KPMG Analysis Validates PierPass Calculation of OffPeak Extended Gate Costs

LONG BEACH, Calif., March 13, 2017—An analysis by KPMG LLP validates the methodology PierPass Inc. uses to calculate the cost of operating the OffPeak extended gates program at the Ports of Los Angeles and Long Beach.

Annual PierPass financial reviews have found that the OffPeak (night and weekend) truck gates cost significantly more to operate than terminals recover through the Traffic Mitigation Fee (TMF) charged on weekday daytime container moves. Based on its analysis of the data and methodology used by PierPass’s auditors and maritime industry analysts, KPMG found that PierPass’s position is well supported.

The analysis by KPMG, an audit, tax and advisory services firm, was conducted on behalf of PierPass, working with the chief financial officers of both the Port of Los Angeles and the Port of Long Beach. The report, “Analysis of PierPass’ OffPeak program cost calculation,” is available at https://www.pierpass.org/about-2.

“As PierPass works with industry stakeholders to evaluate alternative ways of providing the extended gates offering, this timely analysis gives us confidence that we understand the true cost of operating a second shift at the ports,” said PierPass President John Cushing. “We are pleased that KPMG has validated our cost methodology.”

KPMG’s analysis found that the 2015 costs reported by PierPass are consistent with the underlying data and methodology used in program calculations. This observation of consistency applied to each of the four major cost categories (ILWU and non-ILWU labor, equipment and administrative costs). The analysis included testing of the methodology and assumptions used to calculate gate and yard costs, the offsetting cost reductions during Peak (weekday daytime) shifts and the number of containers subject to the TMF.

KPMG found no major issues with the data used, and found that the methodology used is a reasonable approach to calculating the cost.

KPMG also conducted sensitivity analyses using two alternate methods of gauging the costs of the program. Using a revised assumption about current terminal efficiency compared with efficiency in 2005 before the OffPeak program began, KPMG found an estimated cost of $108 per TEU (twenty-foot equivalent unit), approximately 17% higher than the $92 per TEU cost calculated by PierPass and 56% higher than the actual Traffic Mitigation Fee of $69.17 per TEU collected during 2015.

KPMG also used a second alternative method involving an estimate of fixed versus variable man-hours used in OffPeak shifts. By this methodology, KPMG arrives at an estimated actual cost of $93 per TEU, about the same as the $92 per TEU calculated by PierPass.

KPMG noted that the actual TMF in 2015 of $69.17 charged per TEU was about 25% less than the $92 per TEU calculated costs of the program. In other words, the TMF is covering only about 75% of the cost of the extended gates, confirming that the terminals are operating the OffPeak program at a loss. In order for the TMF charged to exceed the actual cost of operating the OffPeak program, the cost calculations would have to be overestimated by more than 33%.

KPMG confirmed that the majority of the 2015 OffPeak program cost before accounting for estimated Peak (day) shift cost reduction is comprised of ILWU labor costs. It found 77% of OffPeak program costs were for ILWU labor, 11% for non-ILWU labor, 9% for equipment costs and 3% for PierPass administrative costs.

KPMG also examined the data used to calculate costs for ILWU labor. KPMG found the PierPass data consistent with the hourly data collected and maintained by the Pacific Maritime Association (PMA), which manages the ILWU payroll.

Since the start of the OffPeak program in 2005, Traffic Mitigation Fees collected have been divided among terminals according to the relative volume of all loaded containers at each terminal (including Peak, OffPeak and intermodal). The revenue individual terminals receive hasn’t been directly based on that terminal’s costs, which could subsidize inefficiency, and would also disclose confidential financial data to competitors. Individual terminals, which are private companies and/or units of larger public companies, don’t share their internal financial data with competing terminals or with their landlords, the ports.

The terminals share their internal cost data, on a confidential basis, with the maritime industry analysis firm that calculates the cost of the OffPeak program. That firm (currently SC Analytics) also obtains ILWU payroll data from the PMA. SC Analytics then aggregates the cost data across terminals and uses it to calculate the overall cost of providing extended gates.

