November 22, 2006
PRESIDENT
Darrell R. Wallace
Vice President, Transportation
Bunge North America, Inc.
P.O. Box 28500
St. Louis, MO 63146-1000
(314) 292-2276
E-mail Darrell.wallace@bunge.com
VICE PRESIDENT & TREASURER
Lynn A Hiser
Director of Transportation, America
Tate & Lyle Ingredients Americas Inc.
2200 E. Eldorado Street
Decatur, IL 62525
(217) 421-2959
E-mail ivnn.hiser@tateandlyle.com
SECRETARY
Peter Cleary
Corporate Rail Fleet Manager
Cargill, Inc.
P.O. Box 9300
Minneapolis, MN 55440
(952) 742-5328
Mr. Kevin Kaufman
Group Vice President
BNSF Railway Company
2650 Lou Menk Drive
P.O. Box 961051
Fort Worth, TX 76161-0051
Re:
Private Car Registration Program
Dear Kevin:
BNSF has placed on its website a notice of its
intent to institute a Private Car Registration Program
early in 2007. North America Freight Car Association
(“NAFCA”) is an association of private car manufacturers,
lessors, and operators, who collectively own or operate
over 500,000 private cars.
As President of NAFCA, I am seeking clarification
of the registration program beyond the outline that is
available on the web. We would appreciate it if you could
include answers to the following questions in any amplification you provide:
1.
Exactly what type of information will be required for each car and
whether that information is now available to BNSF in the UMLER file?
2.
How will the information BNSF proposes to request for each car
be used to provide “more effective management of the private car fleet on
[BNSF’s] network in order to maintain fluidity”?
3.
Will registration be required only when it is known that a private
car is intended to load on BNSF, or will registration be required even if loading
on BNSF is a future possibility?
4.
Will private car suppliers be responsible for keeping the
registration up to date, as when cars go off lease, are destroyed or are sold?
5.
If car “owners” are responsible for registration, but shippers are
the ones who actually load cars, how can BNSF expect to enforce a charge
against the car owner if the shipper loads a non-registered car?
Finally, we hope BNSF recognizes that a private car registration system
has the potential to impose significant new administrative burdens on shippers,
particularly if all railroads were to require individualized registration. We would
appreciate any comments you might have regarding this concern.
Sincerely,
Darrell R. Wallace
Vice President Transportation
Bunge North America, Inc.
and President
North America Freight Car Association
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