‘Truck Tum Time from GPS

7 of 12

LMCs have been keen on highlighting differences among terminals, item [3] above. But changing a
terminal's performance is expensive, and unlikely to be achieved overnight. Let's shift focus to item [2]:
what's common among terminals, the role of port-wide policies in the high baseline. Variations by time of
day, caused by port policies and practices, are at least as wide as the variations among terminals, The
productivity improvements sought could cost little or nothing, and the data to support this are
unambiguous.

1. Labor Breaks

The principal cause of delay is the labor breaks at terminals, one hour each at noon, 17:00 and 22:00. The
enormous waves in Figure 3 leave no doubt about how this works: turn time doubles for trucks arriving in
the hour before the break, and the backlog of trucks delayed inside and outside the terminal takes two
hours to clear completely. The 17:00-18:00 break coincides with the congestion build-up at the start of the
fee-free shift described under the next heading. Queue length can reach over a mile and takes more than an
hour to dissipate.

Given that the demand for service at 17:00 is several times greater than at 02:00, a solution is to move the
entire night shift forward an hour, trom 18:00-03:00 at present to 17:00-02:00. That would keep the traffic
moving at 17:00 and ease congestion throughout the night shift, when turn times are far greater than
during the day. In addition, breaks at noon and 22:00 should clearly be staggered. Some terminals do admit
and service some trucks during some breaks, yet this continues to be the primary productivity problem at
the ports.

2014-09-14 20:56

http://metris.us/services/turntime/index.bir



Truck Turn Time from GPS http://metris.us/services/turntime/index. bir.

Metropolitan Transportation Information System
i by Digital Geographic Research Corporation

nome | : { resources | apourus |

Trucks queue outside a marine terminal. Photo altered to mask terminal Identity

The Land Side of Port Performance: Truck Turn Time from GPS

i GPSis a powerful data source for measurement of turn time. Careful analysis provides insight into origins
i of delay, and solutions.

2014 08 14, rev 2014 09 05 | Val Noronha, PhD

1 Executive Summary

Trucks: The turn time debate is motivated largely by motor carriers arguing that truck waits at the port
are too long. Yet GPS studies show turn time averages an hour, which fails to make an impression. There's
a problem with this: the average is not the appropriate statistic. The right statistics show that the motor
carriers have a valid point, A trucker must budget at least 3 hours for a port visit to make an on-time
delivery. And that number is 50% higher than it was 4 years ago. More ...

Terminals; Long turn times aren't entirely the fault of marine terminals, and singling out terminals for
some kind of punitive action is premature in the absence of an adequate track record of data. It's possible
to identify tiers of service levels, but not to distinguish terminals individually on a scale of performance.
The record shows that turn time at terminals rises and dips every few months, and it takes yearsto |
obtain the stable data that should drive intelligent customer (BCO) decisions. More... |

Ports: High-resolution GPS data, properly analyzed and presented, can build consensus, and point to
avenues for identifying problems and improving productivity. Turn time inflation is largely due to forces

lof 12 2014-09-14 20:56


Truck Turn Time from GPS http://metris.us/services/turntime/index.htr:

3. Dispatchers require LiveQ to read queue length, duration and progress. Schedules and appointments
are often made too far in advance to permit changes in response to current queue conditions.
However, a single withdrawal from a long queue not only saves $120 in hourly wages, but also drops
the number of $120,000 trucks the LMC requires in its fleet, making a persuasive case for live
adjustment wherever passible.

ms Sate

Tus 2914-05

Figure 6. METRIS Live provides real-time updates of queue length, dwell, speed of progress towards the gate, and

trend. [ruses a common schematic for all terminals, for ready comparison. This example compares twa terminals,

rally no queue, the other | mile long with 60 minute dwells and growing. Gate/MTO identities are
masked.

one with pra

4. MTOs need weekly or monthly reports to supplement their in-terminal turn time data, to monitor and
address any deterioration in service levels.

5. BCOs need quarterly or annual performance reviews, terminal by termi to inform their choice of
services, and to negotiate rates with steamship lines and detention rates with LMCs.

6, LMCs, BCOs and MTOs require daily and periodic reports on episodes to document and verify
detention claims.

7, Port executives and MTOs need to draw a line in the sand, say at 4 hours, They should receive weekly
reports on exceptions, and diagnose incidents im cooperation with LMCs to identify systemic
problems. Animated replays of GPS data can assist.

We have seen collaborative turn time research be successful and achieve consensus. We have learned
important lessons from what went wrong, It takes the right motivation, leadership and stakeholders to
initiate a turn time study. It takes the right analytical methodologies to anchor it, with intelligent
interpretation of the results, identifying patterns, causes, and feasible recommendations. And it takes
leadership, action and continued monitoring to deliver the targeted benefits.

Acknowledgments

These observations are drawn from years of conversations with LMCs and drivers, MTQs and ports, BCOs,
union leaders, legistators, state and federal officials, consultants and academic observers. The text was
modified following an interview with Bill Mongelluzzo of the Journal of Commerce, who emphasized the
influence of mega-vessels in worldwide deterioration in port efficiency — a point that had not previously
been made in the article.

The METRIS data archive, on which this article is based, was possible due to the cooperation and patronage
of leading drayage carriers who have been our partners over the past 7 years: Ability/Tri-Modal, California
Intermodal Associates, Dependable Highway Express, Fox Transportation, G&D Transportation, Golden
State Express, Harbor Division Inc, Port Logistics Group, Price Transfer, Progressive Transportation
Services, Southern Counties Express, TK Transport, TTSI and Yamko Truck Lines.

11 of 12 2014-09-14 20:56



9/22/2014 Federal Maritime Commission Mail - “September 15 Public Forum.”