KPMG was given confidential access to both SC Analytics data on individual terminal costs and PMA data in order to conduct its analysis.

KPMG also made several recommendations that could improve the accuracy of these cost calculations:

  • The process for determining how labor costs are allocated to or excluded from OffPeak costs could be made more reliable, for example by adding OffPeak-specific job codes for terminals to use;
  • The estimation of equipment costs could be modified to include an exclusion for variable equipment costs related to the OffPeak program; and
  • The process for estimating the amount terminals save on Peak (weekday daytime) shifts by shifting cargo to OffPeak shifts could be revamped, as it relies on comparisons to terminal operations before the OffPeak program began in 2005.

“We welcome suggestions from KPMG on improving the cost methodology calculation process and will strive to implement them where feasible in our 2017 cost analysis,” Cushing said. “Alternative methods of cost measurement may also be relevant for any possible new programs resulting from the current evaluation of extended gate alternatives.”

PierPass January 2017 Newsletter

The year ended at the Ports of Los Angeles and Long Beach with terminal yards free of congestion, and with cargo moving efficiently in and out of the terminals and on nearby freeways, during both shifts.

Average in-terminal turn time in December 2016*:
42.9 minutes day shift
46.2 minutes night shift
*11 of 13 terminals reporting

For comparison, the average in-terminal turn time in November was 45.2 minutes for the day shift and 47.2 minutes for the night shift.

In-terminal turn time is the average amount of time a truck is inside a terminal to complete a transaction. Truck activity information is derived from RFID data, and excludes lunch hour, breaks and trouble tickets. Turn time at individual terminals will vary depending on time of day and other factors. For more information about turn times and how we measure them, please see our Q&A at http://goo.gl/PiOjBp.

Average daily moves per truck in December:
5 or more moves per day: 7%
4 moves per day: 13%
3 moves per day: 29%
2 moves per day: 33%
1 move per day: 18%

Gate moves during Peak and OffPeak shifts in December:
Total Peak gate moves: 403,107 (58%)
Total OffPeak gate moves: 289,659 (42%)

A gate move occurs when a container enters or leaves a marine terminal via the truck gates. Peak shifts are Monday through Friday, 8:00 a.m. to 5:00 p.m. OffPeak shifts are weeknights from 6:00 p.m. to 3:00 a.m. and on Saturdays from 8:00 a.m. to 5:00 p.m.

Note:
All terminals were closed on Sunday, Dec. 25, for the Christmas holiday, and some terminals were closed for one or both shifts on Monday, Dec. 26.

PierPass Advisory Committee Continues Review of Extended Gate Options

LONG BEACH, Calif., Dec. 12, 2016 – The PierPass Advisory Committee met on Dec. 8 to review potential alternatives to the current extended gates model used at the Ports of Los Angeles and Long Beach under the OffPeak Program.

The meeting continued a process that began at an Oct. 20 workshop, where the 13 container terminals that comprise the West Coast MTO Agreement (WCMTOA) met with more than 70 leaders representing importers, exporters, trucking companies, logistics providers, government representatives and other stakeholders.

Under this process, the terminals are working with industry stakeholders to review extended gate alternatives proposed by various interested parties. The proposals offer different approaches to spreading out truck traffic more evenly across the daytime and nighttime hours of operation at the terminals, while continuing to operate and fund extended gate hours.

The alternatives reviewed include variable pricing, under which the Traffic Mitigation Fee would be higher in times of high gate activity and lower in times of low gate activity; a lower flat fee applying both to day and night moves, with appointment systems to help regulate traffic flow; and port-wide peel-off, in which trucks would operate like taxis in an airport queue and each pick up the next available container, compared with the current system under which a specific container must be located, dug out of the container stack and moved onto a specific truck.

