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The Transportation of Goods



                 Click HERE for graphic.




                  GOODS MOVEMENT ELEMENT

                           OF THE

              LONG RANGE TRANSPORTATION PLAN

                           FOR THE 

                  GREATER ROCHESTER AREA

                          1995-2015


                     * * * * * * * * * 

Financial assistance for the preparation of this document was 
provided in part by the U.S. Department of Transportation's 
Federal Highway Administration and Federal Transit 
Administration and the New York State Department of 
Transportation.  The Genesee Transportation Council is solely 
responsible for its content.

August, 1995




		      TABLE OF CONTENTS
												
		                                         Page
Introduction		                                  1

Purpose of Plan                                           2

1. Existing Conditions 		                          2

    la. Truck Service in the Rochester Area 	          3
    lb. Rail Service in the Rochester Area 		  5
    lc. Intermodal Service 			          8
    ld. New Technology for Intermodal Shipments	          9
    le. Air Cargo Companies 			         12
    lf. Other Express Transportation Services 	         13
    lg. Water Transportation 				 13

2. Projected Future 				         14

3. Issues and Concerns 			                 14

3a. Goals for the Goods Movement Element 		 16

3b. Objectives for Improving Goods Movement in 
    Rochester Area 	 	 			 17

    Objective I - Goods Movement System Management Plan 	 17
    Objective II - Establish Additional Intermodal 
                   Terminals 				  19
    Objective III - Support Existing Intermodal Terminals 20
    Objective IV - Identify Barriers to Efficient Truck 
                   Use     of  Region's Highways          21
    Objective V - Study Erie Canal Use for Commercial 
                  Traffic		                  21
    Objective VI - Competitive Rail Service in Rochester  22
    Objective VII - Alternate Access to RG&E Russell 
                   Power Plant 	                          23

Conclusion	                                          23

Genesee Transportation Council	Goods         Movement Plan



                       List of Figures
											
		                                        Page
Figure 1 - Division Of Traffic Between Modes 		  3
Figure 2 - A Wegman's Tandem Trailer At I-90 Exit 46 	  4
Figure 3 - Truckloads for Rochester At A Mt. Read Blvd.
           Term. 		                          4
Figure 4 - Conrail Train Passing Through Fairport, With
           Empty Coal Cars Returning To The Mines 	  5
Figure 5 - Railroads Of Western New York 		  7
Figure 6 - Conrail Container Train With Japanese 
           Containers 		                         10
Figure 7 - RoadRailer Mark IV Trailer 	                 11
Figure 8 - Triple Crown Train On Norfolk Southern 
           Railway 			                 11
Figure 9 - Federal Express Cargo Plane Unloading At GRIA 12
Figure 10 - Unloading Canadian Cement At Port Of 
            Rochester 			                 13

Appendices:

   A. Intermodal Facilities Inventory
   B. Performance Measures
   C. Map of Rail Access to RG&E Russell Station
   D. Map of GTC Nine County Planning Region
   E. Goods Movement Locations Referred to in Text


             * * * * * * * * * 


Cover Photo:

LIVONIA, AVON & LAKEVILLE RAILROAD train leaving Avon in 
December, 1987, with tank carloads of corn sweeteners to be 
trans-loaded to trucks at the Lakeville intermodal terminal. 
(Photograph used with permission of the photographer, Pete 
Swanson, of Avon, NY.  Other photographs by the author.)

		* * * * * * * * * * * *

For further information, please call or write H. Douglas 
Midkiff, Transportation Specialist, Genesee Transportation 
Council, 65 West Broad Street, Rochester, NY 14614, telephone 
(716)232-6240.



Genesee Transportation Council            Goods Movement Plan




                  TRANSPORTATION OF GOODS

INTRODUCTION

Why plan for the movement of goods? For that matter, what are 
"goods"? The dictionary says they are merchandise, wares, 
commodities, manufactured items.  So why does the Genesee 
Transportation Council (OTC) have a goods movement plan? The 
simplest answer is that the efficient and economical movement 
of goods and materials to, from, and within the Rochester area 
is vital to the health of the regional economy.  Moreover, 
unless we maintain and improve the freight transportation 
network we have, it could become difficult to maintain the 
standard of living we enjoy.

Most of us take for granted that we will find grapefruit, 
oranges, and melons, at our local supermarket.  We are 
accustomed to finding fresh Atlantic seafood, Italian 
chestnuts, New Zealand kiwis, and other foodstuffs that are 
not native to western New York.

We seldom think about the logistics involved in having North 
Carolina-made furniture at our favorite furniture outlet, or 
Pacific Rim computers and other electronic marvels at the 
Jefferson Road discount stores.  Few of us know, or care, 
about the vital role transportation plays in having 
electricity available when we plug in a hair dryer, or a 
respirator at the hospital, or flick a switch to light a 
Christmas tree.

These are just a few examples of the way the movement of goods 
affects our daily lives.  There are many others.  We hope this 
document will explain how the nation's superb freight 
transportation and distribution network, which includes the 
airlines, railroads, truck lines, and water carriers, makes 
these minor miracles possible.

It is no easy task for a planning organization to establish 
and achieve goals and objectives for a goods movement long 
range plan, requiring, as it does, the closest cooperation 
between the public and private sectors. Accomplishment depends 
upon many factors that are outside the control of the planning 
agency.  It will require a judicious blend of the public and 
private transportation infrastructure to attain the goals and 
objectives contained in this document.

The movement of goods is a venture into a new area of 
transportation for most of the professional planners who will 
read this, hence, the detailed background information we have 
supplied.  Traditionally, Metropolitan Planning Organizations 
(MPOs) have concentrated on planning infrastructure for moving 
people.  Relatively low priority has been given to 
specifically planning the movement of goods, despite the fact 
the



Genesee Transportation Council	       Goods Movement Plan



movement of goods makes a disproportionate demand upon the 
infrastructure1.

Highways, bridges, and roads built to move people also handle 
goods, but the Intermodal Surface Transportation Efficiency 
Act (ISTEA) now specifically requires MPOs to take goods 
movements into account and to plan for the multi-modal 
movement of goods in a manner that will make maximum use of 
existing transportation facilities.  The goals and objectives 
expressed in the Goods Movement Element of the Long Range 
Transportation Plan have been developed with that central idea 
in mind.

