DCLI works hard every day to be the industry’s chassis partner of choice. We plan on continuing to do just that.

In light of the FMC’s ruling on IMCC’s complaint, we wanted to provide some initial information on its potential impacts. The primary focus of this ruling was on the OCEMA-managed Consolidated Chassis Management (CCM) pools and how they are run. Those pools, however, have either closed or decreased significantly in size over the last few years. In the case of the Southeast, the pool has transitioned to a new model without the multi-contributor or associated billing “choice” structure that was at the heart of the IMCC lawsuit.

In other words, the market has spoken and truckers and BCOs have a wide variety of options to choose from: competitive chassis pools like our DCLP, trucker owned or leased wheels, and any other number of chassis procurement options locally, regionally, and nationally. In fact, our data shows that one of every two chassis moves across the country for the ocean carriers we support is now performed by a trucker-controlled (leased, owned, or alternative pool) chassis, demonstrating that REAL choice exists.

Knowing that this ruling might cause some confusion around how it truly affects chassis procurement, we have prepared the following list of questions and answers. The FMC’s order covers four markets: Chicago, Memphis, LA/Long Beach, and Savannah. We have split this Q&A into those four markets in order to address the questions most pertinent to each. Please contact customerservice@dcli.com if you have any questions that aren’t addressed here – we’ll be happy to offer answers and add those Q&As to this page.

 

Chicago Market:
Q: What if I don’t want to use the chassis that’s under my box at a wheeled rail ramp?
A: Pool chassis have historically been used to support wheeled or hybrid operations at rail ramps. You are welcome to use any chassis that you’d like to move a box at the rail ramp. If the box is already mounted to a chassis, but you prefer to use a different one, you will have to coordinate with the local rail ramp to have the box flipped to your preferred chassis, which will be subject to its flip practices and rates. That has been, and will continue to be, your choice.

Q: Will gate edits still be allowed and prevent me from using whichever chassis I choose at rail ramps?
A: Gate edits are a control for on-terminal chassis inventory and do not impede the ability for you to use your own chassis or a chassis sourced from any off-terminal supplier. These edits are designed to protect the inventory that has been established at a rail ramp by multiple on-terminal chassis suppliers to support inbound trains and cargo that require pre-wheeling (i.e., dismounting containers from trains straight to chassis for quicker staging/pickup). These supplies are essential to ensuring supply chain fluidity and efficiency at each of these wheeled or hybrid locations. Moreover, it is not an ocean carrier-created or ocean carrier-mandated practice and, as such, we do not expect it to be impacted by the FMC’s ruling. It is important for all stakeholders to understand and accept that container demand must continue to be met or exceeded by chassis supply at locations that need chassis for pre-wheeling so that our valued railroad partners can ensure neither their operations nor the larger supply chain network are put at risk. Note also that gate edits are never present at rail facilities that run wholly grounded operations in Chicago.

Memphis Market:
Q: What if I don’t want to use the chassis that’s under my box at a wheeled rail ramp?
A: Pool chassis have historically been used to support wheeled or hybrid operations at rail ramps. You are welcome to use any chassis that you’d like to move a box at the rail ramp. If the box is already mounted to a chassis, but you prefer to use a different one, you will have to coordinate with the local rail ramp to have the box flipped to your preferred chassis, which will be subject to its flip practices and rates. That has been, and will continue to be, your choice.

Q: Will gate edits still be allowed and prevent me from using whichever chassis I choose at rail ramps?
A: Gate edits are a control for on-terminal chassis inventory and do not impede the ability for you to use your own chassis or a chassis sourced from any off-terminal supplier. These edits are designed to protect the inventory that has been established at a rail ramp by multiple on-terminal chassis suppliers to support inbound trains and cargo that require pre-wheeling (i.e., dismounting containers from trains straight to chassis for quicker staging/pickup). These supplies are essential to ensuring supply chain fluidity and efficiency at each of these wheeled or hybrid locations. Moreover, it is not an ocean carrier-created or ocean carrier-mandated practice and, as such, we do not expect it to be impacted by the FMC’s ruling. It is important for all stakeholders to understand and accept that container demand must continue to be met or exceeded by chassis supply at locations that need chassis for pre-wheeling so that our valued railroad partners can ensure neither their operations nor the larger supply chain network are put at risk. Note also that gate edits are never present at rail facilities that run wholly grounded operations in Memphis.

LA/Long Beach Market
Q: Do I have to continue using Pool of Pools (PoP) chassis for container moves?
A: You have always been free to use whatever chassis is available in the PoP, which is fully interoperable across the fleets contributed by DCLI, Flexi, and TRAC. You also continue to have the choice to bring your own wheels for any move. DCLI provides a portfolio of solutions to help support your choices within the market as PoP chassis currently carry less than one third of the total TEUs moving through the LA/Long Beach market.

Q: What if I don’t want to use the chassis that’s under my box at a wheeled rail ramp or marine terminal?
A: Pool chassis have historically been used to support wheeled or hybrid operations at marine terminals and rail ramps. You are welcome to use any chassis that you’d like to move a box at the rail ramp or marine terminal. If the box is already mounted to a chassis, but you prefer to use a different one, you will have to coordinate with the local rail ramp or marine terminal to have the box flipped to your preferred chassis, which will be subject to its flip practices and rates. That has been, and will continue to be, your choice.

Q: Are there other impacts to PoP arising out of the FMC’s ruling?
A: We are talking to our ocean carrier customers and will be reaching out to other stakeholders as well about how the FMC’s ruling may impact the PoP, but it is too early to predict at this time. For now, nothing has changed in terms of the day-to-day operations of the Pool of Pools.

Savannah Market:
Q: What does this ruling mean for using an SACP 3.0 chassis?
A: DCLI does not currently operate its chassis pool, DCLP, in the Savannah market. For questions about the impact of this ruling on SACP 3.0 operations, we encourage you to reach out to Consolidated Chassis Management. Please note that this ruling has no impact on your access to DCLI’s term lease and private pool products within the Savannah, GA market. If you are interested in learning more, please contact sales@dcli.com

What About Gray Pools?

It’s notable that the FMC’s ruling did not address the initial request in the IMCC’s case to make nationwide gray pools mandatory. Our CEO, Lee Newitt, recently discussed this topic on the Let’s Talk Supply Chain podcast . Here’s an excerpt:

 

If you’d like to get updates on how regulatory changes may impact free market competition, choice, and fleet safety, fill out the form below to be added to our update list: