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Statement of

Carl W. Bentzel

Commissioner,

Federal Maritime Commission

Surface Transportation Board Hearing

April 26, 2022.

Thank you, Chairman Oberman, Board Members Fuchs, Schultz, Primus and 

Hedlund:

While the primary purpose of the hearing is on potential expansion of the Surface 

Transportation Board’s (STB) authority over emergency service rules, and on the 

notice of proposed rulemaking that would modify existing emergency service 

rules. I will confine my comments more to current challenges in the shipment of 

intermodal cargo, and into what the rail service disruption means to overseas cargo 

shipments. 

I have raised these concerns before with Chairman Oberman and I am sure that the 

STB and my agency the Federal Maritime Commission (FMC) will have much

more to say on supply chain disruption in the future. I am hopeful that we can work 

together on ways to strengthen the system of intermodal delivery.

I’ll get right to the point: 

The FMC estimates that intermodal container shipments increased in this country 

last year by an astounding over 21% growth through our major port gateways. 

Unfortunately, the railroads have not been able to keep pace or take advantage of 

this growth. Case in point, last year railroads saw a reduction of 16.8% of 

intermodal rail service, this is at a time when international container volumes 

surged to a 21% growth. During this time, one major West Coast railroad halted

rail service from the West Coast to Chicago for a week at the height of volume 

surge last summer - and another metered or reduced the scope of services. Still, the 

Union Pacific annual report for last year indicated that intermodal revenues had 

increased 3%. 

This is stunning. Think how much revenue was left on the table? Think how much 

could have been made if they had even broken even, let alone increased market 

share. But even more to the issue, think of how much smoother and more efficient

the supply chain could have run this past year if maritime surges had been matched 

by rail efficiency. 
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While this might seem like a condemnation of the railroad industry, it is in fact a 

plea. 

Our nation desperately needs railroad service at U.S. ports. There simply is not 

enough space or land in our major port areas to continue to rely mostly on trucking 

distribution. Since the start of the pandemic, I have visited major port and freight 

gateways in the United States ----and the message from maritime industry leaders 

is always the same, they need expanded rail services, so cargo can move 

expediently and efficiently. Quite frankly, there needs to be better coordination in 

moving boxes from the ports and onto rail. That means more capacity, more 

equipment, and a willingness to communicate. I do not believe that existing port 

infrastructure will be able to handle our international trade without committed 

railroad investment and participation.

In the longer term, cargo distribution must take place away from our heavily 

congested ports. There is nascent growth of a system of inland ports and 

distribution centers, but much work remains if we are to handle projected volumes 

of growth in the supply chain. U.S. railroads must be engaged not only connect the 

dots of the supply chain but stimulate this growth. Our ports and maritime industry 

cannot be relied upon to warehouse and distribute our nation’s cargo, ports are 

facilitators of freight—not distribution centers.

What also concerns me is that other countries have already figured this out. The 

U.S. has been slow to make meaningful investments in connecting our maritime 

infrastructure with our rail network. For instance, market share for U.S.-bound 

cargo from the West Coast in 2007 was dominated by U.S. ports with a 60.7% 

share while Canadian ports had 39.3% market share. By 2019, for the same market 

U.S. ports were 44.1% share while Canadian ports now were dominant with a

55.9% market share. The Canadian government has enacted legislation to support 

Atlantic and Pacific port gateways, and this has hurt our ports, the workers who 

work on intermodal shipping and U.S. railroads who serve the ports.

In the marketplace this means that the investment in Canadian port infrastructure 

has shifted cargo from U.S. ports to Canadian ports, where the Canadian 

government has invested more federal funds and enacted more favorable policies 

supporting their ports and railroads. 

We need to do a better job investing and connecting our infrastructure assets. The 

railroads need to stop reading stock market prices and focus on revenue growth. 

Intermodal shipping is the growth market in international shipping as more nations 
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come online with containerized shipping investments, and I believe that this trend 

will only accelerate in the future.

In closing, I believe that U.S. intermodal railroad service will be critical in the 

coming decade as we struggle with increased trade, and congested entry points. 

Intermodal rail service provides a way to bypass the congested port areas on the 

coast to facilitate the next leg of the intermodal journey. Recently railroads have 

prioritized cost savings, as opposed to revenue generation to maximize intermodal 

market growth. All efforts should be made to work with and push the railroad 

industry to increase market share of intermodal cargo when it gets to the United 

States. This will facilitate greater integration at U.S. ports, and more 

advantageously position trucking to be more efficient in moving cargo from ports 

and railroad terminals.

Thank you for the opportunity to appear today. I look forward to any questions the 

Board Members might have. 

Carl W. Bentzel is a Commissioner with the U.S. Federal Maritime 

Commission. The thoughts and comments expressed here are their own and 

do not necessarily represent the position of the Commission.