ship or train directly onto pre-staged chassis, can expedite the removal of containers from the terminal area to the benefit of shippers (i.e., beneficial cargo owners [BCOs]) and the terminal operator. However, this practice can make more sense when combined with a contractually defined haulage arrangement where the BCO gives the ocean carrier the responsibility to coordinate and pay for the entire transportation service, including sourcing of the pre-positioned chassis and the readying of drayage services through pre-negotiated agreements with IEPs and motor carriers. Wheeled operations are less suited to BCO haulage arrangements with ocean carriers that exclude container delivery and thus give the motor carrier the responsibility to secure the chassis for the container’s drayage, especially when that equipment cannot be staged in advance for pre-mounting. If the container needs to be “flipped” from the pre-staged chassis to the motor carrier’s selected chassis, this process entails additional expense and unproductive time spent waiting by truck drivers (who are often paid by the mile rather than only by the hour).

Likewise, the relative advantages of interoperable pools, where multiple IEPs (and sometimes motor carriers) contribute chassis for shared use by motor carriers, will depend on many market-specific factors, including the size of the drayage market, the number and location of intermodal terminals, and the need for a readily available fleet of chassis to accommodate large peak demands from offloading ships and railroads. In theory, such pooling arrangements can allow each IEP to invest in smaller chassis fleets, knowing that the pooled equipment will be sufficient to cover the peak needs of their partner ocean carriers. Smaller drayage markets where motor carriers and individual IEPs can provide chassis in numbers sufficient to satisfy demand may not be as conducive to such pooling arrangements. However, even in markets with large volumes of container traffic, the practicality of an interoperable pool can depend on the terms under which the pool operates as well as on the geography of the market, including the proximity of terminals to one another and to delivery points, which impact where chassis need to be stored and made available to motor carriers, whether in the fleets of IEPs and pools or from the motor carrier’s own equipment.

These two examples—about wheeled operations and interoperable pools—show how many factors complicate the recommendation of a best practice for chassis provisioning in a particular market. Adding further to the complexity is not knowing the specific interests of the BCOs in each regional market and how these interests are satisfied by their confidential agreements with transportation service providers for moving their containerized cargo. BCOs may differ in their preferences for specific transportation service attributes such as the emphasis they place on total transportation price, transaction simplicity, and time requirements for receiving a container and unloading it from a chassis. Without knowing these BCO interests and

the degree to which they are satisfied by the private terms of their contractual arrangements with transportation providers, efforts to identify best practices are fraught with uncertainty. It is important to keep in mind that all the parties involved in a container move have agreed to the contractual terms affecting chassis provisioning, and hence one can presume that terms satisfy each party’s interests.

This report synthesizes the views on chassis provisioning practices offered by dozens of consulted participants in the intermodal container shipping enterprise, including ocean carriers, railroads, motor carriers, IEPs, pool managers, labor, and BCOs and their agents across a varied mix of geographic regions. From the earliest stages of this consultation, the information obtained made it clear that a study intent on identifying the best practices for chassis provisioning generally (i.e., a set of such practices that would be desirable across markets and circumstances) would not be feasible. Many features of the provisioning system that are viewed as disadvantages by some transportation asset and service providers are viewed as advantages by others. Significantly, the consultations caused the committee to realize that even focused efforts to identify best practices for specific market scenarios would be problematic because of the heterogeneity of participants and interests in the drayage markets. An important insight is that chassis provisioning practices are varied in the United States not only because of the diverse conditions that exist among drayage markets but also because of the diversity in BCO interests and preferences. Another insight is that the efficiency and effectiveness of the chassis provisioning system are best considered from the standpoint of the customer BCOs and with respect to the functioning of the larger container shipping enterprise that serves BCOs as well as the public. Important considerations include the external impacts that the provisioning system can have on the public, such as introducing risks to public safety and environmental harm through added motor vehicle traffic and substandard equipment operating on the roads.

Even if it is not practical to identify an optimal chassis provisioning system, there is little question that chassis provisioning is a controversial part of the supply chain, raising issues unique to the United States, as the rest of the world relies on motor carriers to provide the chassis needed for container drayage services. However, consultations and analysis in this report suggest that motor carrier–controlled chassis are accounting for an increasing share of container drayage moves, albeit to a degree that differs across individual markets. Designing policy interventions that are robust and adaptive to conditions that vary by location and change over time is a perennial challenge but one that is especially challenging in this instance. In short, drayage markets vary widely and the specific preferences of BCOs and how they are satisfied by the variations in current chassis provisioning practices cannot be determined.

they are the most susceptible to being neglected or underprioritized on the information pathway, but they are no less important. Key to this functioning, both for chassis and drayage services specifically and for the container shipping enterprise generally, is providers of transportation services—up and down the supply chain—having access to timely and sufficiently detailed information on container volumes and movements. Opportunities for leveraging ongoing developments in collaborative problem solving and the collection and synthesis of supply chain data to support analyses and forecasts of incoming container volumes remain a necessity.

