ISRI Comments to Surface Transportation Board Highlight Member Concerns Over First-Mile/Last-Mile Service

Washington, DC – Serving as the Voice of the Recycling Industry™, the Institute of Scrap Recycling Industries (ISRI) today submitted comments to the Surface Transportation Board (STB) in response to its notice regarding First-Mile/Last-Mile (FMLM) service.

In its comments, ISRI details significant issues members have had with FMLM service, including missed switches, reduced service days, mismatches between car orders and car deliveries, and extended dwell times at local facilities. Additionally, ISRI’s comments explain operational challenges experienced by members due to the railroads’ failure to provide switches on committed service days or at scheduled times.

Excerpts from ISRI’s comments follow:

… The FMLM Notice asks the commenters to provide concrete examples in identifying their FMLM issues, and explain, among other things, the frequency, reasons, and impact of the FMLM issues experienced. ISRI conducted a survey among its membership to gain a better understanding of the common issues and trends in connection with FMLM service problems. ISRI believes that the members’ responses provide important context as to the significance of the problems experienced by ISRI members, and perhaps in other industries. …

… Poor FMLM service has significant impacts on ISRI members’ businesses. A number of ISRI members reported that FMLM service issues create significant operational challenges. Generally, the scrap industry plans their production, operations, and infrastructure around railroad service days and railcar orders. When railroads fail to provide the switches on the committed service days or at the scheduled time, or otherwise fail to deliver the number of cars ordered, ISRI members incur significant inefficiencies and costs. …

… Similarly, the railroads’ failure to provide consistent FMLM service causes significant challenges managing labor at scrap processing facilities. When ISRI members cannot predict when a railroad will provide switching in its facility, it is impossible for both the member and its customers to plan an efficient labor shift. Instead of being staffed at optimal production levels, employees waste significant time waiting for the delivery/pickup of the railcars and constantly having to monitor the railcar pipeline. …

… Importantly, it is nearly impossible for ISRI members to address these FMLM service issues with the railroads, in their contracts or otherwise, or find a long-term solution that works for both sides. Many ISRI members are captive to one railroad at their facilities. …

… In general, ISRI believes that the additional metrics the Board adopts as part of its FMLM service reporting requirements should be objective, standardized, and able to display an accurate picture of the FMLM service performance of the railroads. The data should be reported to the Board and the public, at the very least, on a regional level, to ensure that the Board has sufficient regional data to monitor any significant FMLM service performance issues at certain areas of the rail network. …

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The Institute of Scrap Recycling Industries, Inc. (ISRI) is the "Voice of the Recycling Industry™." ISRI represents 1,300 companies in the U.S. and more than 40 countries that process, broker, and consume scrap commodities, including metals, paper, plastics, glass, rubber, electronics, and textiles. With headquarters in Washington, DC, the Institute provides education, advocacy, safety and compliance training, and promotes public awareness of the vital role recycling plays in the U.S. economy, global trade, the environment and sustainable development. Generating nearly $116 billion annually in U.S. economic activity, the scrap recycling industry provides more than 506,000 Americans with good jobs.