Federal
Maritime
Commission

“September 15 Public Forum.”

Doug Corbett <doug@chassissystems.com> Wed, Aug 20, 2014 at 11:38 AM
To: secretary@fmc.gov

http://www. youtube.com’ watch? v=SGumMdWe3AIL

Container Chassis shortages can be solved by using high density chassis storage (Chassis Racks).
Chassis Racks provide parking capacity in a extremely small area. Chassis density is equal to stacking
containers nine high.

Chassis Racks can supply enough chassis to handle surges in demand caused by large ships. Can be operated
by Port Labor, and centrally located on port property to lessen pollution from chassis drays.

Chassis Racks could be operated as public parking facility supplied by public agency on public property. We
have customers in Japan who pay per parking day in a "chassis park”.

Chassis density is 725 chassis per acre with much greater selectivity. Used successfully by BNSF for over 25
years.

Please contact doug@chassissystems.com

3 attachments

br) Chassis Racks BNSF #@.pdf
664K

bes) 4,000 Chassis @ BNSF.pdf
509K

=) Rack 500:acre.pdf
a 159K

hitps://mail.google.con/mail/b/53/u/0/?ul= 28ik= f442bic3ea&view=pt&cat=Cabinet%2FLA% 20Port%20F orum_September %202014&search=cat&meg=147412b4... 11


Truck Turn Time from GPS http://metris.us/services/turntime/index. ht:

Median Visit Time

2014 July
2:00
2:00
=
=
Pf
£
3
>
1:00
0:00
06 00 09.00 12:00 15°00 13:00 21:00 00 00 03°00
Arrival Time at Start of Queue Mateit

Figure 3. Enormous peaks in turn time show the impact of longshore breaks that shutdown most terminals entre!
a day. Some terminals do admit some trucks, If not the peaks would be higher:
inefficiency of mght operations, parti

he daily profile also shows the
arly 19:00 and 20:00 compared with 09:00, possibly becatise of the huge
‘TME-related backlog. Mouse-over the hgure tor an idealized but acluevable protile.

2. Traffic Mitigation Fee

The Traftic Mitigation Fee (TMF) in San Pedro ts a striking example of a public policy impacting turn time.
Designed to ease traffic on freeways at rush hour, it is ironically the cause of considerable congestion in the
ports. The longest queues occur at 17:00- 19:00 when trucks line up — as early as 15:30, in designated lanes
with separate queue management at many terminals — to take advantage of the tee-free night shift (Figure
4). This constitutes a significant portion of the 25% exception rate (2h+ visits).

8 of 12 2014-09-14 20:56


Truck Turn Time from GPS http://metris.us/services/turntime/index.har

10 of 12

METRIS Turn Time Performance Index, and Container Volume

go 1.600.000

4 1,500,000
0
TTSG dialog and study period

1,400,000
60 it Hf
Roadability 4 1.300.000
2
Fy so 1,200,000 $
z .4
é
4 1.100.000 s
40 3

Port labor strike 1.000,u00

wo y

Chinese New Year volume dip

si9 000

wy 800,000
POO AZ ZOIG UE QUE AZ GOTT he PAD AZ det ean vols le 2 Moe 2OF E12 201d 08 2OTd Ie

Month

Figure 5. Phe METRES Turn Time Pertormance Indes
unrelated to Container volume, but there are subde relationships. Analysis can relate changes in the index to the events that
may have caused them, but this should be approached with caution

shows current efficiency to be at a 4-year low, Pertormance appears

Conclusion

This is a brief illustration of some non-obvious intricacies of port pertormance, and how appropriately
crafted GPS analysis can not only resolve disputes over facts, but also reveal patterns that point to root
causes and prioritized solutions, without vilitying any industry segment.

Turn time awareness serves the decision needs of a variety of stakeholders,

a . A METRIS offers turn
each requiring a unique presentation of metrics and analysis:

time products from

1. Policy makers — city and port executives, legislators, air quality control
districts: Turn time is a key performance indicator (KPI) for strategic
short- and long-horizon analyses of land side productivity, to assess a
port's performance as a whole. to examine the effects of fees, labor policies, emission controls, vessel
size, automation, construction, and terminal leases, and the longitudinal impacts of changes in those
variables.

Port operations and security managers: As truck queues lengthen, tempers flare, and vulnerability to
an external incident is elevated. Security personnel need a control-tower-like overview of port
operations, with early warning when congestion is starting to develop. This requires real-time queue
measurement such as METRIS LiveQ (Figure 6).

I-time to annual

N

2014-09-14 20:56


Truck Turn Time from GPS http://metris.us/services/turntime/index.hir.

the motive of a driver who intentionally arrives early and lines up behind a closed gate to avoid a
congestion fee, to get a good spot in the queue, to take a chance on a quick entry, to grab a bite, or to kill
time before an appointinent. None of this behavior is unethical, but it does inflate turn time considerably,
and because multiple motives and effects are intermixed there is no way to disaggregate them. The only
reasonable way to deal with this is to declare the limitations and to interpret the numbers accordingly.

Differences Among Terminals

Terminals differ considerably in performance: a factor of 2x or 3x separates
the fastest and slowest each month. On the surface, that’s good reason to
pressure low-end terminals into making the investments required to improve
productivity, by shifting business to better MTOs. history for an

container terminal in

LA/LB

METRIS offers a 5-y

rative turn time

It's not that easy. Asicle from market realities of price/service differentiation,
differences in the size of vessels that call, and other business model variables,
the difficulty is that performance is impossible to predict in a monthly
timeframe. It fluctuates (Figure 2). A terminal can have entire quarters of long turn times, followed by
eycles of improvement and relapse. Every terminal experiences this from time to time. The best MTOs —
one, maybe two, maybe three — are consistent. It is possible to discern a second and third tier, but they
ade positions regularly on the metrics that matter.