The members of the planning community, as well as the members 
of the public, need an understanding of the choices available 
to the freight traffic community and how some choices require 
more investment in the infrastructure than others.  They need 
a good understanding of the logistics of moving goods in order 
to understand the issues and concerns of the freight traffic 
community and to continue the partnership that is necessary if 
the nation and region are to realize to goals of ISTEA.

PURPOSE OF THE PLAN

The purpose of the Goods Movement Element of the GTC Long 
Range Transportation Plan for 1995-2015 is to lay out plans 
for maintaining and improving the freight transportation 
system of the nine-county GTC region (See Map in Appendix D) 
in that 20-year period.  As stated above, the efficient 
movement of goods and materials is vital to the health of the 
regional economy.  As was recognized before the Erie Canal was 
built, most of the products grown and produced in the 
Rochester area have relatively little value until they are 
efficiently and economically transported to the market.  The 
Canal is still available, but the area now depends upon a 
variety of transportation services, all of which are part of 
the national freight transportation network.

1. EXISTING CONDITIONS

The Rochester region has an abundance of goods transportation 
services, however, the type of service and the demands put 
upon it differ substantially from the service requirements of 
earlier times.  The movement to the suburbs and the increase 
in the number of private automobiles after World War II led to 
the building of a vast network of interstate highways and 
state and regional arterial routes, many of them parallel to 
the rail lines.  This, in turn, has led to phenomenal growth 
in the inter-city



 1 According to the Highway Capacity Manual, one 18-wheel truck 
is equivalent to three automobiles on the highways of the 
rolling hill country of the metropolitan area.  In terms of 
pavement wear, an AASHTO study, that trucking interests 
dispute, has concluded that one truck, weighing the authorized 
maximum gross weight of 80,0000 pounds, can do the damage of 
over 5,000 automobiles.


	
Genesee Transportation Council	  2     Goods Movement Plan


trucking industry.  Although the railroads are usually the 
lower cost mode for long haul traffic, the flexibility and 
speed of motor carrier service, over good highways, is 
powerful competition.  As a result, trucks now handle by far 
the largest volume of goods moving to, from, and within the 
Rochester Business Economic Area (BEA), as shown in the graph 
in Figure 1, which depicts the division of traffic between the 
various modes in 1992.

Click HERE for graphic.


la. Truck Service in the Rochester Area

With the passage of the Motor Carrier Act of 1980, the 
trucking industry was partially de-regulated.  Until then, 
entry into the business was severely restricted, with 
applicants having to prove it was in the public interest to 
start a new trucking company.  Since 1980, an estimated 30,000 
new trucking companies have entered the business, resulting in 
a national total of 45,000 companies today.  The Rochester 
metropolitan area has its share of the new carriers, with the 
list of carriers too long for this document.

There are many types of truck lines.  There are common 
carriers that handle freight for all shippers, and contract 
carriers, whose service is usually confined to a few shippers 
under contract.  Many shippers have found it just as practical 
to operate their own truck lines, hence, the growth of the 
private carrier industry, with many companies using small 
trucks, or specially designed trucks, for delivering their 
products or for picking up raw materials or supplies.  
Examples are the trucks of the breweries and beverage 
bottlers, trucks for handling ready-mixed concrete, and for




Genesee Transportation Council	   3    Goods Movement Plan


milk and dairy products.  Cartage companies are trucking 
companies that work with individual shippers, container 
companies, freight forwarders, and distributors.  They

Click HERE for graphic.


Genesee Transportation Council	   3	Goods Movement Plan



pick up empty containers or trailers at intermodal hubs and 
spot them for loading, then pick up the loads and deliver them 
to the hubs.  They sort and distribute less than truckload 
shipments that have been combined into solid truckloads.  Many 
of them provide space at their terminals for parking empty 
trailers and containers.  Rochester has a mix of all types of 
trucking lines. In 1992, trucks handled 71% of the inbound 
traffic to the Rochester BEA and 73% of the outbound traffic, 
totaling 14,582,000 tons, or the equivalent of 634,000 
truckloads of 23 tons each.

lb. Rail Service in the Rochester Area

Truck competition and burdensome economic regulations led to a 
decline in railroad service and, in the case of many 
northeastern railroads, bankruptcy.  However, with the passage 
of the Staggers Act in 1980, which substantially de-regulated 
the industry, the railroads have made a comeback, hauling 40% 
more traffic than they did during WW II, over 44% less track. 
They have introduced new methods of moving rail shipments and 
offer fast and frequent schedules between key cities, over 
rail roadbeds that are in the best condition they have ever 
been.  They have sharply reduced the amount of track they 
operate, abandoning some, but selling even more to short line 
operators who often can make a profit by using non-union 
employees and providing a more personalized service.

Click HERE for graphic.


Figure 4 - Conrail train passing through Fairport, with empty 
coal cars returning from a power plant south of Albany, to the 
mines in West Virginia



Genesee Transportation Council	   5	Goods Movement Plan



The GTC region is served by two major railroads and eight 
short-line rail carriers.  In 1992, they handled 24% of the 
inbound tonnage and 11% of the outbound tonnage.  This 
translates to 23,869 inbound carloads and 8,342 outbound, of 
100 tons each.  While this is less than the truck tonnage, the 
commodities handled by the railroads are of significant 
importance to the area.  For example, a large portion of the 
rail traffic is inbound coal used by RG&E for generating 
electricity.  It cannot be economically handled by any other 
transportation mode.

The major Class 1 railroads2 are Conrail, the giant rail line 
created by special federal legislation when the Penn Central 
and several other northeastern railroads went bankrupt, and 
the Canadian Pacific Railway (CP), which uses the trackage 
rights of its Delaware & Hudson Railroad component over 
Conrail's Southern Tier Line to move through traffic between 
Buffalo and Binghamton.  Conrail is now a privately owned 
railroad in sound financial condition.  The CP Rail System is 
one of two major railroads serving Canada, with thousands of 
miles of track from the Atlantic to the Pacific.  It owns 
several lines extending from border crossings to the interior 
of the United States.

In the GTC region, Conrail is primarily an east-west line that 
uses the famous New York Central Water Level Route between New 
York City and Buffalo. This major trunk line has 40-50 trains 
daily passing through the city, including many intermodal 
trains.  At least ten of them pick up and deliver freight at 
the Goodman Street Yards, but no intermodal traffic is handled 
in Rochester. ( See Map in Appendix E)

The short-line carriers are the Arcade & Attica (ARA), the 
Dansville & Mount Morris (DMM), the Finger Lakes Railroad 
(FLR), Genesee & Wyoming Railroad (GNWR), the Livonia, Avon 
and Lakeville Railroad (LAL), the Ontario Central (ONCT), the 
Ontario Midland (OMID), and the Rochester and Southern 
Railroad (RSR).

The principal business of the ARA is handling agricultural 
products between Arcade and North Java.  The DMM handles heavy 
and oversized shipments of pressure vessels that are not 
practical to ship over the highways, for Foster-Wheeler Energy 
Corporation of Dansville.

The FLR is a new short-line that has bought the so-called 
Geneva Cluster of lines from Conrail, which serve Canandaigua, 
Shortsville, Waterloo, Geneva, Watkins Glen, Penn Yan, Auburn, 
Seneca Falls, and other points on the former Conrail Auburn 
Line.


    2 A Class 1 carrier is defined by the Interstate Commerce 
Commission as one that has annual income of $251 million or 
more.  The revenue threshold for Class 2 carriers is between 
$250 million and $20 million.  Class 3 carriers, which 
includes most short-lines, have annual income of less than $20 
million.


Genesee Transportation Council	   6	Goods Movement Plan



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Genesee Transportation Council	  7	Goods Movement Plan




The GNWR's primary business is the movement of salt from the 
Akzo Nobel mines in Livingston County.  The ONCT provides rail 
service to shippers in the Shortsville Farmington area and in 
Victor.  The OMID serves the fruit and vegetable processors in 
Wayne County and the Xerox plant in Webster.

The Livonia, Avon, and Lakeville Railroad is an important 
short-line railroad in the area.  It operates between 
Lakeville and Avon, where the line connects with the Conrail 
branch line to Henrietta and a connection with Conrail's West 
Shore Line.  The LAL has a large break bulk intermodal 
terminal in Lakeville.  Rail carloads of bulk products, such 
as corn sweeteners, plastic granules, and fertilizer 
chemicals, are   to bulk trucks for delivery to local plants 
and wineries.  Outbound shipments consist of carloads of 
locally produced products, such as locally grown grain, logs 
for paper mill feedstock, and a variety of other agricultural 
commodities that are brought in by truck and trans-loaded to 
rail cars,

The RSR is the only short-line serving the city directly.  It 
has a yard in Rochester from which it serves several 
companies, including Kodak and General Motors plants (See Map 
in Appendix E).  It connects with Conrail in Rochester and 
with the Conrail Southern Tier line at Silver Springs, 50 
miles southwest of the city. It also has a connection at 
Silver Springs with the CP. RSR has haulage rights over the 
Conrail/CP tracks between Silver Springs and Buffalo for a 
connection with its sister railroad, Buffalo & Pittsburgh 
(B&P), making a through route to connections with other 
railroads in Pennsylvania.

lc. Intermodal Service

Intermodal service is defined as the integration of two or 
more modes of transportation.  It includes the transfer of 
goods and cargo in bulk, in packages, or in containers, 
including truck trailers, from one mode to another.  The 
principal intermodal transfers in the region are between 
trucks and the railroads.  Surveys by GTC reveal approximately 
50,000 intermodal trailers and containers are shipped and 
received in the Rochester region each year.  This is less than 
10% of the estimated 634,000 truckloads shipped to, from, and 
within the Rochester BEA.  However, on a national level, the 
volume of rail intermodal traffic is impressive, with over 
8,000,000 intermodal units handled by the railroads in 1994.

Most of the major railroads run trains that handle intermodal 
traffic exclusively between key cities, offering truck 
competitive schedules.  Until 1992, Conrail had an intermodal 
terminal in Rochester and the trains stopped to pick up and 
deliver intermodal shipments and containers.  Despite protests 
from local shippers, Conrail removed the facilities, offering 
the Rochester intermodal users the choice of hauling their 
loads over the highway approximately 90 miles to an enlarged 
intermodal facility



Genesee Transportation Council        8	  Goods Movement Plan



at Conrail's Dewitt Yard at Syracuse, or taking them 60 miles 
to the Norfolk Southern facility in Buffalo.  For some 
shippers, the distance can be even greater.
     
     The trimmed-down railroads have left many plants in 
     the region miles from the nearest railroad

The trimmed-down railroads have left many plants in the region 
miles from the nearest railroad.  While they have the 
transportation option of using commercial or privately-owned 
trucks, they no longer have the option of conventional rail 
service.  Truck-rail intermodal service is an option, but 
because of the distance of many shippers from intermodal 
facilities, the economic advantages of using intermodal 
service are not as great.  In short, many find it difficult to 
use transportation modes that are "economically efficient and 
environmentally sound", an objective of the ISTEA legislation.

ld. New Technology for Intermodal Shipment

New technology for handling intermodal traffic has been 
developed in recent years.  One is the use of containers on 
ocean-going vessels.  Some years ago steamship lines tried 
moving truck trailers, with the wheels removed, on their 
vessels.  This eliminated handling the freight over the docks, 
thereby reducing pilferage and longshoreman labor.

The method caught on Truck trailers were soon replaced with 
specially designed waterproof containers that range in length 
from 45 to 53 feet, which can be equipped with rubber-tired 
wheels at the dock or at the intermodal transfer point.

Fast ships designed to handle containers exclusively now 
operate between ports all around the world.  From the ports, 
import shipments in containers are dispatched directly to 
consignees via over-the-highway cartage or trucking companies, 
or are loaded on rail flatcars, often double-stacked, and 
moved in dedicated rail service to the intermodal hub nearest 
their final destination for distribution over the highways to 
the customers.  The situation is reversed for export 
shipments.

It soon became apparent that containers would-also work for 
domestic shipments.  Many container owners now employ 
third-party brokers and agents to solicit loads for 
containers, at discount prices, that would otherwise move 
empty to the origin ports.  Use of containers for domestic 
shipments is increasing rapidly, with both foreign and 
domestic containers showing up at loading docks throughout the 
country.



	
Genesee Transportation Council	   9     Goods Movement Plan



Another variation on traditional intermodal service that 
employs new technology is provided by RoadRailers, or 
RoadRailer-type, trailers.  These are truck trailers that are 
equipped with rubber tires for operation over the highways, 
but are also equipped, or can be equipped, with steel wheels 
for movement on railroad tracks.  They do not require loading 
on flatcars, but are coupled together for movement in special 
trains.  Tests have shown as many as 120 can be coupled 
together and pulled by one locomotive with a crew of two.

