Tag Archives: transportation

OffPeak 2.0 Begins Next Monday, Nov. 19

Posted on by

In one week, there will be significant changes to the OffPeak program.

When:  Monday, Nov. 19, 2018 subject to the conclusion of applicable Federal Maritime Commission procedures.

The Traffic Mitigation Fee (TMF) rate will be: $31.52 per 20-foot container, and $63.04 for all other sizes of containers.

The TMF will be applicable on all shifts, all days.

Registration: If not already registered in PierPass, register to pay the TMF at www.pierpass-tmf.org.

Payments: Pay the TMF at the same place payments are currently paid, at www.pierpass-tmf.org.

Exempt from the TMF will be:

  • Empty containers
  • Rail intermodal containers
  • Transshipped containers (cargo that arrives at the Port of Los Angeles or Long Beach on one vessel and leaves
    a second vessel without entering U.S. commerce)
  • Domestic cargo
  • Bare chassis

Appointments are required for all import containers.

Appointments are to be made with the terminal using their own terminal appointment system
See http://wcmtoa.org/appointment-systems/.

Common business rules:
As per WCMTOA Marine Terminal Schedule No. 1 and to include (1) two hour appointment windows and (2) the last appointment times of the day will be 3:30 p.m. on the first shift and 1:30 a.m. on the second shift.

FAQs: www.pierpass.org/wp-content/uploads/2018/10/QA-on-New-OffPeak-Program_10-11-18.pdf.

MTO contacts: www.wcmtoa.org/terminals/contacts/.

Revised PierPass OffPeak Start Expected Nov. 19 at Ports of Los Angeles, Long Beach

Posted on by

The members of the West Coast MTO Agreement (WCMTOA) today said the revised OffPeak program for providing extended gate hours at the Ports of Los Angeles and Long Beach—informally known as PierPass 2.0—is expected to start on Nov. 19, subject to the conclusion of applicable Federal Maritime Commission procedures.

In April, PierPass announced it will overhaul the model used by its OffPeak program for truck traffic mitigation at the two adjacent ports, replacing the current congestion-pricing model with an appointment-based system that uses a single flat fee on both daytime and nighttime container moves.

For most port users, the new system won’t require new procedures, but rather an adjustment to current procedures. Most companies moving containers through the ports are already registered with PierPass to claim containers moved during Peak (weekday daytime) hours. Under the revised system, they will claim containers moved at any hour.

Because nine of the 12 terminals at the two adjacent ports already use appointment systems, most trucking firms serving the ports are already using these systems. The remaining three terminals, all operated by SSA Marine, are planning to launch their own appointment systems in advance of the implementation. As part of the program update, the terminals have also agreed on common appointment windows and common last appointment times for each shift. As the revised program moves forward, the terminals will consider further common rules and processes to enhance truck efficiency at the ports.

Cargo owners moving containers into and out of the ports by truck gate and who aren’t already registered with PierPass can do so at https://www.pierpass-tmf.org/.

As previously announced, the current Traffic Mitigation Fee of $72.09 per TEU (twenty-foot equivalent unit) will be replaced by a new flat fee of $31.52 per TEU; the rate for all other size containers will be a flat fee of $63.04. The TMF charged only on Peak cargo moves will be replaced by a fee that is constant across all hours of operation. Other than that change, the same types of cargo will pay the fee.

The changes to the OffPeak program are being made in response to requests from port users, who seek increased flexibility and a reduction in the bunching up of trucks that often occurs before the start of the nighttime OffPeak shifts.

A Q&A about the revised OffPeak program is available at https://www.pierpass.org/wp-content/uploads/2018/10/QA-on-New-OffPeak-Program_10-11-18.pdf. The West Coast MTO Agreement is a discussion agreement filed with the FMC. WCMTOA’s members are the 12 marine terminal operators at the Ports of Los Angeles and Long Beach. For more information and to track continuing developments, please go to https://www.pierpass.org/about/extended-gates-review-process/.

– end –

Revised PierPass OffPeak System Start Expected in Fourth Quarter

Posted on by

LONG BEACH, Calif., June 26, 2018—The members of the West Coast MTO Agreement (WCMTOA) today said the revised OffPeak program for providing extended gate hours—informally known as PierPass 2.0—is expected to start in the fourth quarter of this year.

WCMTOA members—the 12 marine terminal operators at the Ports of Los Angeles and Long Beach—met on June 21 to address reporting requirements for the amendment to Marine Terminal Schedule No. 1, the document on file with the Federal Maritime Commission (FMC) under which WCMTOA operates.