Rating MTOs based on data over some years Is reasonable. Over months it Is not.

5 of 12 2014-09-14 20:56


September 12, 2014

Federal Maritime Commission: September 15 Public Forum

Written comments on behalf of Tyson Foods, Inc.
Submitted by: Perry M. Bourne, Director of Int?’ Trans. & Rail Ops.

Backgroun:

Tyson Foods, Inc. is a major producer of protein for the U.S & global meat markets with sales
projected in 2014 of approximately $40 Billion. We produce poultry, beef, pork & various value-
added branded protein items for retail and foodservice markets within the U.S. and 52 countries. We
have 60 poultry plants, 12 beef, 9 pork & 23 prepared foods plants, and just recently acquired alt 17 of
the newly acquired Hillshire Farms facilities. Tyson has operations in 23 states & 11 countries.

Tyson was the second largest U.S export reefer commodity protein shipper in 2013. We shipped
nearly 35,000 TEU’s of reefer and another 5400 of animal hides/skins & leather worldwide. We ship
approx. 60% of this volume thru LA/LB & Oakland, CA.

Service-Congestion issues:

Port congestion especially on the U.S West coast has been a problem for several years. My comments
will address both Los Angeles/Long Beach, CA & Oakland, CA.

The first area | will address concerns issues associated with the “Pier-Pass” fee at Los Angeles/Long
Beach, CA, As checked back through my file on “Pier-Pass” | confirmed that this terminal gate
management scheme was initiated in LA/LB back in July 2005 with the specific goals of reducing traffic
congestion in the Port terminal area and cutting back on truck idling time thereby reducing air
pollutants in the surrounding communities. The funding was to come from BCO’s {beneficial cargo
owners) with a fee set initially at $80/FEU. The program was designed to incentivize moving as much
cargo to the port terminals as possible for delivery at night thereby significantly reducing traffic
congestion and truck emissions due to idling time. The scheme’s success was far greater than
expected and the air quality was reported to have improved more than expected as well. So the
initial goals were accomplished. The “Pier-Pass” funding was to subsidize the costs of adding extra
night and week-end gates that were established to allow cargo to be delivered at non-peak times
(night shift between 6PM & 3AM or whenever the terminals closed).

In addition to this “Pier-Pass” fee, we as BCO’s had to pay extra to our cross-dock (CFS) operators to
hire truckers willing to deliver at nights and on weekends. That incremental cost could be as much as
$30/load. As a result the LA/LB port complex became the most expensive USWC port Tyson uses to
handle perishable meat trans-loads for export to Asia. Our 2014 “Pier Pass” expense is projected to
exceed $320,000 all of which is totally unrecoverable from our customers.

Since its inception, the fee for “Pier-Pass” has increased four times. Initially the fee in 2005 was
$80/FEU; 2006-- $100/FEU; 2011--§120/FEU; 2012--$123/FEU & 2013 went to $133/FEU which
remains the current fee. That’s a 66% increase over 9 yrs. There are several inequities with the way
“Pier-Pass” fees were setup for billing. Not all containers were subject to this fee. There are



the port complex and on California highways, what I like about this endeavor is it did not cost taxpayers
a dime. More terminal capacity was created by operating at night, and that means more container
volume being managed, and more jobs being created without additional capital expenditures —

something currently in short supply.

As valuable and promising as this industry contribution has been, additional issues obviously
exist. In 2006, the port authorities agreed to implement the Clean Air Action Plan (CAAP), later
supplemented with regulations mandated by the California Air Resources Board. These initiatives were
intended to replace older diesel engines in the port complex with newer, lower emission engines. The
results have been notable, but there is a price associated with environmental compliance. That is one
reason why policy makers need to carefully weigh new regulations against encouraging greater
efficiency of operations. In this case, truck drivers were forced to purchase newer trucks if they wanted
to continue working in the LA/LB port complex. Those trucks were also much more expensive. Now
truck drivers reportedly need more trips during a work period to make more money and pay for those

new trucks.

Despite these new regulations, the LA/LB port complex is still doing something right, and moves
14.6 million containers each year. Despite that impressive number, there is a limitation to how much
productivity terminal equipment can achieve and still maintain a safe working environment for dock
workers without improvements in the management of cargo movements. That is a fact and safety must
remain a top priority. The number of times a truck will be available to pick up or drop off a marine
container will not change if we don’t encourage industry to unlock its creative talents to manage future
volumes more efficiently. Productivity cannot be achieved by local, state or federal government
regulation. It can be achieved through encouraging port managers and those who move cargo to find
more efficient means of operating. Each terminal within the port complex is different, and each
terminal and asset operator needs to work with the port authorities and regulatory authorities, like the

FMC, in a cooperative fashion to maximize its capabilities.

Terminal and asset operators generate meaningful jobs, enhance the efficiency of California
ports, and provide a dependable, efficient, robust supply chain that facilitates U.S. exports and imports.
We have much to be proud of, but we must encourage industry to unleash its creative talents to

maintain our competitive edge in the future.


Representative Duncan D. Hunter
Chairman
Subcommittee on Coast Guard and Maritime Transportation

September 15, 2014

Chairman Cordero, | welcome this opportunity to express my views as you explore “U.S. Port
Congestion: Examining Causes, Impact on Stakeholders, and Exploring Possible Solutions.” As you know,
| chair the House Subcommittee on Coast Guard and Maritime Transportation, and much of that
Subcommittee’s work involves maintaining and improving the safety, security and efficiency of the U.S.
maritime transportation system. { appreciate your including my comments as part of the hearing

record.

