1. 1 ACACSO Nov 2009 LCS Rule 15 Enhancements

2. 2 Rule 15 Definition Rule 15 is the transfer of car hire liability due to a road’s inability to accept railcars when offered in interchange. Rule 15 notification is transmitted via EDI message to Railinc that transmits a TRAIN26 message to the receiving carrier. This message is to be reviewed and the Rule 15 offer is accepted or declined by the receiving carrier. A rejected Rule 15 generates a TRAIN29 message to both roads by Railinc indicating the receiving carrier can indeed accept the railcars at interchange. Class I roads have 6 hours to respond to the original TRAIN26 message. All other roads have 12 hours to respond. When a Rule 15 is accepted the car hire is transferred to the receiving road via a TRAIN28 message.

3. 3 Rule 15 problems addressed by LCS enhancement LCS does not currently evaluate or consider Rule 15 Transfer of Liability (TOL) in the allocation of car hire responsibility. Rule 15 TOL records create situations where car hire liability is difficult to calculate. Rule 5 and Rule 15 TOL records may overlap causing car hire to be paid incorrectly. Rule 15 may have no specific ending and car hire remains in a road’s account for excessive periods of time. Rule 15 and LCS process may cause two roads to pay for the same railcar.

4. 4 Rule 15 example EquipUnitInit: CSXT Number: 0000123456 Event L Location Mark ID LCS Post Date Time Type E SPLC-CD From To Date Time Mark 080101 0502 CH82 E Memphis TN CSX BBB 080101 1300 CSX 090315 0015 ARIL E Nashville TN CSX 090315 0120 CSX 090315 0113 ARIL E Danley TN CSX 090315 0715 CSX 090315 0114 DFLC E Danley TN CSX 090315 0715 CSX 090315 0230 ARIL E Smyrna TN CSX 090315 0715 CSX Before LCS enhancements, road BBB remains liable for car hire after an accepted Rule 15 even though CSX has established continuity and has continued to move this railcar.

5. 5 Rule 15 example EquipUnitInit: CSXT Number: 0000123456 Event L Location Mark ID LCS Post Date Time Type E SPLC-CD From To Date Time Mark 090603 2312 CH82 E Chicago IL CSX BBB X 090604 0701 CSX 090604 2030 BHVY E Chicago IL CSX A 090604 2159 CSX 090606 0359 ICHR E Chicago IL CSX CCC R 090606 0544 CCC 090606 0404 ARIL E Chicago IL CCC A 090606 0544 CCC 090606 0405 ARIL E Chicago IL CCC A 090606 0642 CCC Before LCS enhancements, road BBB accepted a Rule 15 offer but railcar eventually was delivered to road CCC. Both roads BBB and CCC may be paying car hire on this railcar since road BBB Rule 15 cycle is open ended.

6. 6 Rule 15 Enhancement Accepted Rule 15 TOL will be considered by LCS as a verified interchange. Accepted Rule 15 TOL will still be communicated via TRAIN28 message. LCS will create a gap interchange record to close a Rule 15 cycle allowing roads to quantify costs. No change to the current Rule 15 messaging process.

7. 7 Rule 15 Enhancement continued Movement records and activity reported by the delivering road considered ‘inactive’ by LCS within first 5 days. After 5 days, movement records and activity reported by the delivering road will be evaluated using normal LCS rules. Test data compiled by Railinc indicated that over 97% of interchanges occurred within 5 days of the accepted Rule 15 offer.

8. 8 Advantages of Rule 15 Enhancement Since Rule 5 (switching) TOL must conform to LCS interchanges, Rule 5 and Rule 15 TOL can no longer overlap. The gap record closes the Rule 15 cycle and allows the Rule 5 to be calculated normally. Rule 15 TOL to one road with eventual delivery to another is resolved via gap interchange to road physically receiving railcar. Lengthy TOL will be ended via gap interchange when any road establishes continuity.

9. 9 Changes occur in LCS Logic Railinc has completed coding and currently testing these enhancements in the LCS logic. Limited to no coding required by roads. No change in the current Rule 15 messaging to and from roads and Railinc.

10. 10 Questions for Jim Pinson LCS TAG and Railinc collaborated to create and test Rule 15 enhancements.