In April, PierPass announced it will overhaul the system used by the OffPeak program for truck traffic mitigation at the two adjacent ports, replacing the current congestion pricing model with an appointment-based system that uses a single TEU-based flat fee on both daytime and nighttime container moves.

On May 24, the FMC voted to issue a Request for Additional Information about the proposed amendment. WCMTOA members are currently working to gather the requested information. Once WCMTOA submits its response, the FMC will have another 45 days to analyze the amendment. The completion of this process revises WCMTOA’s projected program launch date, originally expected in August, to the fourth quarter of 2018.

A Q&A about the revised OffPeak program is available at www.pierpass.org/wp-content/uploads/2018/04/QA-on-New-OffPeak-Program_4-16-18.pdf. The West Coast MTO Agreement is a discussion agreement filed with the FMC. For more information and to track continuing developments, please go to https://www.pierpass.org/about/extended-gates-review-process/.

PierPass Members Add Common Business Rules to Terminal Appointment Systems

Posted on by

LONG BEACH, Calif., April 30, 2018—The members of the West Coast MTO Agreement (WCMTOA)—the 12 marine terminal operators at the Ports of Los Angeles and Long Beach—have agreed to add common business rules for the appointment systems that will become part of the OffPeak program later this year. Subject to regulatory approval, the revised OffPeak program, which is administered by PierPass, is expected to begin in August.

The terminals agreed to add the common business rules—operational procedures that all terminals will follow—in response to requests from trucking companies and other stakeholders.

The new common business rules include an appointment window—the time span between the earliest and latest times a truck can arrive for an appointment, including grace periods—of two hours for all appointments. In addition, all terminals agreed that their last appointment times of the day will be 3:30 p.m. on the first shift and 1:30 a.m. on the second shift. The new business rules will take effect when the new program begins, and are expected to increase efficiencies for users when planning appointments at more than one terminal.

PierPass also clarified that the new system, which some have referred to as “PierPass 2.0,” won’t require appointments for individual import containers being picked up from peel-off piles. Trucking companies and cargo owners will continue to arrange for a single time window to pick up entire blocks of containers going to the same company or destination from a single container terminal.

Earlier this month, PierPass announced it will overhaul the system used by the OffPeak program for truck traffic mitigation at the two adjacent ports, replacing the current congestion pricing model with an appointment-based system that uses a single TEU-based flat fee on both daytime and nighttime container moves. The change has been welcomed by port leadership and by trucking industry associations as a way to improve flexibility and reduce the bunching up of trucks in late afternoons.

PierPass is scheduling a combined meeting of the PierPass Advisory Committee and Extended Gates Subcommittee in October. This will provide an opportunity for stakeholders to provide feedback and suggestions after implementation of the new system.

A Q&A about the revised OffPeak program is available at www.pierpass.org/wp-content/uploads/2018/04/QA-on-New-OffPeak-Program_4-16-18.pdf. The West Coast MTO Agreement is a discussion agreement filed with the FMC. For more information and to track continuing developments, please go to www.pierpass.org.

– end –

PierPass to Adopt Appointment System and Flat Fee for OffPeak Program

Posted on by

LONG BEACH, Calif., April 16, 2018—PierPass will overhaul the model used by its OffPeak program for truck traffic mitigation at the Ports of Los Angeles and Long Beach, replacing the current congestion pricing model with an appointment-based system that uses a single flat fee on both daytime and nighttime container moves.

The members of the West Coast MTO Agreement (WCMTOA)—the 12 marine terminal operators at the two adjacent ports—reached the decision after an 18-month process of consultation with industry stakeholders, and an analysis and survey by industry consultants.

Port users have expressed a desire for changes to increase flexibility and reduce the bunching up of trucks that often occurs before the start of the nighttime OffPeak shifts. Subject to regulatory approval, the revised OffPeak program is expected to begin in August.

“The industry has been demanding ‘PierPass 2.0,’ and we are responding,” said PierPass President John Cushing. “The original OffPeak program was an innovative and highly effective solution to the challenges we faced in 2005. But it was fairly inflexible, whereas an appointment-based model is scalable and can evolve to meet changing industry needs, technology and practices.”

Under the current program, OffPeak charges a Traffic Mitigation Fee (TMF) on weekday daytime cargo moves to incentivize cargo owners to use OffPeak shifts on nights and Saturdays. The revised OffPeak program will replace this two-tier fee structure with a single flat TMF during both shifts, and use appointments to spread traffic across the two shifts.

Applying the TMF to both day and night cargo will allow a reduction of more than 55 percent in the TMF while still providing funding to operate extended gates. The current TMF of $72.09 per TEU (twenty-foot equivalent unit) will be replaced by a new flat fee of $31.52 per TEU; the rate for all other container sizes will be a flat fee of $63.04.

“The Port of Long Beach is pleased with the progress PierPass has made in working with industry stakeholders to improve night gate operations in our terminals,” said Port of Long Beach Executive Director Mario Cordero. “As ships are getting bigger and volumes increase, efficient gate management is critical to our ability to move cargo in a reliable, predictable and expedient manner.”

“I’m pleased and encouraged that PierPass members are taking a significant step forward to improve efficiencies at the San Pedro Bay port complex,” said Port of Los Angeles Executive Director Gene Seroka. “We, as well as the trucking community and all of our stakeholders, look forward to increased cargo velocity and customer responsiveness at Port facilities.”

The process of reviewing OffPeak alternatives has included a series of meetings beginning with an October 2016 workshop where WCMTOA met with more than 70 leaders representing importers, exporters, trucking companies, logistics providers, elected officials, government representatives, port authorities and other supply chain stakeholders. After a series of subsequent stakeholder meetings to delve into potential alternative models, PierPass retained industry consultants to conduct a detailed analysis. The consultants’ findings were presented and discussed at a follow-up industry workshop on March 8, 2018. WCMTOA members then worked through the remaining issues to arrive at the final plan for the revised OffPeak program.

“The California Trucking Association appreciates the proposal put forth by PierPass regarding its re-structuring of the TMF,” said Alex Cherin, Executive Director of the CTA Intermodal Conference. “This is the culmination of many collaborative discussions between the marine terminal operators and trucking communities over the last few years, and we look forward to supporting these efforts.”

“The HTA has worked hard with our marine terminal colleagues to create a more efficient and environmentally sustainable port complex,” said Weston LaBar, CEO of the Harbor Trucking Association. “This new direction for PierPass is another example of cross-industry collaboration and is a giant step in the right direction. It shows that the San Pedro Bay Port Complex will continue to be the preferred gateway for moving America’s cargo.”

A Q&A about the revised OffPeak program is available at www.pierpass.org/wp-content/uploads/2018/04/QA-on-New-OffPeak-Program_4-16-18.pdf. The West Coast MTO Agreement is a discussion agreement filed with the FMC. For more information and to track continuing developments, please go to www.pierpass.org.

###

PierPass Retains Tioga Group to Evaluate Extended Gate Options

Posted on by

LONG BEACH, Calif., Nov. 6, 2017—PierPass has retained the consulting firm The Tioga Group Inc. and its partner World Class Logistics (WCL) Consulting Inc. to evaluate alternative models for providing the traffic mitigation benefits of extended gates at the Ports of Los Angeles and Long Beach, which are offered through the OffPeak program.

Tioga will analyze the traffic, commercial and operational impacts of two potential alternatives to the current model used by OffPeak, which mitigates traffic congestion caused by port truck operations through encouraging the pickup and delivery of containers on weeknights or Saturdays.

Tioga, based in Philadelphia, has extensive experience analyzing operational issues for North American freight transportation, producing reports including the Cargo Handling Cooperative Program’s “Improving Marine Container Terminal Productivity,” the National Cooperative Freight Research Program’s “Truck Drayage Productivity Guide,” and numerous planning studies for individual West Coast ports. WCL has deep experience working with cargo owners, ports, railroads and other goods movement groups.

The two alternatives under consideration are appointments to control traffic flow combined with a flat fee on both daytime and nighttime cargo moves; and port-wide peel-off, in which trucks would operate like taxis in an airport queue, each truck picking up the next container in the stack. Hybrid models may also be considered.

PierPass launched the OffPeak program in 2005 to reduce severe cargo-related congestion on local streets and highways around the Los Angeles and Long Beach ports. Using a congestion pricing model, PierPass charges a Traffic Mitigation Fee (TMF) on weekday daytime cargo moves to incentivize cargo owners to use the OffPeak shifts on nights and Saturdays. The TMF also helps pay for the labor and other costs of operating the OffPeak shifts. PierPass manages the OffPeak Program as the agent of the West Coast MTO Agreement (WCMTOA), comprised of the 12 marine terminal operators (MTOs) at the two adjacent ports. More than 40 million truck trips have been diverted out of weekday daytime traffic in the Los Angeles area since the program began in 2005, dramatically decreasing congestion on the region’s streets and highways.