At the Dec. 8 meeting, the PierPass Advisory Committee reviewed the feedback received at the Oct. 20 meeting, and members offered their points of view on the benefits and challenges of the three alternative models. During the Dec. 8 meeting, the first option – variable and dynamic pricing – received no support from Committee members, echoing the cool reception it received at the Oct. 20 workshop. This option has been removed from consideration.

During the remainder of the Dec. 8 meeting, attendees offered detailed feedback on the “flat fee tied to an appointment” and “port-wide peel-off” options.

An initial draft report will now be prepared by PierPass staff, which the Advisory Committee will review and meet to discuss in February. The subsequent revision of the report will go to the Extended Gates Subcommittee for review and feedback in March. PierPass is scheduled to distribute the final draft of the Extended Gates Report and Recommendations in mid-April, and a follow-up to the Extended Gates Workshop has been scheduled for early May.

The OffPeak program is managed by PierPass Inc., a not-for-profit company formed by WCMTOA to coordinate multi-terminal programs addressing congestion, air quality and security. The PierPass Advisory Committee, established in 2005, includes a broad range of cargo owners, trucking companies, terminal operators and other stakeholders.

PierPass launched the OffPeak program in 2005 to reduce severe cargo-related congestion on local streets and highways around the Los Angeles and Long Beach ports. Using a congestion pricing model, PierPass charges a Traffic Mitigation Fee (TMF) on weekday daytime cargo moves to incentivize cargo owners to use the OffPeak shifts. The TMF also helps pay for the labor and other costs of operating the OffPeak shifts.

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PierPass November 2016 Newsletter

West Coast Terminals Evaluate Extended Gate Options

Terminal operators at the Ports of Los Angeles and Long Beach held an Oct. 20 workshop with industry stakeholders to evaluate potential alternatives to the current extended gates model used at the ports under the OffPeak Program.

The 13 container terminals that comprise the West Coast MTO Agreement (WCMTOA) met in San Pedro with more than 70 leaders representing importers, exporters, trucking companies, logistics providers, government representatives and other stakeholders.

A copy of the presentation used at the workshop is available at https://goo.gl/6FUWKD.

More Terminals Adding Appointment Systems

As of Oct. 17, eight of the 13 container terminals in LA-Long Beach were using appointment systems. On that day, ETS (Everport Terminal Services) began using its system for import loads. More information about the ETS appointment system can be found at http://www.etslink.com.

A ninth terminal, YTI (Yusen Terminal Inc.) plans to have an its appointment system running by March 2017.

Average in-terminal turn time in October 2016:
50.2 minutes day shift
51.2 minutes night shift

For comparison, the average in-terminal turn time in September was 45.1 minutes for the day shift and 47.1 minutes for the night shift. Turn times increased in October as terminals redistributed Hanjin containers to other terminals.

In-terminal turn time is the average amount of time a truck is inside a terminal to complete a transaction. Truck activity information is derived from RFID data, and excludes lunch hour, breaks and trouble tickets. Turn time at individual terminals will vary depending on time of day and other factors. For more information about turn times and how we measure them, please see our Q&A at http://goo.gl/PiOjBp.

Average daily moves per truck in October:
5 or more moves per day: 5%
4 moves per day: 9%
3 moves per day: 24%
2 moves per day: 39%
1 move per day: 23%

Gate moves during Peak and OffPeak shifts in October:
Total Peak gate moves: 396,324 (56%)
Total OffPeak gate moves: 305,960 (44%)

A gate move occurs when a container enters or leaves a marine terminal via the truck gates. Peak shifts are Monday through Friday, 8:00 a.m. to 5:00 p.m. OffPeak shifts are weeknights from 6:00 p.m. to 3:00 a.m. and on Saturdays from 8:00 a.m. to 5:00 p.m.

Note:
All terminals were closed for the OffPeak shift on Oct. 6 for an ILWU Stop Work Meeting.