The slackless coupling of RoadRailer trailers all but 
eliminates the stress caused by starting and stopping a long 
train, removing the need for heavy weight construction, so the 
RoadRailers are only slightly heavier than comparable highway 
trailers.  When compared to trailers and containers loaded on 
flat cars, the light weight and lower drag of RoadRailers 
provide exceptional performance.  Tests have shown fuel 
economy approaches 26 trailer miles per gallon as compared to 
8 trailer miles per gallon for an over-the-highway truck.  The 
stability and air suspension provide a very smooth ride, 
meaning the cargo will need less bracing Cans of water have 
remained full on test trips from Detroit to St. Louis.  
RoadRailers can operate at much higher speeds than those of 
conventional rail freight equipment, limited primarily by the 
locomotive power wheel track dynamics, and train scheduling.

Click HERE for graphic.

Figure 6 - Conrail container train, with Japanese containers, 
crossing Main Street in Fairport

The RoadRailer concept has the potential to greatly expand the 
movement of time sensitive goods by rail.  Triple Crown 
Services, a subsidiary of Conrail and Norfolk Southern 
Corporation, operates an extensive RoadRailer operation.  It 
has announced plans to purchase an additional 1,700 Mark V 
RoadRailers to add to the existing fleet of 3,300 nationwide.


Genesee Transportation Council	    10	  Goods Movement Plan



Click HERE for graphic.



in May, 1994, that it will purchase 500 RoadRailers.  Nine 
major truck lines have also announced that they will form a 
cooperative that could acquire up to 5,000 RoadRailers by the 
end of 1995.


Genesee Transportation Council	   11	  Goods Movement Plan



The truckload carriers have stated that they look upon 
themselves as "shippers" as far as railroads are concerned.  
The RoadRailers will give the truckers the option of using the 
new equipment over the highways in the conventional manner, or 
when circumstances permit, using the lower cost rail mode.

Triple Crown opened a RoadRailer terminal in Rochester in 
November, 1994, on the north side of Conrail's Goodman Street 
Yard, and offers service between Rochester and points in the 
midwest and central south.  (See Map in Appendix E)

le. Air Cargo Companies

The Greater Rochester International Airport (GRIA) is the 
major air hub in the region with service by 13 airlines, large 
and small.  Not all of them offer air cargo service, but, 
because of the many high-tech companies in the area, there is 
an abundance of air cargo service.  Airborne Express, 
Burlington Air Express, DHL, Emery Worldwide, and Federal 
Express, operate their cargo-only airplanes in and out of the 
GRIA, where each has an air cargo terminal.  UPS flies in and 
out of Buffalo.  The regular passenger airlines-also provide 
air cargo service and transportation for the U.S. Postal 
Service.

Click HERE for graphic.

Figure 9 - Federal Express cargo plane unloading at Greater 
Rochester     International Airport

The old terminal has been substantially rebuilt and enlarged 
and has excess capacity at the present time.  Studies will be 
made of the access to the privately-owned air

	
Genesee Transportation Council      12    Goods Movement Plan


cargo terminals at GRIA to determine if any improvements to 
the infrastructure are needed.

lf. Other Express Transportation Services

Rochester has ample service from express companies that 
provide expedited service for small packages, generally 
limited to 70 pounds.  Delivery can be overnight or in from 
two to five days, depending upon the needs of the shipper.  
Examples of these canters are United Parcel Service (UPS), 
Roadway Package Systems, AMTRAK, and several of the bus 
companies.  The U. S. Postal Service also offers an express 
package service.

lg. Water Transportation

The Erie Canal is still available for commercial water 
transportation, but is seldom used for that purpose.  The New 
York State Thruway Authority, which now has responsibility for 
operation of the Canal, is seeking to increase its use for 
commercial service.  The only major goods movement by water 
today in the Rochester Transportation Management Area (TMA) is 
via the Port of Rochester at the mouth of the Genesee River.  
Inbound shipments of cement, shipped in bulk by lake boat from 
Picton, Ontario, are trans-loaded to bulk trucks for 
distribution over a wide area of the state.

Click HERE for graphic.

Figure 10 - Unloading Canadian cement at the Port of Rochester

	
Genesee Transportation Conncil	    13	  Goods Movement Plan



Because Rochester is a large exporting city, several steamship 
companies maintain container pools here, but the containers 
move to the ports by truck.  Third-party brokers solicit 
business and regional sales and service representatives are 
located here.  Rochester is also the home of several freight 
forwarders, which are transportation companies that accumulate 
shipments from several shippers in order to get volume 
discounts from the carriers.

2. PROJECTED FUTURE

The purpose of ISTEA is contained in the following policy 
statement: "It is the policy of the United States to develop a 
National Intermodal Transportation System that is economically 
efficient and environmentally sound, provides the foundation 
for the Nation to compete in the global economy, and will move 
people and goods in an energy efficient manner."

The message of the legislation is clear and simple.  It is 
saying that, with the national highway system essentially 
complete, we will no longer need to emphasize the building of 
new highways or the extensive widening of existing ones to 
accommodate the ever increasing volume of roadway traffic.  
ISTEA stresses that the states and local governments must 
manage the transportation infrastructure they already have, 
investing the money where it will best accomplish the region's 
goals for moving goods and people and building new capacity 
only when additional capacity is determined to be the best 
option, after all alternatives have been examined.

3. ISSUES AND CONCERNS

While the Rochester metropolitan area is well-situated for 
goods transportation service, with transportation modes of all 
types tied into the national freight transportation network, 
there are issues related to the provision of competitive rail 
service, convenient access to intermodal facilities, and 
sufficient capacity for the growing volume of goods movement, 
which could get worse by 2015 if not properly addressed.

The number of trucks moving to, from, and within the GTC 
region is expected to increase from 634,000 in 1992, to 
approximately 1 million by 2015.  While a lot of this traffic 
is local, a substantial portion is inter-regional traffic that 
will travel over the federal and state highways.  The 
projected increase in truck traffic will put a 
disproportionate demand upon the transportation infrastructure 
in terms of pavement wear and congestion. Increased use of 
intermodal service would obviously slow the demand upon the 
infrastructure.  Consequently, the objectives of the Goods 
Movement Element have been developed with that central idea in 
mind.

