MIPRC files comments on FRA’s proposed new rule, ‘Metrics and Minimum Standards for Intercity Passenger Rail Service’; lauds strong OTP rule

The Midwest Interstate Passenger Rail Commission supports the on-time performance standards in the Federal Railroad Administration’s proposed new rule Metrics and Minimum Standards for Intercity Passenger Rail Service.

In formal comments filed June 1, MIPRC lauded the rule, jointly developed by FRA and Amtrak, agreeing with its main components while offering several suggestions on how particular aspects of the rule can be strengthened.

MIPRC “strongly agrees that having accurate and fair standards for measuring passenger rail service performance – and providing remedies when service is poor – is critical to the health and vitality of intercity passenger rail,” noting that “ridership depends, in large part, on whether service is reliable.”

The Commission said the proposed rule, which sets minimum on-time performance (OTP) as trains averaging at least 80 percent on-time arrival over two consecutive quarters – at intermediate stations as well as start/end points – would promote better compliance with federal law which already gives passenger rail preference over freight transportation in using a rail line, junction or crossing.

“We would particularly like to emphasize that using the ‘Customer On-Time Performance’ metric, wherein the arrival of every passenger on every train by route – including and especially those who de-train along a route – seems to be an accurate and fair way to measure OTP,” the Commission commented. “We also concur that providing metrics to measure the degree of customer lateness on an individual host railroad is very important.”
MIPRC also commended the proposed rule’s plan to let states and Amtrak bring complaints for violating the on-time performance standard to the Surface Transportation Board.

“The ability for them to bring complaints before the Surface Transportation Board and requiring the STB to initiate an investigation and ‘make recommendations to improve the service, quality, and on-time performance of the train and to award damages and prescribe other relief’ is an important component of assuring that complaints can be resolved, and OTP improved,” MIPRC commented.

The Commission agreed with the FRA’s proposed connectivity metric to measure connections between trains, and that train schedules should be re-aligned to distribute “recovery time” – now added at the end of a train schedule – along the train schedule without adding time to the overall schedule.

But MIPRC strongly recommended strengthening the rule’s proposed “community access” metric aimed at measuring transportation needs of communities and populations that are not well-served by other forms of intercity transportation. As proposed by the FRA, this metric would measure community access as the “percent of Amtrak passenger trips to and from not well-served communities, updated on an annual basis.”

“We do not see evidence in this rule of how the proposed ‘community access’ metric will adequately measure the transportation needs of communities and populations that aren’t currently well-served by other forms of intercity transportation,” MIPRC’s comments said.

“The metric also doesn’t make any attempt to parse out issues such as whether the time the train arrives at a rural station is convenient. The proposed service availability metric will measure total number of trains daily that arrive and depart between 5 a.m. and 11 p.m. per 100,000 residents, but only to the top 100 MSAs (metropolitan statistical areas).”

MIPRC also suggested some additions and clarifications, including:

1. Clarifying the definitions of schedule modifications: FRA currently proposes “temporary” as less than three months, and “long- term and permanent modifications” as six months or more. The rule should be expanded to either include another “medium term” modification for a period between three and six months or clarify the “short-term” to include under what conditions a modification between three and six months can be sought.
2. Make explicit that improved OTP should have a significant effect on ridership, making a huge impact on operational costs. Every additional paying rider lowers a train’s operating cost.
3. Adding a question or questions to Amtrak’s customer satisfaction survey about passengers’ satisfaction with the train’s on-time performance. While this element may be inferred in questions about overall satisfaction with the trip, the Commission believes it would be useful to know how Amtrak’s passengers (customers) perceive on-time performance vis-à-vis their own expectations and the published schedule.
4. Adjusting Amtrak’s customer survey for “excessively late” trains to include situations in which a delay is Amtrak’s fault, in addition to adjustments currently made for situations in which a delay is not Amtrak’s fault.

“Providing another score (or a replacement for the adjusted score) that includes those customer satisfaction surveys wherein excessive delays are Amtrak-related would be a more accurate report of customers’ satisfaction with Amtrak,” the Commission commented.

(MIPRC previously offered oral testimony on the proposed new rule during an FRA April 30 telephonic public hearing.)