West Coast Terminals Evaluate Extended Gate Options

The marine terminals at the Ports of Los Angeles and Long Beach held a workshop on Oct. 20 with industry stakeholders to evaluate potential alternatives to the current extended gates model used at the ports under the OffPeak Program.

The 13 container terminals that comprise the West Coast MTO Agreement (WCMTOA) met in San Pedro with more than 70 leaders representing importers, exporters, trucking companies, logistics providers, government representatives and other stakeholders. The OffPeak program is managed by PierPass Inc., a not-for-profit company formed by WCMTOA to coordinate multi-terminal programs addressing congestion, air quality and security.

PierPass launched the OffPeak program in 2005 to reduce severe cargo-related congestion on local streets and highways around the Los Angeles and Long Beach ports. Using a congestion pricing model, PierPass charges a Traffic Mitigation Fee (TMF) on weekday daytime cargo moves to incentivize cargo owners to use the OffPeak shifts. The TMF also helps pay for the labor and other costs of operating the OffPeak shifts.

Since 2005, OffPeak has taken more than 35 million truck trips out of daytime Southern California traffic and diverted them to less congested nights and weekends.

Various interested parties have proposed alternate models for the extended gates. These include variable pricing, under which the TMF would be higher in times of high gate activity and lower in times of low gate activity; a lower flat fee applying both to day and night moves, with appointment systems to help regulate traffic flow; and port-wide peel-off, in which trucks would operate like taxis in an airport queue and each pick up the next available container.

Working with PierPass staff, the PierPass Advisory Committee has been tasked with compiling the feedback received at the workshop and producing a report, with possible recommendations, on proposed changes to the model. PierPass will distribute the final draft of the Extended Gates Report and Recommendations in mid-April. A follow-up to the Extended Gates Workshop has been scheduled for early May.

“The stakeholders who gathered yesterday share the goals of moving cargo efficiently and productively through the ports while minimizing impacts on neighboring communities,” said PierPass President John Cushing. “We welcome stakeholder input on potential alternatives to meeting the needs of operating and funding extended gates and distributing truck traffic between day and night to minimize road congestion.”

The West Coast MTO Agreement is filed with the Federal Maritime Commission, and comprises the 13 marine terminal operators serving the Los Angeles and Long Beach ports.

PierPass September 2016 Newsletter

PierPass monthly transaction data
Each month we provide a summary of the latest transaction data from marine terminal operators (MTOs) at the Port of Los Angeles and Port of Long Beach. Below please find data from the month of August 2016.

Average in-terminal turn time:
43.4 minutes day shift
45.9 minutes night shift

For comparison, the average in-terminal turn time in July was 44.7 minutes for the day shift and 47.6 minutes for the night shift.

In-terminal turn time is the average amount of time a truck is inside a terminal to complete a transaction. Truck activity information is derived from RFID data, and excludes lunch hour, breaks and trouble tickets. Turn time at individual terminals will vary depending on time of day and other factors. For more information about turn times and how we measure them, please see our Q&A at http://goo.gl/PiOjBp.

Average daily moves per truck in August:
5 or more moves per day: 6%
4 moves per day: 9%
3 moves per day: 29%
2 moves per day: 37%
1 move per day: 19%

Gate moves during Peak and OffPeak shifts in August:
Total Peak gate moves: 442,025 (57%)
Total OffPeak gate moves: 335,766 (43%)

A gate move occurs when a container enters or leaves a marine terminal via the truck gates. Peak shifts are Monday through Friday, 8:00 a.m. to 5:00 p.m. OffPeak shifts are all other times and are considered exempt from the Traffic Mitigation Fee.

Note:
All terminals were closed for the OffPeak shift on August 4 for an ILWU Stop Work Meeting.

PierPass August 2016 Newsletter

Overall cargo volume at the Ports of Los Angeles and Long Beach rose slightly in July compared to June – up 5.6% in Long Beach and 1.8% in Los Angeles.

