The Honorable Ann D. Begeman 

Acting Chairman 

Surface Transportation Board 

395 E Street, SW. 

Washington, D.C. 20423 

Dear Acting Chairman Begeman: 

USDA 

iiiii 

United States Department of Agriculture 

Office of the Secretary 

Washington, D.C. 20250 

SEP 07 2017 

I am writing to you about service problems facing agricultural shippers who move their products by 

rail on CSX. Changes in CSX's operations are causing delays, increased costs, and decreased 

production. I support your recent efforts to address the problem and offer additional suggestions. 

Agriculture is a fundamental and vital component of our country's economy, contributing 

$992 billion to the U.S. gross domestic product and more 21 million full- and part-time jobs. The 

transportation delays and inadequate rail service that agriculture is now experiencing may ultimately 

lead to supply chain breakdowns. For example, livestock and poultry operations depend on reliable 

rail shipments for grain for feed. Milling operations rely on consistent deliveries of wheat to make 

flour used in consumer products and commercial bakeries are entering their major operating period 

for the year. Nationwide, the peak of this year's grain harvest will soon be upon us, adding to the 

demand for rail transportation. The convergence of seasonally driven rail transportation demands 

and the CSX service reductions could make U.S. agriculture less competitive in the global 

marketplace or cause prices to rise for consumers. 

Rail service disruptions are costly and can have repercussions on our economy and the food supply. 

The U.S. Department of Agriculture encourages the Board to continue its efforts to resolve the CSX 

service issues and augment those efforts as suggested in the enclosure to this letter. The objective is 

to pinpoint issues and identify speedy resolutions. Additionally, I request the Board to encourage 

CSX to communicate clearly and frequently on the location and timing of service changes, helping 

agricultural shippers better plan production and transport schedules. 

Agriculture needs an efficient and reliable transportation system to feed our Nation and remain 

competitive. I am hopeful that such measures to survey and correct CSX's current issues will lead to 

improved services and lower transport costs for moving our Nation's farm products. 

//m/M~ 

Enclosure 

An Equal Opportunity Employer 
ADDITIONAL INFORMATION AND USDA RECOMMENDATIONS 

Agricultural supply chains are varied and complex. Rail service is a key component of freight 

logistics that many farmers and agricultural processing companies rely on as the predominant or 

only option for shipping some commodities to market. The industry's success requires the 

seamless movement of goods from the field to processing and manufacturing facilities, as well as 

distribution to a wide variety of domestic and international customers. Inadequate transportation 

service imposes additional costs on agricultural producers and shippers who, as a result, have to 

maintain higher inventories and source needed inputs from other areas or other modes. 

Some agricultural shippers have reported significant service issues with CSX rail service, 

affecting a wide swath of States, including Alabama, Georgia, Pennsylvania, Tennessee, and 

several others. The Surface Transportation Board's (STB) existing service data (collected 

through EP 724), as well as CSX's updated performance data, support these claims by shippers. 

System-level train speeds in key corridors appear to be trending downward since May 2017. 

Dwell times are also concerning. In some locations that serve important agricultural lanes, 

terminal dwell times appear to be trending upward. The U.S. Department of Agriculture (USDA) 

is particularly concerned about the impact of this on agricultural commodity shippers in Illinois, 

Indiana, New York, North Carolina, and Ohio where many farmers rely on CSX's rail service for 

the success of their agribusiness. 

While USDA is greatly concerned about the problems illustrated in shipper accounts and in the 

available service data, we are also confident that the private sector is capable of resolving these 

issues, as long as shippers are able to convey their concerns in an environment of transparency. 

USDA believes the Board can greatly aid shippers and railroads in resolving these issues by 

requiring CSX to provide data that is wider in scope, more granular in detail, and fully explained. 

Therefore, USDA is suggesting further ways that STB could improve upon existing service data. 

First, USDA believes more granularity would improve existing performance metrics. Train 

speeds, car orders, and equipment available should be provided by corridor, particularly for lanes 

serving origin points in Midwestern States to the northeast, south Atlantic, and southern States. 

CSX should provide dwell time metrics for many more locations in their network that represent 

important segments of the agriculture industry and each of the metrics should distinguish between 

unit, shuttle, and manifest trains. 

Second, USDA believes more detailed methodological explanations of existing data would be 

useful. For example, the CSX grain cars loaded and billed is uncorrelated with CSX's grain 

car loadings. This is not true for other railroads. CSX' s methodology document does not explain 

why this would be the case. Shippers and other interested stakeholders need a better explanation 

of what the data means for service levels, or alternatively, CSX's methodology needs 

modification so it is similar to the data provided by other railroads in order to provide a useful 

view of delivery status. 
Additional Information and USDA Recommendations 

Page2 

Third, USDA encourages the Board to investigate the CSX grain car orders' data and 

methodology. During the 2013-2014 rail disruptions, the number of outstanding orders was a 

powerful indicator of the magnitude and location of problems, but CSX does not currently 

provide unfilled order data as other railroads do. Some methodological flexibility is necessary in 

an industry where each company is different; however, that flexibility should not prevent 

accomplishing the goal of providing service transparency and clarity. 

Finally, USDA believes the service data should include a longer history of observations. USDA 

appreciates the fact that, when CSX recently updated the methodologies behind some of its 

service metrics, CSX included prior year data in order to benchmark current weekly values. With 

seasonal variations, a benchmark from at least two previous years is necessary to know what any 

particular point or change means in the current year. USDA encourages the Board to request that 

CSX provide historical benchmarks for all of its existing service metrics, as well as any additional 

metrics requested by the Board.