0000 $7,600,000 2030 4.00% 2030 2.00% 0.02 $687,436,742 $501,229,173 $1,031,066,318

2031 180 22 26.7 6.7 $0.183 $0.243 $0.032 7.600 $42,852,667 $35,252,667 1.0000 $7,600,000 2031 4.00% 2031 2.00% 0.02 $679,358,433 $481,032,343 $1,056,670,368

2032 184 22 26.7 6.7 $0.183 $0.243 $0.032 7.600 $43,923,984 $36,323,984 1.0000 $7,600,000 2032 4.00% 2032 2.00% 0.02 $669,869,997 $459,153,067 $1,082,702,763

2033 189 23 26.7 6.7 $0.183 $0.243 $0.032 $45,022,083 $45,022,083 1.0000 $0 2033 4.00% 2033 2.00% 0.02 $658,887,854 $435,513,956 $1,109,161,506

2034 194 23 26.7 6.7 $0.183 $0.243 $0.032 $46,147,635 $46,147,635 1.0000 $0 2034 4.00% 2034 2.00% 0.02 $638,420,401 $402,206,629 $1,127,987,789

2035 199 24 26.7 6.7 $0.183 $0.243 $0.032 $47,301,326 $47,301,326 1.0000 $0 2035 4.00% 2035 2.00% 0.02 $615,963,677 $366,740,763 $1,146,750,562

2036 204 24 26.7 6.7 $0.183 $0.243 $0.032 $48,483,859 $48,483,859 1.0000 $0 2036 4.00% 2036 2.00% 0.02 $591,408,844 $329,022,620 $1,165,416,190

2037 209 25 26.7 6.7 $0.183 $0.243 $0.032 $49,695,956 $49,695,956 1.0000 $0 2037 4.00% 2037 2.00% 0.02 $564,641,984 $288,954,923 $1,183,948,271

2038 214 26 26.7 6.7 $0.183 $0.243 $0.032 $50,938,355 $50,938,355 1.0000 $0 2038 4.00% 2038 2.00% 0.02 $535,543,870 $246,436,737 $1,202,307,454

2039 219 26 26.7 6.7 $0.183 $0.243 $0.032 $52,211,814 $52,211,814 1.0000 $0 2039 4.00% 2039 2.00% 0.02 $503,989,736 $201,363,333 $1,220,451,245

2040 225 27 26.7 6.7 $0.183 $0.243 $0.032 $53,517,109 $53,517,109 1.0000 $0 2040 4.00% 2040 2.00% 0.02 $469,849,039 $153,626,065 $1,238,333,798

2041 230 28 26.7 6.7 $0.183 $0.243 $0.032 $54,855,037 $54,855,037 1.0000 $0 2041 4.00% 2041 2.00% 0.02 $432,985,207 $103,112,225 $1,255,905,690

2042 236 28 26.7 6.7 $0.183 $0.243 $0.032 11.440 $56,226,413 $44,786,413 1.0000 $11,440,000 2042 4.00% 2042 2.00% 0.02 $393,255,377 $49,704,904 $1,273,113,693

2043 242 29 26.7 6.7 $0.183 $0.243 $0.032 11.440 $57,632,073 $46,192,073 1.0000 $11,440,000 2043 4.00% 2043 2.00% 0.02 $362,407,723 $5,066,046 $1,302,026,917

2044 248 30 26.7 6.7 $0.183 $0.243 $0.032 11.440 $59,072,875 $47,632,875 1.0000 $11,440,000 2044 4.00% 2044 2.00% 0.02 $328,864,276 $42,359,807 $1,331,184,935

2045 254 30 26.7 6.7 $0.183 $0.243 $0.032 $60,549,697 $60,549,697 1.0000 $0 2045 4.00% 2045 2.00% 0.02 $292,480,658 $92,692,463 $1,360,565,183

2046 261 31 26.7 6.7 $0.183 $0.243 $0.032 $62,063,439 $62,063,439 1.0000 $0 2046 4.00% 2046 2.00% 0.02 $241,208,200 $157,839,424 $1,378,016,416

2047 267 32 26.7 6.7 $0.183 $0.243 $0.032 $63,615,025 $63,615,025 1.0000 $0 2047 4.00% 2047 2.00% 0.02 $186,310,551 $226,499,949 $1,394,910,156