After reaching two-year lows in the second quarter, truck turn times rose in July. A couple factors were in play. The terminals were mostly closed on Monday July 4 and Tuesday July 5, leading to a backlog when they reopened on Wednesday July 6. Also, the supply of available chassis tightened in July, as both street dwell times and the number of out-of-service chassis rose.

PierPass monthly transaction data
Each month we provide a summary of the latest transaction data from marine terminal operators (MTOs) at the Port of Los Angeles and Port of Long Beach. Below please find data from the month of July 2016.

Average in-terminal turn time:
44.7 minutes day shift
47.6 minutes night shift

For comparison, the average in-terminal turn time in June was 39.6 minutes for the day shift and 42.7 minutes for the night shift.

In-terminal turn time is the average amount of time a truck is inside a terminal to complete a transaction. Truck activity information is derived from RFID data, and excludes lunch hour, breaks and trouble tickets. Turn time at individual terminals will vary depending on time of day and other factors. For more information about turn times and how we measure them, please see our Q&A at http://goo.gl/PiOjBp.

Average daily moves per truck in July:
5 or more moves per day: 4%
4 moves per day: 10%
3 moves per day: 27%
2 moves per day: 38%
1 move per day: 21%

Gate moves during Peak and OffPeak shifts in July:
Total Peak gate moves: 365,135 (56%)
Total OffPeak gate moves: 286,161 (44%)

A gate move occurs when a container enters or leaves a marine terminal via the truck gates. Peak shifts are Monday through Friday, 8:00 a.m. to 5:00 p.m. OffPeak shifts are all other times and are considered exempt from the Traffic Mitigation Fee.

Note:
Most terminals were closed for the July 4 Independence Day holiday, and all terminals were closed for the ILWU “Bloody Thursday” holiday on July 5.
All terminals were closed for the OffPeak shift on July 14 for an ILWU Stop Work Meeting.

West Coast Terminals Shelve Chassis Fee but Affirm Right to Compensation for Services

Dear OffPeak Users,

The West Coast MTO Agreement (WCMTOA) today issued the following press release:

West Coast Terminals Shelve Chassis Fee but Affirm Right to Compensation for Services

LONG BEACH, Calif., Aug. 23, 2016 – The West Coast MTO Agreement (WCMTOA) today announced it has shelved plans to introduce a chassis services fee, as individual marine terminals negotiate directly with chassis leasing companies over hosting agreements.

WCMTOA’s member terminals affirm their right to seek compensation for the costly services they provide to chassis leasing companies at the Ports of Los Angeles and Long Beach. It costs terminals more than $200,000 per acre per year to lease land from the ports, and the terminals each have many acres stacked with chassis. This land could otherwise generate income for terminals by letting them process more containers, and would also let them manage containers more efficiently. Terminals have also been covering the cost of ILWU labor needed to stack, unstack and move the chassis, and the cost of the personnel, hardware and software needed to provide chassis usage data to the leasing companies.

In June, after two years of providing chassis management and storage to the leasing companies without reimbursement, WCMTOA announced a chassis services fee applying to chassis owners that receive services from WCMTOA’s marine terminal members. Since then, negotiations between individual terminals and some of the leasing companies have moved forward.

The leasing companies on Aug. 9 filed a Petition for an Order to Show Cause with the Federal Maritime Commission, seeking to avoid paying for the services they receive. The FMC on Aug. 16 asked interested parties to submit their views or arguments related to the Petition by Aug. 26. While it has shelved plans for the fee, WCMTOA intends to vigorously defend its position in its response to the Petition. WCMTOA members strongly believe the chassis owners must be responsible for covering the land, labor and technology costs the terminals incur on their behalf.

The West Coast MTO Agreement is filed with the Federal Maritime Commission, and comprises the 13 marine terminal operators serving the Los Angeles and Long Beach ports.

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Terminals in Ports of Los Angeles and Long Beach Move Start of Chassis Rule to September 1

LONG BEACH, Calif., Aug. 1, 2016 – The West Coast MTO Agreement (WCMTOA) has extended the implementation date of a new tariff rule for chassis services by one month until September 1. The rule applies to chassis owned by chassis leasing companies that receive services from WCMTOA’s marine terminal members at the Ports of Los Angeles and Long Beach.