Hiring Tioga is an important step in the process through which the WCMTOA members are working with other industry stakeholders to review alternative methods to provide the benefits of extended gates. An alternative model must continue to spread truck traffic across the terminals’ daytime and nighttime shifts of operation, while continuing to fund the operation of extended gates.

The process has included a series of meetings that began at a workshop where WCMTOA met with more than 70 leaders representing importers, exporters, trucking companies, logistics providers, elected officials, government representatives, port authorities and other supply chain stakeholders. Subsequent meetings to address the issues surrounding the alternative models were held with the 40 supply chain stakeholders who together comprise the PierPass Advisory Committee (PPAC) and the Extended Gates Subcommittee (EGS).

Participants have highlighted a range of operational and commercial issues for consideration. In early May, participants recommended hiring a consulting firm to conduct a detailed analysis of the two remaining options. An RFP was issued to four consulting firms recommended by the working groups. Members of the PPAC and EGS participated in the scoring process to assist WCMTOA with its final selection of Tioga. Recommendations and a final report are expected during the first quarter of 2018.

PierPass OffPeak Diverts 40 Million Truck Trips from Los Angeles Traffic

Posted on by

LONG BEACH, Calif., July 26, 2017—PierPass Inc. today announced that its OffPeak program has diverted more than 40 million truck trips out of weekday daytime traffic in the Los Angeles area since the program began 12 years ago this week.

The OffPeak program’s reduction in traffic congestion has also removed hundreds of tons of pollution from the region’s air, a major contribution to efforts by the cities of Los Angeles and Long Beach to cut pollution from the San Pedro Bay port complex.

“In southern California, heavy-duty trucks are the single largest source of both the pollutants that cause smog and exposure to toxic diesel particulates,” said Wayne Nastri, Executive Officer of the South Coast Air Quality Management District. “By reducing the amount of time that trucks spend trapped in terminal queues or traffic jams, OffPeak has made a big contribution to addressing our region’s air pollution problem.”

Without the OffPeak program, more than 12,600 additional truck trips would be jammed into local traffic every weekday between 8:00 a.m. and 5:00 p.m., enough trucks to stretch nearly halfway from Los Angeles to Las Vegas if lined up bumper-to-bumper. The OffPeak program creates weeknight and Saturday shifts for trucks delivering containers to and from the ports, offers a congestion pricing incentive to reduce weekday daytime truck trips, and provides funding for the new shifts.

“Efficient goods movement enables a crucial jobs engine for Southern California’s economy to continue thriving,” said Rep. Duncan Hunter (R-Calif.), Chair of the House Subcommittee on Coast Guard and Maritime Transportation. “The PierPass OffPeak program seeks to maximize the efficient use of existing transportation infrastructure and demonstrates the potential for private-sector innovation to tackle public policy problems. I encourage stakeholders to continue working together to strengthen the program to ensure goods can move as efficiently and safely as possible.”

OffPeak was conceived after a surge in cargo volume in the early 2000s led to severe traffic congestion and its associated air pollution in and around the Ports of Los Angeles and Long Beach. Local communities and political leaders demanded that the ports take action to address the problem. OffPeak was created with the support of cargo owners, the ports and political leaders.

“Over the last 12 years, OffPeak had diverted more than 40 million trucks off our roads and freeways during the busiest times of the day,” said David Pettit, Senior Attorney at the Natural Resources Defense Council. “By reducing truck congestion at the marine container terminals and on the Harbor and Long Beach Freeway, the program has helped reduce pollution and increase mobility for the communities in and around the ports.”

# # #

CUT Terminal Closing – Last OffPeak Shift is Thursday 7/13; No TMF From 7/17

Posted on by

California United Terminals Inc. has announced it is closing its terminal at the Port of Los Angeles. Its last OffPeak shift will be Thursday night, June 13.

CUT is currently working its last vessel. It has advised that effective Monday, July 17, it will no longer offer an OffPeak shift, but will keep labor during the day to work the gates and yard through the end of July, when it will cease those operations as well.

Beginning Monday, July 17, CUT will no longer collect a Traffic Mitigation Fee on cargo moving during day shifts. For more information, please contact CUT at 310-521-5000.