The movement of goads in commerce is enormously important to California and to the nation.
The Los Angeles and Long Beach port complex {LA/LB port complex) moves more containerized cargo in
and out of the country than any other port in the United States. Importers and exporters depend on an
efficient and seamless supply chain and, by and large, that is what they receive. Even with the
downturns during the global economic collapse, container volumes have increased exponentially over
the last 30 years. With those increases in volume have come enormous increases in productivity within
the LA/LB port complex. In terms of volume the port complex is within the tap ten in the world.
Therefore, by global standards, the industry within the port complex is doing a lot of things right.
However, if the port wants to continue its growth, it must continue to make its port operations more
productive. Today 14.6 million containers are moved in and out of the LA/LB port complex each year.
Projections indicate that future volumes could increase to 20 million by 2025. If projected container
volumes materialize, traditional stacking and sorting processes used at marine terminals to manage

containers will not be adequate to support future growth.

{ama firm believer in unlocking the creative talents of business to become more efficient,
particularly when it will serve a measureable public purpose. As an example, prior to 2005, marine
containers transported by drayage truck drivers in and around San Pedro typically competed with
California motorists during peak rush hour. Now 30 million containers have been diverted to move at
night, approximately 55 percent of the daily truck traffic within the two ports. That is an incredible feat.
The industry should be commended for what it has accomplished. And the Federal Maritime

Commission (FMC) should encourage such collaboration. In addition to minimizing congestion within


Truck Turn Time from GPS http://metris.us/services/tumntime/index.htr

Turn Time Comparison: METRIS Turn Time Performance index (Smoothed)

AY rareranaly

marels

asure

Figure 2, It's not easy fo give MTOS a grade report when then pertormance varies like this. The graph shows one me
of pertormance traced over avo vears, for each terminal. A smoothing function has been applied to each curve to
rtainty due to sampling.

compensate tor unce

Consensus and Policy in San Pedro: Two Problems, Two Solutions

The issues covered above are generic, applicable to any port. Individual ports

. METRIS analysis and
have their own unique patterns of turn time variation, that act as baselines
that facilitate or constrain the performance of thei terminals. We illustrate consulting helps

MTOs, LMCs, BCOs

this with the example of San Pedro.
and ports achieve

Turn time has at least five components:
consensus.

1. Transaction and wait time that might be incurred in a perfect world; plus

Baseline delay attributable to port-wide policies such as fees, labor agreements, chassis policy and
demurrage-free time, as well as port-wide conditions that are difticult for anyone to change, such as
roadability inspections, security checks, union/non-union culture, work ethic and general quality
control; plus

3. Terminal-specitic delay, based on physical mnfrastructure capacity and management; plus

4. Short-term problems (crane failure, construction), lasting minutes or months, that impact the entire

N

a

port or a specific terminal, plus
5. Transaction-specific delay, such as a typo on the container number in a document: usually human

error that may originate with any party in the supply chain.

6 of 12 2014-09-14 20:56


industry work to respond to those conditions as do our supply chain partners. This year we are seeing
varying forms of cotlaboration in Southern California, as well as on the other coasts, being used to find
solutions to additional problems such as chassis supply shortages and truck wait times. Those efforts by
market participants will result in market solutions that by their very nature should bring more efficiency

to the system. We firmly believe that is how improvements will be realized.



Truck Tura Time from GPS http://metris.us/services/turntime/index har

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12 of 12 2014-09-14 20:56



Stephen A. Young
14620 Joanbridge Street
Baldwin Park, CA 91706

Telephone: (626) 962-4047

October 7, 2014

Mr. Mario Cordero, Chairman
Federal Maritime Commission
800 North Capitol Street, N.W
Washington, D.C. 20573

Subject: Port Congestion — Ports of Los Angeles and Long Beach
Dear Mr. Cordero:

We, as a group of companies that collect and process scrap, are having a
very difficult time getting our containers in and out of the dock. The
terminal operators will tell you this is not true but just ask the drivers

waiting in line and the shippers that are shipping containerized cargo.

Normally independent drivers would get 2-3 loads per day, each load
paving from $170 - $250 per truckload depending on the distance from the
port. We are currently down to | or 2 truckloads per day. Drivers’

turnaround Lime is as long as 3 hours at the container terminal.

To try to manage around the congestion, we are paying an extra $133 per
container in Pror Pass fees to deliver during the day. For us this is costing
$100,000 $9 $200,000 per moath and dris ers are still stuck in excessive lines

limiting them to an average of 1.63 loads per day.


acceptable chassis solutions. This change remains a current problem as it has added yet another layer
of complexity, and ongoing delays and congestion, at the port terminals.

Instead of going in to pick up an empty refrigerated container on wheels, Tyson and other refrigerated
shippers must have their truckers provide a chassis or lease one for the move, which in most cases
forces the trucker to make multiple stops within the terminal. These stops are necessitated by
equipment inspection and potential deficiency correction, having an empty container loaded on the
chassis and for chilled loads the trucker must go to a third location within the terminal to get an
electrical gen-set to power the container. In short, what previously was a “one stop shop” has grown
to two or three stops within the same terminal or multiple terminals. These additional steps lengthen
the turn time for the trucker which ends up costing the BCO more in wait time costs at the terminal or
higher base pick-up rates to the drayage company. When making this change, Ocean carriers initially
claimed that this chassis mode! would be more consistent with practices outside the U.S. and that it
would be a more cost effective and efficient way of managing this activity. As yet, few if any BCO’s
have seen anything other than increased costs and increased turn times in the pick-up and delivery
activity at the U.S. ports.