It will require extremely close cooperation between the 
privately-owned railroads, shippers, and the planning 
organizations to increase the use of rail intermodal as an


Genesee Transportation Council	    14	  Goods Movement Plan



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Genesee Transportation Council		Goods Movement Plan



Click HERE for graphic.


Genesee Transportation Council		Goods Movement Plan



Click HERE for graphic.


Genesee Transportation Council		Goods Movement Plan



alternative to over-the-highway service.  As has been 
previously noted, during the 1980s, most of the major rail 
carriers took advantage of the liberal provisions of the 
Staggers Act to down-size their capacity, eliminating what 
they considered to be redundant lines.  Putting their faith in 
new dispatching and operating technology, many railroads, 
including Conrail, felt it was no longer necessary to maintain 
multiple track capacity to get the trains over the line and 
reduced four and three-track lines to two tracks.  Many have 
gone a step further and reduced double track lines to single 
track lines, such as on the Conrail Southern Tier Line between 
Buffalo and the New York-New Jersey area.

However, while they have been down-sizing, the volume of 
traffic has been exceeding predictions, with an increase of 
8.5% for all types of rail traffic during 1994.  Intermodal 
traffic has been increasing at an even faster rate with a 14% 
increase nationwide and a 21% increase on Conrail. This is 
taxing the capacity of the railroads on key truck competitive 
routes and, in some cases, they are beginning to be selective 
in the type of intermodal traffic they will handle.

Conrail business is so good, there is much competition for 
time slots on the New York-Buffalo-Chicago route.  RoadRailer 
service, with 50-75 trailer units, ranks behind the 
150-car/300-container double stack container trains from a 
revenue standpoint.

Thus, service provided by the new Triple Crown RoadRailer 
operation in Rochester is threatened and it is not likely 
Conrail will be receptive to opening additional RoadRailer 
terminals on high density lines.  The need to provide truck 
competitive schedules required the elimination of many 
intermediate stops, which led to the closing of the Conrail 
conventional intermodal terminal in Rochester in 1992, forcing 
local shippers to use the terminal in Syracuse.  In August, 
1994, the railroad announced it would no longer handle 
shipments to destinations less than 500 miles from Syracuse.

Conrail is simply not interested in investing private funds to 
put the region's shippers within economical range of 
intermodal terminals unless there is a clear demand for 
intermodal service that will provide a balanced and profitable 
operation.  Thus, of major concern to GTC is the question of 
how to blend public and privately-owned infrastructure into a 
regional intermodal system that is part of a multi-modal 
national transportation system.

     "an opportunity for . . . carriers and the shippers 
     and receivers in the freight traffic community to 
     become partners in the planning process"

ISTEA and its requirement for public participation provide an 
opportunity for the public and private sectors, as represented 
by the railroads, truck lines, and other


Genesee Transportation Council        15  Goods Movement Plan


carriers, and the shippers and receivers in the freight 
traffic community to become partners in the planning process 
for goods movements and to work together to use the existing 
infrastructure with maximum efficiency.  It is through this 
process that GTC hopes to accomplish its objectives.

3a Goals for the Goods Movement Element

The knowledge of the problems and approaches to solving them 
are due, in a large part, to the assessment and analysis, in 
the fall of 1993, of the goods movements and operations within 
the Rochester TMA, with emphasis on the movement of goods in 
intermodal transportation.  In the course of the program, new 
channels of communication were opened with key players in the 
freight traffic community, providing information that forms 
the basis for the goals and objectives in this report.

Through responses to questionnaires, round table discussions, 
one-on-one meetings with shipper and carrier representatives, 
and various other sources, GTC has learned that there are 
issues and concerns that need addressing if the region is to 
realize the full potential of the ISTEA goals.  In line with 
the policy statement of ISTEA, GTC has established goals and 
objectives that will make the best use of the existing 
transportation infrastructure.

The goals for Goods Movement Element are:

  . to establish a monitoring and reporting system to provide 
    effective oversight of the GTC region's goods 
    transportation system.
 
  . to establish additional intermodal terminals within the 
    GTC region in order to take advantage of new technology in 
    intermodal transportation and to put the region's shippers 
    within economical range of the terminals.
 
  . to provide continuing support to existing intermodal 
    facilities by maintaining access to them and by providing 
    supporting infrastructure when it can be logically 
    justified.
 
  . to determine the patterns of highway usage by the truck 
    lines in the Rochester TMA and develop strategies for 
    correcting barriers to efficient use of the system.
 
  . to work with the New York State Thruway Authority to 
    establish facilities that will encourage increased use of 
    the Erie Canal for commercial transportation.
 
  . to restore competitive rail service in Rochester.


Genesee Transportation Council        16   Goods Movement Plan


Accomplishment of these goals will give more shippers the 
option of using energy efficient and environmentally sound 
modes of transportation, remove barriers to the use of 
intermodal transportation, and offer opportunities for 
reducing transportation costs so that the region's shippers 
can compete more effectively in the global economy.  Use of 
intermodal service can also lead to the slowing of the 
projected increase in truck traffic by the year 2015, which 
will in turn reduce the demand upon and wear of the highway 
infrastructure.

3b. Objectives for Improving Goods Movement in the Rochester 
     Metropolitan   Area

Using information gathered from personal observations and 
experience, plus information obtained from the freight traffic 
community, seven short and long range objectives have been 
established that, if accomplished, will further the goals 
identified above.  The objectives are as follows:

	
Objective I - Establish a Goods Movement System Management 
             Plan

To provide effective management of the region's goods movement 
transportation system, an on-going and dynamic Goods Movement 
System Management Plan is being developed using guidelines 
established in an ISTEA federal rule-making procedure.  It 
will be used in the years ahead to provide an effective means 
of monitoring and improving the Rochester region's intermodal 
and goods movement system.  Features of the plan are as 
follows:

  . Identification of Intermodal and Goods Movement Facilities

    GTC has developed a base line inventory of intermodal 
    facilities and of facilities that support goods 
    transportation, as listed in Appendix A.  In addition to the 
    actual air, truck, rail, and water intermodal hubs, the list 
    includes elements of the freight transportation network that 
    connect the intermodal facilities to the rest of the network 
    and to the shippers and receivers.

  . Identification of Performance Measures

    Using information supplied by the consumers, parameters have 
    been identified for measuring the performance of single mode 
    and intermodal goods transportation for comparison of the 
    services available by the respective modes.  A list of 
    performance measures shippers and carriers may consider are 
    attached as Appendix B.  In addition, GTC will develop basic 
    cost data, such as cost per ton/mile, and transit time 
    between Rochester, Syracuse, Buffalo, and key destinations, 
    for use in making comparisons between the modes and for use 
    in tracking performance over time.