A new schedule of OffPeak gates beginning July 17 is available at https://www.pierpass.org/wp-content/uploads/2017/07/RollingSchedule-170717_2.pdf and has been posted below.

PierPass Will Retain Consultant to Evaluate Extended Gate Options

Posted on by

LONG BEACH, Calif., May 12, 2017—PierPass will retain a transportation consulting firm to evaluate the operational, business and traffic impacts of two alternative models for providing extended hours for truck gates at the marine terminals in the Ports of Los Angeles and Long Beach.

The PierPass Advisory Committee (PPAC) and the Extended Gates Subcommittee met last week to review industry feedback received on two alternative models to the current OffPeak program and to identify key issues for the consultant to investigate.

The May 4 meeting continued a process that began at the Extended Gates Workshop held on Oct. 20, 2016, when the 13 marine terminals that comprise the West Coast MTO Agreement (WCMTOA) met with more than 70 leaders representing importers, exporters, trucking companies, logistics providers, government representatives, port authorities and other stakeholders.

Since then, the PPAC has held a series of meetings to review proposed models and make a recommendation to WCMTOA, which is responsible for deciding on any changes to the OffPeak program.

The three alternatives initially proposed were variable and dynamic pricing, under which the Traffic Mitigation Fee would be higher in times of high gate activity and lower in times of low gate activity; a lower flat fee applying to both day and night moves, with appointment systems to help regulate traffic flow; and port-wide peel-off, in which trucks would operate like taxis in an airport queue. Variable and dynamic pricing was subsequently eliminated from consideration. For more information on these models, see https://goo.gl/Vxi89y.

Since the Oct. 20 meeting, the following steps occurred:

  • On Nov. 3, detailed notes from the Oct. 20 meeting, including pros and cons of each model, were distributed to PPAC members and additional feedback was requested. Those notes became the original basis for the recommendations report being developed by the PPAC.
  • The PPAC met on Dec. 8 to begin developing the recommendations report. Participants reviewed industry feedback received and offered additional points of view. At this meeting, the variable and dynamic pricing model was removed from consideration as it had received no industry support.
  • On Feb. 1, an initial version of the recommendations report drafted by PierPass staff was distributed to PPAC for review and feedback.
  • The PPAC met on Feb. 22 to review the initial draft and collect feedback. At that meeting, participants discussed the need to bring in a third-party consultant to analyze the ideas under consideration, due to the complexity and possible side effects of these changes.
  • On March 15, a revised draft of the report was sent to the Extended Gates Subcommittee for review and feedback. This draft included the recommendation to hire an industry consultant.
  • Committee members submitted input by April 14.
  • On May 4, PPAC and the Extended Gates Subcommittee met to review the recommendations, develop the scope of work to be included in a Request for Proposal (RFP) for consulting firms, and take recommendations for specific consulting firms.

Participants in the May 4 meeting agreed that the consultant should define and maintain a strict schedule of meetings and reports. The group will endeavor to have the RFP released within the next two months. The RFP may request deliverables such as:

  • Evaluation of the ability of a port-wide appointment system to maintain a roughly even split between day and night traffic.
  • Recommendations on how dual transactions (dropping off one container and picking up another during a single truck visit) could be facilitated under each alternative system.
  • Recommendations for handling regulatory, compliance and other challenges to implementing a port-wide peel-off system.

The PierPass Advisory Committee includes more than 25 leaders representing cargo owners, trucking companies, brokers, terminal operators and other stakeholders. The Extended Gates Subcommittee includes 15 additional industry stakeholders who volunteered at or after the Oct. 20 meeting.

PierPass launched the OffPeak program in 2005 to reduce severe cargo-related congestion on local streets and highways around the Los Angeles and Long Beach ports. Using a congestion pricing model, PierPass charges a Traffic Mitigation Fee (TMF) on weekday daytime cargo moves to incentivize cargo owners to use the OffPeak shifts on nights and Saturdays. The TMF also helps pay for the labor and other costs of operating the OffPeak shifts.

###

KPMG Analysis Validates PierPass Calculation of OffPeak Extended Gate Costs

Posted on by

LONG BEACH, Calif., March 13, 2017—An analysis by KPMG LLP validates the methodology PierPass Inc. uses to calculate the cost of operating the OffPeak extended gates program at the Ports of Los Angeles and Long Beach.

Annual PierPass financial reviews have found that the OffPeak (night and weekend) truck gates cost significantly more to operate than terminals recover through the Traffic Mitigation Fee (TMF) charged on weekday daytime container moves. Based on its analysis of the data and methodology used by PierPass’s auditors and maritime industry analysts, KPMG found that PierPass’s position is well supported.

