BNSF's response to the American Chemistry Council's study on rail fuel surcharges

This is a politically-driven document. BNSF strongly disagrees with both the conclusions reached and methodologies utilized with respect to BNSF in the American Chemistry Council Report. Flaws in methodology, which result in the erroneous conclusions, include the treatment of fuel hedging, the time period or base period assumption, exclusion of certain fuel costs, and assumptions on renewal of contracts. Rather than over recover, BNSF believes it significantly under recovered unhedged fuel costs over the time period analyzed by the ACC.