The committee learned about several public- and private-sector initiatives underway, and which are noted in this report, to expand and strengthen the sharing of information among the many participants in the intermodal container shipping industry and across the international supply chain more generally. Among the initiatives noted in this report are the Freight Logistics Optimization Works, International Convention on Facilitation of International Maritime Traffic, and Maritime Transportation Data Initiative. Significantly, in April 2023, FMC Commissioner Bentzel recommended the establishment of the Maritime Transportation Data System (MTDS), which would harmonize available data so that information on international shipping container traffic activity would be accessible online. To further this initiative, FMC is seeking comments about the data elements that should be included and communicated to promote the interest of supply chain efficiency, presumably including efficiencies in the provision of container chassis and drayage services. It will be important for these efforts to engage providers of chassis and drayage services, which may indeed be the plan and central to the goal of developing and sustaining an efficient and robust supply chain.

RECOMMENDATIONS

Chassis availability and safety are important factors for the efficient functioning of the intermodal container industry and an imperative for public policy. FMCSA’s roadside inspection data reveal quality control issues with intermodal chassis that were supposed to have been remedied by the introduction of stricter maintenance and repair protocols and FMCSA monitoring of their effectiveness and compliance by IEPs and pool managers. A review of inspection records from recent years reveals that the effect of these requirements as implemented and enforced should be evaluated, informed by a thorough review of the inspection data. Because of the variability in how intermodal chassis fleets are owned, controlled, and managed, the incentives for equipment quality control and enhancement can differ. Such an evaluation would therefore benefit from a deeper understanding by FMCSA of these provisioning means. That understanding resides at the

Federal Maritime Commission, which oversees intermodal chassis provisioning arrangements and practices.

FMC’s recognition of the importance of, and intentions to promote, information sharing for the efficient functioning of the international supply chain are welcome developments. FMC is well positioned to play a lead role in spurring such efforts and ensuring that the efficiency benefits extend across the full supply chain to include container drayage. FMC’s interest in the efficiency of the supply chain must also be attune to its individual elements and to phenomena detrimental to their efficient functioning. Chassis quality assurance is a longstanding and chronic problem, not only for supply chain efficiency but for public safety on the highways. Hence, FMC’s efforts to address the chassis quality problem should be accompanied by a commitment to work with FMCSA to ensure chassis roadworthiness for highway safety.

For the purposes of furthering these public interests in a reliable, efficient, and safe functioning supply chain, the committee recommends the following:

Recommendation 1: The Federal Maritime Commission should assume a lead role in promoting, and coordinating as necessary with the U.S. Department of Transportation, the sharing of data on intermodal shipping container traffic across all elements of the supply chain, including its beginning and end points that require efficient drayage services. The commission should ensure that any such system, such as the proposed Maritime Transportation Data System, helps create a process for the capture and timely provision of container traffic information up and down the supply chain to include the providers of drayage services and equipment.¹

Recommendation 2: The Federal Maritime Commission (FMC) should consult regularly with the Federal Motor Carrier Safety Administration (FMCSA) about the quality, condition, and roadworthiness of intermodal chassis. Ongoing monitoring of chassis inspection performance and compliance with standards is warranted and would benefit from FMCSA having a strong understanding of the chassis provisioning system and how its segments operate. FMC should help FMCSA gain this understanding and regularly convey the feedback it receives about chassis condition, including complaints from motor carriers.

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¹ This text was changed after release of the prepublication version of the report to clarify that the Maritime Transportation Data System is a proposed initiative.

markets and to the changing dynamics of the marketplace. Information gathered from the committee’s consultations and other analysis in this report suggest that motor carrier–controlled chassis are accounting for an increasing share of container drayage moves, yet this pattern may differ across individual markets. Designing policy interventions that are robust and adaptive to conditions that are varying by location and changing over time is a perennial challenge but especially challenging in this instance and may not be a practical endeavor. Instead, it is the committee’s conclusion that increased information sharing and analyses, and better enforcement of current regulations, are the best next steps to ensure the long-term functioning of the chassis market.