The chassis system in the United States has been in flux for several years as shipping lines have moved away from providing the chassis (the truck trailer onto which containers are mounted) as part of their services. Since 2014, users in Los Angeles-Long Beach have arranged chassis directly with the leasing companies.

However, the terminals haven’t been compensated by the leasing companies for basic services provided such as storage space, stacking and unstacking the chassis, and electronic data interchange (which tells the chassis lessors who is using their chassis). Since the chassis leasing companies formed a “pool of pools” in early 2015, the terminals have been working with the leasing companies to address the compensation and services issues.

The new Rule 15 of WCMTOA’s Marine Terminal Schedule No. 1 describes the “On-Terminal Chassis Services” provided and establishes the “Chassis Services Fee.” The rule provides for a $5 fee each time a chassis enters or leaves the terminal, to cover the cost of services. The fee will be collected by PierPass on chassis with loaded or empty containers mounted, but not on bare chassis. MTO Schedule No. 1 is available at http://goo.gl/QihQ1u.

No fees will be charged for chassis that are owned directly by cargo owners or trucking companies, as these owners don’t require the services provided to leasing companies. Neither cargo owners or trucking companies need register their chassis under Rule 15.

Rule 15 was originally scheduled to take effect today, August 1. On Friday, PierPass informed the FMC that it was extending the start date to September 1, giving the leasing companies additional time to implement the change without impacting cargo flow in the ports.

The West Coast MTO Agreement is filed with the Federal Maritime Commission, and comprises the 13 marine terminal operators serving the Los Angeles and Long Beach ports.

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PierPass July 2016 Newsletter

Fastest Turn Times in Two Years

In the second quarter of 2016, trucks were able to pick up and deliver containers at the Ports of Los Angeles and Long Beach more quickly than in any other quarter over the last two years, according to monthly data reported by marine terminals and compiled by PierPass Inc.

In both May and June, turn times fell below 40 minutes during the Peak shift and below 45 minutes during the OffPeak shift for the first time since the second quarter of 2014. Turn time measures how long it takes a truck to drop off or pick up a container at a marine terminal. The average turn times for the full quarter were 40.8 minutes (Peak) and 43.0 minutes (OffPeak), down from 55.3 minutes (Peak) and 58.4 minutes (OffPeak) during the fourth quarter of 2014.

PierPass monthly transaction data
Each month we provide a summary of the latest transaction data from marine terminal operators (MTOs) at the Port of Los Angeles and Port of Long Beach. Below please find data from the month of June 2016.

Average in-terminal turn time:
39.6 minutes day shift
42.7 minutes night shift

For comparison, the average in-terminal turn time in May was 39.2 minutes for the day shift and 41.1 minutes for the night shift.

In-terminal turn time is the average amount of time a truck is inside a terminal to complete a transaction. Truck activity information is derived from RFID data, and excludes lunch hour, breaks and trouble tickets. Turn time at individual terminals will vary depending on time of day and other factors. For more information about turn times and how we measure them, please see our Q&A at http://goo.gl/PiOjBp.

Average daily moves per truck in June:
5 or more moves per day: 6%
4 moves per day: 11%
3 moves per day: 26%
2 moves per day: 37%
1 move per day: 20%

Gate moves during Peak and OffPeak shifts in June:
Total Peak gate moves: 412,910 (57%)
Total OffPeak gate moves: 310,841 (43%)

A gate move occurs when a container enters or leaves a marine terminal via the truck gates. Peak shifts are Monday through Friday, 8:00 a.m. to 5:00 p.m. OffPeak shifts are all other times and are considered exempt from the Traffic Mitigation Fee.

Note:
All terminals were closed for the OffPeak shift on June 2 for an ILWU Stop Work Meeting.