The final issue t will address concerns another service hampered by restricted terminal services. As
most ag-product containers are heavy weight and require a special tri-axle chassis to legally
accommodate the higher load weights, the truckers reuse the same tri-axles when they come in witha
load and require a flip to get another empty reefer container for the return move to the cross-dock
(CFS) operator's warehouse or the BCO’s facility for the next load. This further extends the time
inside the terminal and in some cases the night or week-end terminal operations don’t provide this
flip service forcing more work back to the high volume daytime operations that are already
overburdened.

As | believe this Commission understands, Tyson Foods operates in a very competitive environment.
As a large exporter of chilled and frozen meats our company has to deliver our goods in a consistent
and timely manner or our customers who can easily find other sources of protein from various parts
of the world to replace us if we can’t deliver their orders on-time and efficiently. The last thing any
meat supplier in our industry can afford is to be labeled as an unreliable supplier. We deal in
commodity products that competitors like Brazil & Australia are very capable of supplying if we can’t
get the job done. Service and consistency is the name of the game for us.

For this reason, the congestion issues that have continued to plague the U.S. California ports are very
serious for my company. | know that others in our industry, as well as trade groups like the
Agricultural Transportation Coalition, have expressed their concerns and have made suggestions for
ways to improve efficiency at the ports. On behalf of Tyson Foods, | would like to provide our own
suggested list of action items that we believe will help lessen the port congestion situation which is
negatively impacting current and future global commerce running thru our U.S ports.

Please consider the following:

1- Move the Union “stop work” meetings at the USWC ports to Wednesday — this will help
with week-end volume. Whenever there is a monthly “stop work” meeting, there should
always be a Saturday gate to recover the lost capacity.

2- We need more Saturday gates on the USWC in general. Each terminal could close one
shift on Tuesday for example and open a Saturday morning gate or a Friday night gate.


y

container categories that are exempt from this fee even when the terminal deliveries for this exempt
cargo are made during the peak day timeframe. All empties are exempt from paying the “Pier-Pass”

fee as well as all intermodal containers. This pricing mechanism sets in place a discriminatory pricing
preference favoring the steam ship owners and intermodal shippers utilizing the same gates that the
BCO’s use and have to pay to go thru during the day shift.

Since 2011, the number of night gates have been reduced as Imports declined from the global
recession and volume at the piers were subsequently lowered. At that point, the weekend gate was
eliminated and the night gates were cut from five to four per week. This reduction of off-peak gates
forced more cargo back to day time deliveries and added to the terminal congestion, frustrating one
of the big initial goals of the “Pier-Pass” scheme. At the same time, BCO’s were told they had to pay
more for fewer gates because the terminals couldn’t afford to stay open at the times needed. An
additional factor impacting gate availability is Union meetings that are held on Thursday nights once a
month. This event reduces gate availability for that specific week from four to three night gates and
rarely is a consistent weekend gate made available to accommodate the loss of that night’s gate
capacity.

The second issue | will address concerns issues at the port of Oakland. We have experienced
difficulties resulting from the consolidation of multiple marine terminals into smaller mega terminals
(SSA & Ports America). This was an extremely difficult time period starting over a year ago when
these mega terminals were formed. As we understand it, these changes raised a number of concerns
with the labor unions at Oakland leading to significant problems with turn/time on pick-up & delivery
of containers. The port of Oakland became a very challenging port to export from due to its
inefficiencies and the uncertainty of the labor situation.

For Tyson, which represents a large segment of the U.S. refrigerated protein industry, most all of our
chilled beef & pork ships through Oakland which happens to be the last U.S. port of call for many
Ocean carriers. Over several months we were fighting every week to get containers picked-up and
trans-loads back to the terminals in time to make the vessel cut-offs on Monday & Tuesday. Each
week, we were having problems picking up empty containers prior to the weekend so we could cross
dock 30-plus reefer containers Monday morning from trucks that loaded at our Midwestern plts. the
previous Thursday & Friday. Any disruptions at the port terminals that occurred on the previous
Thursday and Friday before our cargo delivered made it nearly impossible to get all the empty
containers out of the terminals in order to work these loads and get them back for a 4PM cut that
Monday. We were constantly asking for late-gates and in some cases having to air-freight chilled
cargo because our plans failed. Congestion and delays at Oakland weren’t the exception, they
became the rule.

The third issue | will address concerns the Ocean Carriers’ decision to no longer own and supply
chassis within the U.S, thereby forcing terminals to go to grounded operations. Although this has
been a developing issue as each carrier announced they would no longer own chassis, the problems
created remained as truckers and BCO’s worked to develop acceptable alternatives at each and every
port. This action by the ocean carriers in effect became a de facto rate increase for the ocean carriers
as they were able to cut their operating cost of providing shippers a wheeled container to perform
pick-up and delivery of the cargo while not providing BCO’s with a rate reduction to compensate them
for the increased cost of hiring truckers to perform the same service. What was cost effective for the
Ocean carriers became a nightmare for the truckers and shippers who were forced to develop


STATEMENT OF JOHN CROWLEY, EXECUTIVE DIRECTOR
NATIONAL ASSOCIATION OF WATERFRONT EMPLOYERS
To Public Forum in San Pedro, CA on September 15, 2014

Chairman Cordero, | welcome this opportunity to express my views as you explore “U.S. Port
Congestion: Examining Causes, Impact on Stakeholders, and Exploring Possible Solutions." This is a
serious subject which has the attention of the National Association of Waterfront Employers (NAWE)
and our member companies and associations. | ask that this statement be included as part of the
hearing record .

NAWE appreciates that the Federal Maritime Commission, under your leadership, has provided
the opportunity for lawful and thoughtful collaboration by the marine terminal industry in their search
for market-based solutions to the problems we are witnessing in the intermodal supply chain.