The analysis by KPMG, an audit, tax and advisory services firm, was conducted on behalf of PierPass, working with the chief financial officers of both the Port of Los Angeles and the Port of Long Beach. The report, “Analysis of PierPass’ OffPeak program cost calculation,” is available at https://www.pierpass.org/about-2.

“As PierPass works with industry stakeholders to evaluate alternative ways of providing the extended gates offering, this timely analysis gives us confidence that we understand the true cost of operating a second shift at the ports,” said PierPass President John Cushing. “We are pleased that KPMG has validated our cost methodology.”

KPMG’s analysis found that the 2015 costs reported by PierPass are consistent with the underlying data and methodology used in program calculations. This observation of consistency applied to each of the four major cost categories (ILWU and non-ILWU labor, equipment and administrative costs). The analysis included testing of the methodology and assumptions used to calculate gate and yard costs, the offsetting cost reductions during Peak (weekday daytime) shifts and the number of containers subject to the TMF.

KPMG found no major issues with the data used, and found that the methodology used is a reasonable approach to calculating the cost.

KPMG also conducted sensitivity analyses using two alternate methods of gauging the costs of the program. Using a revised assumption about current terminal efficiency compared with efficiency in 2005 before the OffPeak program began, KPMG found an estimated cost of $108 per TEU (twenty-foot equivalent unit), approximately 17% higher than the $92 per TEU cost calculated by PierPass and 56% higher than the actual Traffic Mitigation Fee of $69.17 per TEU collected during 2015.

KPMG also used a second alternative method involving an estimate of fixed versus variable man-hours used in OffPeak shifts. By this methodology, KPMG arrives at an estimated actual cost of $93 per TEU, about the same as the $92 per TEU calculated by PierPass.

KPMG noted that the actual TMF in 2015 of $69.17 charged per TEU was about 25% less than the $92 per TEU calculated costs of the program. In other words, the TMF is covering only about 75% of the cost of the extended gates, confirming that the terminals are operating the OffPeak program at a loss. In order for the TMF charged to exceed the actual cost of operating the OffPeak program, the cost calculations would have to be overestimated by more than 33%.

KPMG confirmed that the majority of the 2015 OffPeak program cost before accounting for estimated Peak (day) shift cost reduction is comprised of ILWU labor costs. It found 77% of OffPeak program costs were for ILWU labor, 11% for non-ILWU labor, 9% for equipment costs and 3% for PierPass administrative costs.

KPMG also examined the data used to calculate costs for ILWU labor. KPMG found the PierPass data consistent with the hourly data collected and maintained by the Pacific Maritime Association (PMA), which manages the ILWU payroll.

Since the start of the OffPeak program in 2005, Traffic Mitigation Fees collected have been divided among terminals according to the relative volume of all loaded containers at each terminal (including Peak, OffPeak and intermodal). The revenue individual terminals receive hasn’t been directly based on that terminal’s costs, which could subsidize inefficiency, and would also disclose confidential financial data to competitors. Individual terminals, which are private companies and/or units of larger public companies, don’t share their internal financial data with competing terminals or with their landlords, the ports.

The terminals share their internal cost data, on a confidential basis, with the maritime industry analysis firm that calculates the cost of the OffPeak program. That firm (currently SC Analytics) also obtains ILWU payroll data from the PMA. SC Analytics then aggregates the cost data across terminals and uses it to calculate the overall cost of providing extended gates.

KPMG was given confidential access to both SC Analytics data on individual terminal costs and PMA data in order to conduct its analysis.

KPMG also made several recommendations that could improve the accuracy of these cost calculations:

  • The process for determining how labor costs are allocated to or excluded from OffPeak costs could be made more reliable, for example by adding OffPeak-specific job codes for terminals to use;
  • The estimation of equipment costs could be modified to include an exclusion for variable equipment costs related to the OffPeak program; and
  • The process for estimating the amount terminals save on Peak (weekday daytime) shifts by shifting cargo to OffPeak shifts could be revamped, as it relies on comparisons to terminal operations before the OffPeak program began in 2005.

“We welcome suggestions from KPMG on improving the cost methodology calculation process and will strive to implement them where feasible in our 2017 cost analysis,” Cushing said. “Alternative methods of cost measurement may also be relevant for any possible new programs resulting from the current evaluation of extended gate alternatives.”