Railway fee consultation 2016-2017 feedback

The feedback received during the railway fee consultation has been posted according to our Submission Guidelines.

Submitted by Feedback

Koppers Ashcroft Inc
Industrial railway

Strongly disagree. There is no benefit to us to have this, it is only a monetary burden. The fees are very high for the business we operate. We are a small facility, serviced by a federally regulated RR.
Stella-Jones Inc
Industrial railway
Strongly disagree. 4 times the CPI. What justification can be possible for such an outrageous increase. New capital expenditures? Inefficient administrative structure at BCSA? What is it?
Koppers Ashcroft Inc
Industrial railway

Strongly disagree. We have a very small rail operation.  The fees are already very high.

This is from the point of view of an Industrial Railway, where Public Safety is not a concern.   While we appreciate the information and knowledge that the Rail Safety Officers provide, perhaps an annual inspection/audit is not really necessary.  Many other regulatory agencies require annual INTERNAL audits, and each 3 or 5 year EXTERNAL audits.   Perhaps training companies in how to internally audit their OWN program would save on fees of the Rail Safety Officers travelling to each location. Again, as much as I appreciate the information of the Rail Safety Officer, the paperwork that was audited, combined with the amount of time spent, could easily have been scanned directly to the Rail Safety Officers desk.   We could even attach a few photos if requested.

BCR Properties Ltd
Common carrier railway
Strongly disagree. Over the past 4 years, BCR's annual fees have nearly tripled, increasing by more than $36,000 (177% increase). It is simply not possible for any operating railway to support the concept of a further 20% increase in regulatory fees over the next 2 years, especially in the context of a Canadian economy with a 2% annual inflation rate.
WestPine MDF, a division of West Fraser Mills
Industrial railway

Strongly disagree. 10% is far too high; it is well beyond the rate of inflation. In the private sector this type of increase would push our business to another vendor. For increases beyond inflation I would expect to get more value out of the BCSA to make the increase more palatable. WestPine MDF has met the standard and passed our first audits with great scores. If some poor operators are costing you more money to monitor make them pay - not me.

This appears to be more of an announcement than a negotiation. As such I'm very skeptical that my comments will have any impact on the final decision; please surprise me.

Industrial railway

Strongly disagree. Canada is back into a recession with two quarters of negative growth. The economies of both BC and Alberta are struggling and your organization is not doing anything to provide additional service to justify a price increase. Many businesses are faced with having to provide additional service at the same or lower prices and you seem to feel that because you are a quasi government organization you can adjust your prices any time you like without any reason. Lower your costs and manage your budget. We cannot afford a price increase.

Canada is in a recession. No one is getting wage increases or price increases. Figure out how to cut your costs like the rest of us.

Lhoist North America
Industrial railway

Strongly disagree. The current fees already are a heavy burden for a small rail shipper like our plant. These increases will push freight away from rail and move it to trucks.

The proposed increases are ridiculous considering the current poor economic environment.

Dunkley Lumber Ltd.
Industrial railway

Strongly disagree. After successive years of substantial increases, well above inflation, we feel it would be prudent to institute no more than inflation level increases for 1-2 years and re-assess your needs. We appreciate that each technology needs to be independently sustainable but with the significant increases in recent years we feel like the new rates should bridge the gap that existed and perhaps further savings in indirect and overhead costs could be found to cover any perceived shortfalls. Additional punitive increases in the next two years would be detrimental to our own efforts to manage our fixed costs going forward. Please consider putting any further rate increases on hold at this time.

Teck Coal
Industrial railway

Strongly disagree. We appreciated the initial guidance in setting up the SMS, associated inspections and reporting. We also value the BCSA's availability as sounding board regarding new rail operating rules. However given our strong internal Safety culture and processes, we consider annual audits as redundant. The existing fees are already exorbitant, in particular compared to the very limited value of BCSA services received and we propose a reduction of the existing fee structure. We object to further increases that have no relation to inflation or value added and suggest the BCSA re-evaluate their role and approach.

We propose an annual self-audit protocol, similar to the approach taken by the Alberta Regulator. The internal self-audit is supplemented by an external one where the external party does not have to be the regulator but can be a consultant/ retired employee.
Thank you for the opportunity to provide input and we hope shippers' comments are taken into consideration.

Mainline Mgmt. Ltd./ Grand Forks Railway
Industrial railway

Strongly disagree. As with many other small railways, we are struggling to remain both operational and viable. We have had a gradual freight and revenue reduction for the past 10 years, including a complete shutdown for over a year. As we have no way to dictate revenue increases, we’ve made some hard decisions and have managed to remain operational by becoming more and more efficient without sacrificing either train crew safety (clean record since start up 1993) or track condition. Margins remain on the plus side but barely. I really appreciate the BCSA personnel that come once a year to be on our railway and the consultation, assistance, and directives they provide but have a very difficult time trying to justify the current cost to us, regardless of proposed increases. Our fees have increased 26% since 2012 and an additional 20% in the next 2 years means just under a 50% increase in 5 years. This is very very difficult for us to accept as we have no recourse to up our revenues to offset these costs. My biggest fear is that the increase will be imposed regardless of comments.

Other comments: from the Sept.28 teleconference questions and comments. BCSA response to increase – “We haven’t had much response overall from industry that would convince BCSA’s Board who decide final fees, to go in another direction ” Comment – Virtually all responses from industry on the site are “Strongly Disagree” and would suggest this should be considered as representative of industry opinion, suggest most of the others are resigned to the increase. BCSA response to “industry reps expressed that they obviously didn’t like the fee increases but appreciate the value BCSA brings to their operations ....” Comment – We also think the BCSA reps provide a really excellent & worthwhile service to us when they come to Grand Forks Railway but if you extrapolate a cost per hour for this annual visit, it is already staggering. We all need to make/have made some hard decisions to remain viable and hope BCSA does too.

Teck Trail Operations
Industrial railway
Disagree. Commodity prices are low and operating costs must be vigorously controlled for BC businesses to remain viable.
Source Energy Services Fort Nelson
Industrial railway

Disagree. It is a very slow time in oil/gas sector to add more costs to the operations just adds to the already high costs from CN and overall makes rail a lesser option in Fort Nelson

I would say 5% should be the max in my opinion

NELSON ELECTRIC TRAMWAY SOCIETY
Heritage railway

Disagree. We are  a very small operation in the overall scheme of things and cannot afford continuing increases.  In order to maintain safety standards we cannot cut corners but costs keep going higher.  If we implemented a similar response of a 10% increase in our revenues such as fares, season passes etc we would only lose passengers which creates a downward spiral.  We would soon become not a viable and self-sustaining entity.  We need to find ways to cut costs but not at the cost of Safety.

Please consider what these increases mean to the bottom line of our operations and try to find ways to cut your costs.

BCR Properties Ltd
Common carrier railway

Remain neutral. Fees are not a concern.

50% increase in 5 years, wow!

Industrial railway Have you considered allowing stakeholders who only operate Sidings and Spurs [...] and Industrial Railways [...] who also continue to operate at a Low risk with minimum incidents the right to self-audit every two years with the BCSA auditing every third year. This is the arrangement we have with other protocols that we are involved with. This should help you reduce your costs and your officers can spend their time at the higher risk sites.
Thanks for the opportunity to respond.

This page contains submissions received by the closing date October 30, 2015 11:59pm PST