The intermodal freight system, and certainly the global supply chain, consists of commercial
entities engaged in a system of intense competition and narrow margins. Squarely in the middle of the
international logistics chain, a marine terminal's stresses are immediately visible to many. Yet marine
terminal operations are affected when less visible and connected modal operations do not function as
they should. When it comes to port congestion, large parts of the system can be adversely affected by
any one part.

American marine terminal operators, in their constant efforts to improve productivity and
remain competitive, work to be responsive to the market demands of each of the intermodal
components. Marine terminal operators seek out the helpful FMC authority to permit coordination as
they have here in Southern California. That coordination has, in turn, been used to great effect, for
example, in reducing emissions at local ports and addressing congestion on community infrastructure
such as those experienced by drayage trucking.

NAWE encourages all industry sectors to collaborate, to the extent practicable and legally
permissible, to achieve greater efficiencies and reduced social impacts to port related operations. All
parts of the supply chain can contribute to an improved system.

We welcome positive and appropriate, but limited, Federal involvement that doesn’t intrude
into terminal operations but can contribute to market-based solutions.

Port-related congestion comes in many forms and in many places, both here in the United
States and around the world. The logistics, technologies, manpower, changing cargo flows and other

factors in play in international commerce make for very dynamic conditions. We in the marine terminal


‘Truck Turn Time from GPS hittp://metris.us/services/turntime/index.hor

Figure 4. Trucks hang back, hesitating te enter a terminal until the Tratfic Mitigation Pee ends at 18:00. MTOs accommodate

this by designating dedicated waiting lanes.

Shortly after the TMF was introduced, an analysis of its mpacts concluded that the fee worked as designed:
it smoothed traffic on the 1-710 freeway. What's required now is scrutiny of its unintended consequences: a
cost-benefit analysis of freeway congestion versus the truck backup outside the night gates under a couple
of different TMF-structure assumptions. The TMF does not have to be an all-or-nothing proposition. A fee
that ramps down over a window of say 3 hours starting at 15:00 would encourage utilization of the
terminals during that low early afternoon period, while staggering some of the queuing for the night gate.

If both these measures were implemented, a quick visual estimate based on Figure 3, basically eliminating
the waves partially or entirely (mouse-over Figure 3 to see the change), suggests that a 20% turn time
reduction is not a farfetched expectation. More important, it would greatly reduce the frequency of
exceptional delays, improving reliability, with a significant impact on the 3-4 hour statistic.

The above are just two examples of observations and recommendations that arise from METRIS turn time
analysis. To be sure, they merely skim the surface of remedies. There are many other plausible proposals for
efticiency improvement, from freeway reconstruction to improved communications and coordination
between LMCs and MTUs, and decongestion of the port area by better management of empties. There are
policy proposals too: a uniform 24*7 TMF, and 247 port operations. Unlike these, the two measures above,
unique to San Pedro, are modest in scope, eminently supportable by analyses, non-controversial,
cost-neutral, and they deliver considerable benefits in a short time-frame.

3. Performance Timeline

A simple analysis, the variation of performance over time, can reveal causes of improvement and
degradation. Figure 5 traces changes in the METRIS Performance Index, which combines “average” and
worst-case metrics on a positive scale, ie. better performance yields a higher index. Sharp and sustained
turns in the curve coincide with policy changes and other events, and reflect the magnitude of impact of
those changes.

The figure suggests that variations in San Pedro have little to do with container volume (there is indeed a
relationship, but that’s an involved discussion). The downward pattern in performance is probably due to
more calls by larger vessels, changes in readability inspections and chassis policy, and slightly increased use
of night gates. The impact of the strike in November-December 2012 is clear The period of remarkable
improvement in summer 2010, coinciding with the TTSG dialog, strongly suggests that turn time is
positively influenced by goodwill between MTOs and LMCs {an alternate explanation is that the summer
freight volume of 2010 justified terminal actions, such as additional gates and some staggering of breaks,
that ceased to be warranted when traffic subsequently dropped). Clearly, all explanations are speculative
unl confirmed by specitic analysis. The graph points out coincidence, not cause-effect.

9 of 12 2014-09-14 20:56


8/22/2014 Federal Maritime Commission Mail - September 15 Public Forum
Federal

Maritime
Commission

September 15 Public Forum

Ernesto Nevarez <portofaztlan@yahoo.com> Tue, Aug 19, 2014 at 2:54 PM
Reply-To: Ernesto Nevarez <portofaztlan@yahoo.com>

To: "Secretary@fmc.gov' <Secretary@fmc.gov>

Cc: port of Aztlan <portofaztlan@yahoogroups.com>, IWW 500 <dept500@lists.iww.org>

| would like to be a registered participant in the above hearing. Also, | would request that you
include that truck drivers are invited on the press release. The context in which you use the
ambiguous jargon "truckers" is aimed at licensed motor carriers and gives the impression that
the concerns and input of the 12,000 port drivers is not solicited. You do make a point to invite
both terminal operators and their workers, the longshoremen. In regards to drayage it appears
that the FMC is only interested in hearing the firms and NOT THE DRIVERS.

Please confirm my reservation and correct the exclusiveness nature of your press release.
http:/Awww.fmc.gov/public_forum_u.s._port_congestion/

Sincerely,

Ernesto Nevarez

httpsvimail. google. com/mail/b/S3/u/0/?ui= 28ik=1442bfo3ea& uew=pi8cat=Cabinet%2FLA%20Port%20F orum_September%2020148search=cat&msg= 1476f8f28... 11


Truck Turn Time from GPS http://metris.us/services/turntime/index.htr

2 of 12

that are common across the port: fabor law, hours of service, chassis policy, etc. Analysis shows that in
the case of Los Angeles-Long Beach, two port-wide policies have enormous negative impacts on
efficiency. And they may be relatively easy to change. More ...