2048 274 33 26.7 6.7 $0.183 $0.243 $0.032 $65,205,401 $65,205,401 1.0000 $0 2048 4.00% 2048 2.00% 0.02 $127,603,347 $298,818,423 $1,411,172,839

2049 281 34 26.7 6.7 $0.183 $0.243 $0.032 $66,835,536 $66,835,536 1.0000 $0 2049 4.00% 2049 2.00% 0.02 $64,893,864 $374,944,538 $1,426,725,484

2050 288 35 26.7 6.7 $0.183 $0.243 $0.032 $68,506,424 $68,506,424 1.0000 $0 2050 4.00% 2050 2.00% 0.02 $2,019,338 $455,033,476 $1,441,483,346

Total 6,434 772 $0.007 $0.036 $632 $689,164,000

Constructed Route Miles 28.6

$/Total

VMT $0.000 $0.063 $0.200

$2012 per Constructed Route Mile $24,096,643

Deficit per

Route Mile $70,606 $15,910,261 $50,401,516

Test Ratio for Fees 16.75

Truck (N‐1) Prorate

Total Cost Ratio Total Cost Ratio

Automobile 100% $0.000 $0.052 $0.165

Class 8 Truck 400% $0.001 $0.208 $0.659

Computed Cost Responsibility per Class at VMT

Automobile 65%

Class 8 Truck 35%

Additional funds per VMT to make up capital deficit ‐ add to existing fuel fees

Analysis of Recently Constructed Interstate Highway Long‐Run Average Construction and Rebuilding Costs relative to Fuel Taxes and Fees Collected for Use of System

Interstate Total VMT

(Millions) Estimated

Miles per Gallon   

Gasoline      Diesel

Federal Fee per Gallon  

Gasoline      Diesel
y = 67.478x-0.805

$0.00

$0.10

$0.20

$0.30

$0.40

$0.50

$0.60

$0.70

$0.80

$0.90

$1.00

200 400 600 800 1,000 1,200 1,400 1,600 1,800 2,000

2018 Base Airfare with respect to Trip Length

(Passenger Fees & Airport Access as well as

Government Infrastructure Investment Excluded)

Expressed in $2018

Low Volume Routes

High Volume Routes

Average (Power)

Trip Length in (Air) Miles - Data from Quarter 3 USDOT Bureau of Transportation Statistics Fare per Passenger (Air) Mile
Family Family Name Subfamily 

Number Subfamily Name

Operating 

Costs 

(Millions)

Percent

of Amtrak 

Fully 

Allocated 

Costs

Operating

and Capital 

Costs 

(Millions)

% of 

Operating 

and Capital

FM_101 Central Div MoW $19.90 0.5% $26.30 0.5% X $26.30

FM_102 MidAtlantic Div MoW $93.20 2.2% $150.30 2.7% X $150.30

FM_103 New England Div

MoW

$59.10 1.4% $85.30 1.5% X $85.30

FM_104 New York Div

MoW

$110.10 2.6% $140.10 2.5% X $140.10

FM_105 MoW Support $113.80 2.7% $572.60 10.4% X $572.60

FM_106 System Gangs $8.60 0.2% $114.00 2.1% X $114.00

FM_107 West Div MoW $11.10 0.3% $11.20 0.2% X $11.20

FM_108 Empire District $10.70 0.3% $14.70 0.3% X $14.70

FM_109 Michigan Line $10.30 0.2% $10.40 0.2% X $10.40

FM_201 MoE Turnaround $163.00 3.9% $163.30 3.0% X $163.30

FM_202 MoE Loco

Maintenance

$88.30 2.1% $88.50 1.6% X $88.50

FM_203 MoE Car

Maintenance

$38.00 0.9% $38.00 0.7% X $38.00

FM_204 MoE Support $39.10 0.9% $44.00 0.8% X $44.00

FM_205 MoE Multiple $186.60 4.4% $344.00 6.2% X $344.00

FM_206 MoE HSR

Maintenance

$57.60 1.4% $58.20 1.1% X $58.20

FM_207 MoE Back Shop $18.00 0.4% $79.10 1.4% X $79.10

FM_208 MoE Material Control $10.60 0.3% $10.60 0.2% X $10.60

FM_301 On Board Services

(OBS)

