Econometric Analysis of Costing System Components in Rail Rate Regulation

In response to Congressional directive, the Interstate Commerce Commission (ICC) has created a railroad costing system that includes as key components ratios designed to estimate variable costs associated with freight transportation. The estimated variability ratios are used to determine freight surcharges, jurisdictional threshold rates, and basic rail rates in administrative law and federal court proceedings. In this article we assess the quality and reliability of the estimated variability ratios and their components against standards from economic theory and statistical theory and practice. Our work includes reproduction of the naive ICC regressions, updated naive regressions for the latest data set, estimation based on more secure econometric foundations, and sensitivity analyses comparing alternative estimation procedures. Fundamental questions arise concerning the scientific and evidentiary standards that are required for econometric methodology in policy making and regulatory activities.