Synthesis—Need to know: Turn time study is not just about addressing the gripes of truckers. It's about
port efficiency: optimal use of a critical national asset. There are several KPIs on the turn time
dashboard, that need the attention of administrators and supply chain stakeholders, some in real-time,
some annually. More ...

I" the ports of Vancouver, Oakland, Los Angeles-Long Beach and New York-New Jersey, turn time disputes

have led to strikes or otherwise attracted considerable attention this past year. They're the latest
developments in an intense and long standing conflict, mostly between truckers (formally, licensed motor
carriers or LMCs) and marine terminal operators (MTOs).

GPS isa valuable new data resource that's being used to establish the facts of turn time: is it as bad as the
truckers claim?

That’s neither the full extent of the problem. nor the full value of GPS data. Turn time is a problem of
national significance, The Tioga Group valuated annual US. losses at $300 million. Port inefficiency delays
economic activity, ties up critical freight assets, creates security vulnerabilities, and has environmental and
community impacts, The parties to the problem are not just LMCs and MTOs, but the entire port freight

industry. With multiple competing interests, and arguments and counter-arguments this way and that, key
issues of logistical efficiency tend to get obfuscated.

When properly analyzed and interpreted, good data cuts through the log. MsTels

clarifies issues and builds consensus. The causes of delay, and remedies, TURN TIME RESOURCES

, r ar Live cong reports rucker: * clear of long
become crystal clear. Live congestion reports help truckers steer clear of long Truck Turn Time from GPS

queues.
Measuring Tum Time:

In this article ['m going to show how that’s done. Techical Hazards

Turn Time Gtossary
In the twin ports of Los Angeles and Long Beach (together known as San Turn Time Report 2011
Pedro}, turn time has worsened considerably over the past 4 years, GPS data
build a compelling case that two straighttorward, cost-neutral policy adjustments — (1) staggering
longshore labor breaks, and (2) ramping down the daytime Traffic Mitigation Fee (TMF) over a few hours
rather than all at once — would reduce turn time by perhaps 20%.

‘To begin, let's look at the GPS answer to the basic question: how bad is turn time?

Brief History of Debate
LMCs have struggled to tind the objective evidence to support their claim that turn time is a problem.

In the past, MTOs’ gate entry and exit timestamps were the only hard evidence available. While LMCs
complained that turn times were in the range of 2-3 hours, MTO data indicated that in-terminal time

2014-09-14 20:56


Truck Turn Time from GPS

4 of 12

Turn Time Distribution

2014 May
1D.
Mode pinans

10%?

Medan a iettle megni pial

a Mean not ad eanngiul

6

Percentage of visits

+

Visits aver dna

‘Oh th th ah an sh 6h

Duration (hrs) aterers

Figure 1. The distribution of turn tine is heavily skewed and tailed. tistics like mean and median are not
signiticant points on the curve, and are of fittle value. Although the average as around one hour, because of the high
prevalence of long delays, the time a trucker must budget for a port trip is 3-4 hours,

The data behind these statistics are drawn from METRIS, a product/service package that we deployed in
Los Angeles under a USDOT Research and Innovative Technology Administration project in 2007, and
later commercialized. METRIS GPS tracking equipment polls location 10 times more frequently than
other commercial instruments. It's backed by sophisticated, purpose-built, error-proof analytical
software that calculates queue and in-terminal ciwell with near-100% certainty. The rigorous integrity
checking of this system is unmatched by the off-the-shelf algorithms used by other consultants who
analyze turn time. For example. METRIS detects the worst instance of operational confusion: a truck that
makes repeated entries and exits before completing or abandoning a transaction. They constitute one

trip, not several: those episodes in particular need to be documented, diagnosed and remedied. METRIS
records for San Pedro go back S years, covering thousands of port transactions each month. No other
data resource approaches it. METRIS also offers LiveQ. a unique feed of queue information in real time.
Unlike one other service at a Canadian port that clocks a truck's time in the queue after it enters the
terminal, METRIS LiveQ measures length, dwell, speed of progress and trending while trucks are still in

line.

(Movie of multi-entry episode]

There are caveats on GPS-derived statistics, that should be clear. Most important, it is impossible to discern

2014-09-14 20:56

http://metris.us/services/turntime/index.hir


9/10/2014 Federal Maritime Commission Mail - September 15 hearing port congestion at LA Ports

Federal
Maritime
Commission

September 15 hearing port congestion at LA Ports

Norman Duncan <nomanduncan1919@gmail.com> Tue, Sep 9, 2014 at 11:35 PM
To: Secretary@fmc.gov

{note the omission of the railroads from the guest list. Truckers would rather see
congestion than divert traffic to rail, their competitor. This is also a balance of
payments revelation as to the amount of imports coming into the country. These
shippers should be invited as well to assist in the faster turnaround of equipment
by expediting unloading and not use the container for storage of cargo.
Demurrage charges should be doubled to correct this practice.Norman Duncan

https://mail goog le.conYmail/b/52/W0/?ui=28ik=F442bfc3ea&view= pt&search=inbor&msg = 1485da198d8e4097 &simi=1485da196d8e4097 41



Port Congestion
October 7, 2014
Page 2

The government has given the terminal operators anti-trust immunity. The
terminal operators try to force every container load to day gate. This is
abuse of truckers and shippers and must stop! Set the terminal rates so
there is no differential between day and night. Make these terminal

operators operate 24/7 and cover lunch at the gate.