$262.70 6.2% $262.70 4.8% X $262.70

FM_302 T&E $438.40 10.4% $438.40 7.9% X $438.40

FM_303 Yard $71.00 1.7% $71.20 1.3% X $71.20

FM_304 Fuel $128.10 3.0% $128.10 2.3% X $128.10

FM_305 Transportation -

Multiple

$11.50 0.3% $11.50 0.2% X $11.50

FM_306 Train Movement $86.70 2.0% $86.80 1.6% X $86.80

FM_307 Train Movement - 

Host RR

$152.30 3.6% $160.10 2.9% X $160.10

FM_308 Transportation

Support

$77.60 1.8% $149.80 2.7% X $149.80

FM_309 Power - Electric

Traction

$81.10 1.9% $81.10 1.5% X $81.10

FM_310 Stations $196.90 4.7% $196.90 3.6% X $196.90

FM_401 Sales $10.30 0.2% $10.30 0.2% X $10.30

FM_402 Information &

Reservations

$73.00 1.7% $73.00 1.3% X $73.00

FM_403 Marketing $54.90 1.3% $77.40 1.4% X $77.40

FM_404 Station and On- Board 

Technology

$5.00 0.1% $5.00 0.1% X $5.00

FM_601 Corporate

Administration

$144.10 3.4% $190.30 3.4% X $190.30

FM_602 Centralized

Services

$237.20 5.6% $296.40 5.4% X $296.40

FM_603 Qualified Mgmt $971.50 23.0% $1,015.60 18.4% X $1,015.60

FM_604 Direct Customer (NonNTS)$49.40 1.2% $154.10 2.8% X $154.10

FM_605 Subsidiary $39.20 0.9% $39.20 0.7% X $39.20

FM_UTILI

TIES

Utilities FM_801 Utilities $5.80 0.1% $5.80 0.1% X $5.80

FM_901 Police $58.90 1.4% $60.90 1.1% X $60.90

FM_902 Emergency Mgmt

& Corp Security

$28.40 0.7% $34.40 0.6% X $34.40

FM_903 Environmental &

Safety

$7.40 0.2% $22.30 0.4% X $22.30

$4,229.10 100% $5,521.60 100% $1,917.90 $3,604.00

Reconcilliation of APT Formula to Actual FY2018 Costs and Revenues

FY2018 Federal Government Investment after FRA witholding1 $1,924.90

Below-the-Rail Infrastrucutre Remaining to be Covered by Operations ($7.00) $7.00

Actual FY2018 Total Operating, Capital, Interest, Pensions, Tax, and Net Change in Cash1 $5,063.70

APT Formulaic Cost Above Actual FY2018 Costs $457.90 9.0% $ (457.90)

Total Above-the-Rail Operations Cost + Remaining Infrastructure Cost $ 3,153.10

$ 3,386.70

1. Consolidated Financial Statements National Railroad Passenger Corporation and Subsidiaries (Amtrak) for FY2018 

FM_OPS_ 

TRANS

Ops - 

Transportation

FM_SALES

_MKTG

Sales and 

Marketing

Actual FY2018 Total Revenues (Tickets, State Contributions, Ancillary, and Other Core) 1

Below-the-Rail 

Infrastructure Investment 

(Mostly Fixed with Respect 

to Train Movements)

Above-the-Rail Operations 

(Mostly Variable with 

Respect to Train 

Movements)

APT Average Costs FY2018 Dollars (Millions) - 

Responsibility for Infrastructure and Operations parsed per 

Highway and Aviation Divisions

FM_G_A General and 

Administrative

Table B-2. Fully Allocated Costs by Subfamily, Pre-Audit FY2018 Dollars (Millions)

This table provides the allocated costs of each APT Subfamily.