Genesee Transportation Council	    17	    Goods Movement Plan


  . Data Collection and System Monitoring

    In order to properly monitor the system, GTC will establish 
    base line operating characteristics of the intermodal hubs 
    and supporting facilities, developing as much information as 
    possible on the strengths and weaknesses of each, e.g., the 
    distance from point of loading to the intermodal hub, access 
    streets, clearance problems, etc., to see if improvements in 
    the system can, or should be, included in the Transportation 
    Improvement Program (TIP).  GTC has organized a standing 
    Shipper/Carrier Advisory Committee to assist in system 
    monitoring.  This process will be on-going.

  . System and Facility Efficiency Evaluation

    The efficiency of the system and facilities will ultimately 
    be reflected in the reaction of the shippers and, to a 
    lesser degree, the reaction of the intermodal service 
    providers.  If the infrastructure used in goods 
    transportation services, whether publicly or privately 
    owned, creates problems or inefficiency, the problems will 
    first be noticed by the providers and through them, will 
    surface as problems for the shippers and as barriers to 
    intermodal usage.  In addition to periodic checks by GTC and 
    its agreed-upon performance standards, the system will be 
    monitored by GTC through the Shipper/Carrier advisory 
    Committee, as described in the System Monitoring component 
    above.

  . Strategy and Action Identification and Evaluation

    When deficiencies in the system are identified, or 
    improvements are needed, it will be determined if a remedy 
    is possible under the provisions of ISTEA, or other public 
    source.  If so, GTC and the Committee will develop short 
    term and long term strategies for improving the intermodal 
    transportation and goods movement system in an on-going 
    process.

  . Implementation

    GTC, in collaboration with the Shipper/Carrier Advisory 
    Committee, will, when appropriate, recommend inclusion in 
    the area Transportation Improvement Program(TIP) the actions 
    for eliminating the deficiencies or for improving the 
    system.  There may be other strategies that could be 
    developed outside the parameters of ISTEA, or the TIP, such 
    as supporting the private sector in establishing intermodal 
    options and choices by coordinating the efforts of the 
    parties involved.  This would be done on a case by case 
    basis, to remedy needs that became apparent during the base 
    line survey, or as they become apparent through the System 
    Monitoring process.


Genesee Transportation Council 	       18    Goods Movement Plan



Objective II - Establishment of Additional Intermodal Terminals

As previously noted, one area of concern is the projected 
increase in the number of trucks moving over the region's 
highways.  According to Reebie Associates TRANSEARCH Data, 
truckload traffic to, from, and within the Rochester BEA will 
increase at the rate of about 2.7 percent per year, from 
approximately 634,000 truckloads in 1992 to over 1,000,000 by 
2015.  Given the disproportionate impact heavy trucks have on 
the infrastructures3, will the existing highways be able to 
handle the increase without substantial expenditures for 
additional highway capacity and accelerated reconstruction 
cycles?

Despite the increase in rail business, some rail lines have 
excess capacity and are able to offer truck competitive 
intermodal service.  Increased use of rail intermodal service 
would be a step in the direction of reversing the trend of 
ever increasing truck traffic over the highways.  Thus, GTC 
has adopted objectives that, if accomplished, will make it 
easier for shippers, regardless of location, to use intermodal 
transportation and which will allow shippers, now located 
miles from a railroad, the option of using lower cost rail 
transportation.

    IIa. New Intermodal Terminals - The use of RoadRailers 
    for rail intermodal transportation will increase 
    substantially by the year 2015. For this reason, more 
    shippers in the region should have the option of using 
    RoadRailer service.  GTC is working with the and the CP 
    to establish an intermodal terminal in Rochester that 
    would handle RoadRailers and conventional intermodal 
    equipment if surveys reveal there is enough shipper 
    interest to support it.

    GTC has had meetings with CP and RSR to discuss the 
    operating parameters for a new terminal on the RSR, for 
    RoadRailer and conventional trailers or containers.  If 
    an intermodal terminal is built on the RSR in Rochester, 
    the RSR would provide dedicated intermodal service to 
    Silver Springs, for connection with CP intermodal trains 
    operating between the Buffalo/Niagara frontier and points 
    in the Middle Atlantic States and points in the 
    Southeast, as well as the ports of New York and 
    Philadelphia, thereby filling a gap in the available 
    intermodal service in the area.

    Another objective is the location of a second intermodal 
    terminal on the Conrail/CP Southern Tier Line, at Hornell 
    or Gang Mills, provided there is sufficient shipper 
    interest.  A terminal in either location would reduce the 
    highway distance for shippers located in the southern end 
    of the   region.  Surveys will be conducted to determine 
    the level of shipper interest.

 3 Traffic counts that show approximately 5% of the vehicles 
moving over federal-aid highways in the Rochester TMA are 
heavy trucks, meaning over 80% of the weight on the pavement 
of these highways comes from heavy truck traffic. (See 
Footnote 1)



Genesee Transportation Council	   19	   Goods Movement Plan



    IIb. Re-opening the Conrail Intermodal Terminal in 
    Rochester - According to information received from 
    shippers and cartage companies in Rochester, the loss of 
    the Conrail intermodal terminal in Rochester in 1992 has 
    created barriers to intermodal usage by some Rochester 
    area shippers.  Shippers now desiring to use Conrail 
    intermodal services must deliver the shipments to Conrail 
    at Syracuse, or use the Norfolk Southern facility in 
    Buffalo.

    If there is sufficient shipper support and intermodal 
    traffic to justify it, GTC will organize a joint 
    shipper/carrier effort to encourage the re-opening of the 
    Conrail intermodal facility for conventional trailers and 
    containers in the city.

Objective III - Provide Continuing Support for Existing 
                lntermodal Terminals

To encourage the movement of goods in intermodal 
transportation in the region, GTC, through its Intermodal 
Management System Plan, will support access to and from 
existing intermodal terminals.  This includes truck/rail, 
truck/air, and truck or rail/water terminals.  Using the newly 
established channels of communication with the freight traffic 
community, GTC will monitor the efficiency of the links and 
make recommendations for any improvements that are needed.