Truckers or shippers don’t want to ship export. Our cargo is being held
hostage by the congestion at the ports. The abuse of power must stop!

Help us move our cargo through the ports.

Sincerely,

Trphew A om

Stephen A. Young

C: Jennifer Andberg, Deputy Director
Office of Business | iaison
US. Department of Commerce
1401 Constitution Avenue, N.W.
Washington, D.C. 20230

Doug Drummond, President

Port of Long Beach Harbor Commission
4801 Airport Plaza Dive

Fong Beach, CA 9080!

Ambassador Vilme Martinez, President
Porbot bos \ngeles | farbor Commission
425 South Palos Verdes sireet

pan Pedro. CA 9073;


3- Those terminals that operate on Saturday need to provide full service. As an example in
LA/LB certain Ocean carriers are open but will not flip containers off carrier’s overweight
chassis — therefore, they cannot deliver overweight containers. Overweight loads are
becoming more common than standard weights, but without full service we are limited
and it becomes extremely critical on weekends.

4- Terminal operators do a poor job of advising CFS operators and the draymen when they
plan to cancel a shift. They need to provide effective notice of any shift closing several
days in advance so schedules can be reworked to accommodate the loss of gate capacity.

5- Add a Monday night gate just for the delivery of loaded refrigerated containers. This will
add needed gate delivery capacity for all refrigerated perishable commodities (i.e. meat
proteins, fruits, vegetables and other food grade cargo).

6- Establish designated lines for refrigerated container cargo delivery. There is no good
reason to mix highly perishable time sensitive cargo in with wastepaper or other
recyclables products in the same lines. Reefer cargo all pays much higher freight rates
than the products mentioned, yet we are often delayed behind recyclable cargo
containers that are not time sensitive and have much less of a financial impact if they miss
a vessel.

7- Terminals should have refrigerated containers and gensets in the same area so multiple
stops are not required by a trucker to pick up containers in one part of the terminal and
then drive to another area within the terminal or worse yet go to a different terminal to
get a genset.

In closing, President Obama established a goal in January 2010 that he wanted to see exports from the
U.S. doubled within five years. That doesn’t appear to be achievable at this point in time with only
five months left in the targeted time period. However, the U.S. exports have grown in terms of value
by an estimated 40 percent, which is an impressive achievement. Unfortunately, the issues | have
addressed in my comments are certainly having negative impacts on Tyson and other shipper’s efforts
to drive export numbers even higher. We must have efficient ports from which to ship our exports in
order to satisfy our commodity customers’ need for service of time sensitive cargo like chilled meat
which is highly perishable and time sensitive due to shelf-life concerns.

| have addressed a number of critical issues that impact service through our U.S. ports. With the
increased use of bigger ships at the ports, it is critical for all stakeholders to do all that is possible to
look for new ways to make our U.S. exports more competitive and efficient on a service cost basis if
we expect to grow in this highly competitive world market.

Respectfully submitted,

Perry M. Bourne

Director of tnt!’ Trans. & Rail Ops.
Tyson Foods, Inc.

800 Stevens Port Drive

Dakota Dunes, SD 57049


‘Truck Tum Time from GPS http://mettis.us/services/turntime/index.htr

averaged 30 minutes. LMCs were certain that these numbers were dishonestly manipulated. Inevitably,
accusations flew in both directions.

When it became possible to measure turn time from GPS, LMCs found they had a trump card. Now they had
a data source of their own.

However, a series of GPS-based studies, most recently a program commissioned and closely controlled by
the Harbor Trucking Association in Los Angeles, found turn time averaging an hour: about 20 minutes in
the queue to get in, and 40 minutes inside the terminal, corroborating the MTO data.

All these numbers are rounded for clarity. We're not splitting hairs over 10-20 minutes: the argument is

about 1 hour versus 2 or 3 hours.

Truths About Turn Time

T conducted the first of those GPS-based studies, for the Truck Turn Time Stakeholders Group (TTSG) in the
ports of Los Angeles and Long Beach. TTSG consisted of LMCs, MTOs, BCOs and the two ports, who came
together in 2010 to address deteriorating efficiency. The details of the project, participants and findings are
covered on a separate page. [emphasized in my report, and continue to argue strenuously, that turn time
cannot usefully be summarized in an average. (Of course, both sides excavated the average from the report,
and quarreled over it.)

In statistical terms, turn time doesn’t have a “normal distribution” or bell curve, like averages we're familiar
with, e.g. marks on an algebra test. Turn time ts heavily skewed, with a long tail on the right (Figure 1). So
we can't quote a mean and standard deviation and close the case. We need to examine the data patterns
carefully and find other statistics,

The following results in particular reveal crucial facets of port visits, and indicate why terminals and
truckers are at odds:

1. Many visits are short. The most likely visit duration (the mode) is about 30 minutes.

2. Some visits are exceedingly long: 2 hours, even 8 hours. Visits over 2 hours were 14% of all trips in
2011. They're 20-25% now, 40-50% at some terminals in some months, and 60% port-wide at certain
hours of the day. Let's be clear: MTOs are not exclusively to blame for this.

3.]fa trucker were to schedule his trips around the median, halt of his deliveries would be late. When
planning a 75-mile run, he needs a near-certainty of making his delivery window, which means
budgeting in grace time. Working out a range of standard allowances commonly used in
transportation, it Lurns out that the time a Wucker must budget for a port visit to meet a deadline is
3-4 hours. In 2010 that budget was 2-3 hours, precisely what the truckers’ impression of turn time
was.

The MTOs are right: their numbers are legitimate, the average is an hour.

The LMCs are right toa: there yy a turn time problem.

3 of 12 2014-09-14 20:56