FM_MOW Maintenance of 

Way

FM_MOE Maintenance of 

Equipment

FM_POLIC 

E_SAFETY

Police, 

Environmental & 

Safety

Grand Total

FM_OPS_ 

TRANS

Ops - 

Transportation
AAF/Brightline/Virgin SEC Data (Made Parametric) Parametric Benchmark

Miami to Orlando One-way Route (Miles) 235 235

Average Schedule Speed (MPH) 74.4 74.4

Utilization Miles per Hour - Full Schedule Cycle 58.9 58.9

Est. Cycles per Day 1.5 1.5

Trip Time (Hours) 3.16 3.16

Departure Terminal Dwell (Hours) 1.08 1.08

Turning Terminal Dwell (Hours) 0.58 0.58

Total Round Trip Cycle Time 8.0 8.0

Miles per Day 942 942

Train-Miles (Millions) 2.747 2.747

Train-Hours 23,329 23,329

Seats per Train-Mile 622 348

Seat-Miles (Millions) 1,708.435 955.845

Car-Miles (Millions) 32.960 19.227

Equipment Sets 10 10

Annual Train-miles per Set (Millions) 0.275 0.275

Locomotives per Set 2 2

First Class Coaches per Set 5 2

Seats per Car 50 50

Business Class Coaches per Set 6 4

Seats per Car 62 62

Café Cars per Set 1 1

Total Car per Set 12 7

Stated Total Operating Labor $45.9

Corporate, Station, and Parking Garage Operating Expense

Est. Station and Parking Garage Operating Labor Portion $14.0 $14.0

Est. Corporate Operating Labor Portion $10.6 $10.6

Marketing & Advertising $2.2 $2.2

Station Expense $3.6 $3.6

Information Technology $7.9 $7.9

Parking Garage $5.6 $5.6

Other G & A $2.8 $2.8

Total $46.7 $46.7

Above-the-Rail Operating and Maintenance Expense

Est. Rail Operations Labor $21.3 $21.3

Maintenance of Equipment $16.4 $11.3

Fuel $22.3 $16.4

Maintenance Facility $3.5 $3.5

Est. Equipment Development & Testing $172.5

Est. Equipment Cost Variable wrt Pieces $521.5

Est. Total Equipment Cost $694.0 $549.0

Est. Equipment Lease Payment/ Depreciation / Parts $55.52 $43.9

VMA - Heavy Maintenance and Parts Contract $24.0 $14.0

Total $143.1 $110.4

Sales and Consumables Expense

Credit Card Fees $27.2 $15.2

Passenger Meal Costs $21.4 $12.0

Above-the-Rail and Below-the-Rail Financial Analysis
Complimentary Meal Costs $9.1 $5.1

Total $57.7 $32.3

Below-the-Rail Infrastructure Maintenance Expense

Maintenance of Way $18.5 $18.5

Insurance (Risk on Infrastructure Use) $7.7 $7.7

Total $26.2 $26.2

Below-the-Rail Infrastructure Capital Depreciation

Railway Track and Signal Depreciation $128.4 $128.4

Land Lease - Right of Way $8.3 $8.3

Total $136.7 $136.7

Above-the-Rail Train Operating and Equipment Expense (Train-mile) $52.08 $40.20

Above-the-Rail per Car-Mile $4.34 $5.74

Above-the-Rail per Seat-Mile $0.084 $0.116

Above-the-Rail Sales and Consumables Expense (Train-mile) $21.02 $11.76

Common - Parking, Station, and Corporate Expense (Train-mile) $17.00 $17.00

Total Operating (Millions Annually) $247.50 $189.42

Total Operating (Train-mile) $90.11 $68.96

Total Operating (Seat-mile) $0.145 $0.198

Total Operating per Person-Mile at 60% Occupancy $0.241 $0.330

Below-the-Rail Infrastructure Maintenance (Train-mile) $9.54 $9.54

Below-the-Rail Infrastructure Capital Depreciation (Train-mile) $49.75 $49.75

Total Infrastructure Investment per Person-mile at 60% Occupancy $0.159 $0.284

Proposed Below-the-Rail Tax Credits for Infrastructure Investment Equivalent to Highway Revenue Gap

Proposed Tax Credit per Passenger Train-Mile $17.20 $17.20

Proposed Tax Credit per Intermodal Freight Train-Mile $21.00 $21.00

Remaining Below-the-rail Infrastructure covered by Direct Consumer Revenue after Tax Credit

Below-the-Rail Infrastructure Investment Remaining (Train-mile) $21.09 $21.09

Total Infrastructure Investment per Person-mile at 60% Occupancy $0.057 $0.101

Below-the-Rail Infrastructure Investment Analysis (Long-run Average Cost)

Above-the-Rail and Common Operating Analysis (Long-run Average Cost)