    IIIa Support the New RoadRailer Terminal in Rochester - 
    Triple Crown Services has opened a new RoadRailer 
    terminal on the north side of Conrail's Goodman Street 
    Yard in Rochester.  GTC is working with Triple Crown 
    management to determine which routes to and from the new 
    Rochester terminal are free of clearance restrictions and 
    which intersections need improvement in the turn radii in 
    order to handle trailers fifty-three feet long GTC will 
    monitor the level of traffic and will recommend 
    improvements in the infrastructure should problems arise 
    with access to the site.

    IIIb. New Parking Area for Intermodal Trailers and 
    Containers - While some shippers and cartage companies 
    have expressed an interest, it will be necessary to 
    conduct a broader survey to determine the need for a, 
    strategically located parking area for truck trailers and 
    containers.  By "strategically located", GTC means a 
    location that is reasonably close to interstate highways 
    and to major intermodal shippers and cartage companies, 
    yet reasonably close to the intermodal hub at the rail 
    yards.  Such a parking area would offer a secure, fenced 
    location for storing empties and loads and, if possible, 
    would have amenities for the users, such as public 
    telephones, restrooms, and office space for the necessary 
    paperwork.

    IIIc. Intermodal Break Bulk Terminal in Lakeville - 
    Another existing area intermodal facility that offers 
    shippers and receivers in the region an opportunity to 
    reduce transportation costs and enjoy just-in-time 
    deliveries is the LAL Railroad break bulk intermodal 
    terminal in Lakeville.  As previously


Genesee Transportation Council	    20	  Goods Movement Plan


    noted, LAL has established facilities for serving several 
    companies that transload bulk shipments between rail cars 
    and trucks for pick up and delivery at plants in the 
    region.

    Reducing the length of trip by truck through 
    trans-loading and confining the truck portion to 
    relatively short distances for pick ups and deliveries, 
    reduces the line-haul unit costs and allows shippers of 
    products in bulk, who do not have rail sidings or who are 
    located miles from the railroad, to take advantage of the 
    inherent economic advantages of rail transportation.  
    Moreover, because inventories of the products are 
    maintained in Lakeville in bulk rail cars, customers in 
    the region are able to reduce their inventories by 
    utilizing "just-intime" deliveries.  Many firms in the 
    region currently are served through the LAL facility.

    LAL has expansion plans on the drawing board.  An 
    important part of its plan is the acquisition of the 
    Conrail secondary line from Henrietta to Avon, where it 
    connects with the LAL.  This line, while in poor 
    condition, would allow LAL to pick up additional 
    customers and would assure them a direct connection with 
    Conrail's West Shore Line.  Negotiations with Conrail are 
    in progress.

    With support from GTC, LAL has secured grants from the 
    Federal Railroad Administration and NYSDOT to upgrade the 
    track.  GTC support is in keeping with the ISTEA goals 
    and the GTC policy of fostering economic development.

Objective IV - Identify Barriers to Efficient Truck Use of 
               Streets and Highways and Develop Strategies for 
               Correction.

Using currently available information on truck usage of the 
region's streets and highways, GTC will determine barriers to 
their most efficient use for goods movement, such as low 
clearances, bridge weight restrictions, restrictive turn 
radii, grade crossing protection, and gross weight and length 
limitations, and in concert with the appropriate agencies and 
the private sector, develop strategies for correction of the 
barriers.

Objective V - Establish a Joint Program with the New York 
              State Thruway Authority to Study Benefits of Using 
              the Erie Canal for Commercial Traffic.

In a joint effort with the New York State Thruway Authority, 
GTC will determine if there are volume movements to or from 
the region that can be economically transported via the Erie 
Canal.  Products that often move by water are fuel oil, 
gasoline, asphalt, cement, grain, and fertilizer chemicals.


Genesee Transportation Council       21    Goods Movement Plan


Objective VI - Re introduction of Competitive Rail Service in 
               Rochester

Another area of concern is the loss of competitive rail 
service in Rochester.  Prior to  1984, Rochester was served by 
two Class 1 railroads, Conrail and the CSX System, formerly 
the B&O.  In 1984, negotiations began between the CSX and the 
Genesee & Wyoming Industries for sale of the Rochester Branch 
of CSX, running from Ashford Junction, near Salamanca, to 
Rochester.  This was accomplished in 1987 and the Rochester & 
Southern (RSR) was created to operate between the two points.

The new short-line started off with a core revenue base of 
coal for Kodak from mines in Pennsylvania and West Virginia 
and chemicals and plastics moving between Kodak's Chemicals 
Division plant in Tennessee and Rochester, but with the track 
in poor condition, trains were restricted to 10 MPH.

Because of the short RSR haul from Ashford Junction to 
Rochester, the per car division of the revenue for RSR was 
marginal, leaving little room to maneuver when Conrail offered 
Kodak lower freight rates.  RSR lost the Kodak coal business 
to Conrail.  In addition, promised state aid to upgrade the 
track was late in coming The combination of these factors led 
to the abandonment of the RSR line between Silver Springs and 
Machias and the railroad no longer provides a direct route to 
the coal fields, although it can and does handle some coal to 
Rochester in connection with its sister railroad, the Buffalo 
& Pittsburgh, and by way of haulage rights over Conrail via a 
route through Buffalo.

Rochester consumers of large volumes of coal, such as RG&E, 
are, for all practical purposes, "captive" customers of 
Conrail.  This is especially true of RG&E.  At present, RSR is 
unable to compete for the RG&E coal business because both RG&E 
plants are located on Conrail tracks and Conrail assesses a 
high switching charge per car for switching the cars from RSR 
tracks for final delivery to RG&E.  Because of the minimal per 
car revenue, RSR cannot pay the switching charge and make a 
profit.

Shippers no longer have easy access to the Interstate Commerce 
Commission to claim rates are too high since the Staggers Act 
became law with its premise that competition would be the 
regulator.  While there is no evidence of Conrail taking 
advantage of its position, there is the potential for this 
becoming an issue in the future.

In line with the ISTEA policy of offering shippers 
opportunities to use transportation modes that are 
"economically efficient" and allow them to better "compete in 
the global economy", as well as to support the GTC policy of 
fostering the economic development of the Rochester area, GTC 
has established a goal of securing competitive rail service 
for Rochester.  It has adopted an objective of coordinating a 
plan that would bring together key players to encourage 
cooperation between the CP, a Class 1 carrier, and the RSR.  
This could provide a single line route to the Middle


Genesee Transportation Council	   22	    Goods Movement Plan



Atlantic and Southeastern states, via Northern Virginia 
Gateways, for conventional and intermodal traffic via RSR and 
CP.  More importantly, it would offer Rochester area coal 
users competitive access to coal mines on the Norfolk Southern 
Railway in Virginia and West Virginia for movement via the 
Buffalo gateway.

Objective VII - Alternate Access to the RG&E Russell Station

A related objective is to work out an alternate means of rail 
access to the Russell Station of RG&E in Greece.  The 
generating plant at present is served exclusively by Conrail 
by way of a secondary track running from a connection with the 
main line in Lincoln Park up the west bank of the Genesee to 
Charlotte, then west over Conrail tracks under Lake Avenue and 
over Greenleaf Road to the storage yards at the plant site.  A 
map of the area can be found in Appendix C.

The city of Rochester has plans for expansion of the 
waterfront in Charlotte, including possible restoration of the 
old NYC Railroad station, but access to the waterfront and 
station is blocked by the Conrail tracks. The city would like 
to see the tracks moved.

The RSR tracks run parallel to the Conrail secondary to 
Charlotte for some distance and are close enough for a 
physical connection in several places, especially north of 
Ridge Road.  However, the RSR tracks end at Stonewood Avenue, 
some three miles short of Russell Station.  There is an 
abandoned B&O right-of-way, now owned by CSX, the successor to 
the B&O, to a rail bridge that crosses the Ontario Parkway.  
The bridge is owned by New York State DOT or Parks & 
Recreation and may need repair.  The balance of the 
right-of-way to the Conrail lead tracks to RG&E is owned by 
the Greenleaf Meadows Apartments.

Building a delivery track over this abandoned ROW could give 
RSR switching access to the plant and provide RG&E with a 
competitive source of coal, but just as important, it could 
provide a means of delivering Conrail coal that would 
eliminate the need for Conrail to maintain its riverside 
trackage, thereby allowing the City to proceed with its plans 
for developing the waterfront.

CONCLUSION

As was stated in the introduction, it will not be easy to 
achieve the goals and objectives in this plan.  It will 
require the closest cooperation between the public and private 
sectors, for accomplishment depends upon many factors beyond 
the control of the public sector.  We are hopeful the new 
channels of communication that are opened with the freight 
traffic community will establish a partnership that will allow 
us to correct existing problems, as well as learn of new 
problems as they surface, and that, by working together, we 
can solve them to the benefit of all.


Genesee Transportation Council	  23   	     Goods Movement Plan



To achieve the goals, GTC staff will take an active role by 
serving as a catalyst to bring the parties together in a forum 
for discussion and for development of strategies for 
implementation.  It is hoped we can create a blend of public 
and private transportation infrastructure for a transportation 
system that will allow the shippers of the region and the 
nation to move their goods in a manner that is economically 
and energy efficient, as well as environmentally sound, and in 
a manner that will provide the foundation for them to compete 
in the global economy.


Genesee Transportation Council	   24	   Goods Movement Plan


                          APPENDICES 


                          APPENDIX A

       Preliminary Inventor of Intermodal Facilities

                      August 16, 1995

Some intermodal facilities, or facilities that support 
intermodal service, in the GTC Region, that should be 
considered for linking to the National Highway System and 
ultimately to the National Transportation system.  The 
specific firms and locations can be provided as needed.

    * Conrail's Goodman Street Yard

    * Conrail's Storage and Delivery tracks to Kodak Park and 
      the Kodak  distribution Center

    * Conrail’s Intermodal Yard in Syracuse and Norfolk 
      Southern's  Terminal in Buflalo

    * Rail and truck facilities in Avon, Batavia, Canandaigua, 
      Lyons,   Newark, Macedon, Palmyra, Shortville, and Victor

    * Asphalt Terminal on Conrail's West Shore Line at Monroe 
      Avenue in   Pittsford

    * Rochester & Southern's Brooks Avenue Yard

    * Rochester & Southern's Storage & Delivery tracks to 
      Kodak Park and  Kodak Distribution Center

    * Rochester & Southern's Storage track at GM plants

    * Numerous inter-city truck terminals

    * Cartage company truck terminals

    * Livonia, Avon, and Lakeville intermodal facilities in 
      Lakeville

    * Ontario Midland's rail facilities in Monroe & Wayne 
      counties, including the facilities serving Xerox and the 
      fruit and vegetable  companies.

    * Ontario Central's rail facilities in Ontario County

    * All airports in the planning region, public and private, 
      that handle passengers and air cargo.

    * Rochester Port at mouth of Genesee River (ESSROC Terminal)

    * Air cargo facilities at the Greater Rochester 
      International Airport

    * Any sand and gravel trans-loading facilities

    * Marines in Rochester, Fairport, Pittsford, Spencerport, 
      Brockport, and others in the region, such as at Palmyra, 
      Geneva, Macedon, etc.

    * Triple Crown Terminal at Conrails Goodman Street Yard.

    * Private air cargo terminals at GRIA, e.g., Airborne, 
      Emery, DHL, and Federal Express.


                           APPENDIX B

Below are some performance measures a typical consumer (shipper)
may consider

    a. Price (total cost dock to dock)
    b. Transit time
    c. Reliability of schedules    
    d. Availability of equipment    
    e. Cubical capacity of equipment
    f. Flexibility in obtaining equipment
    g. Condition of equipment, i.e. cleanliness, no 
       protruding nails etc.
    h. Loss and damage ratio
    i. Ease of obtaining information on service availability 
       and  parameters
    j. Availability of electronic data interchange
    k. Responsiveness of customer service department
    l. Flexibility of pricing i.e. willingness to meet 
       competitive prices and receptiveness to rate negotiations
    m. Security of shipment in transit (Susceptibility to theft,
        vandalism,  etc.)


Below are some performance measures that a cartage company or 
an inter-city truck line may consider

    a. Clearances on the route to and from an intermodal 
       hub, terminal, or  a shipper's dock (13'6. desirable)
    b. Bridge and highway weight restrictions
    c. Turning radii for trailers up to 53' in length
    d. Availability of secure parking for trailers
    e. Amenities for drivers, e.g., restrooms, public 
       telephones, office space for required paperwork
    f. Cooperation of rail intermodal employees in making a 
       reasonably  quick interchange
    g. Condition of pavement on access roads
    h. Snow removal in appropriate areas
    i. Restrictions on tandem trailers
    j. Extra cost of above barriers


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