RLBA incorporated railroad configuration, traffic and operating inputs provided by various expert witnesses into a computerized, railroad operations simulation model employed on behalf of AEP Texas North Company (AEP), to support the company’s request to the Surface Transportation Board (STB) to secure relief from excessive coal transportation rates. RLBA represented in the model the hypothetical “stand-alone railroad” extending from the Powder River Basin in Wyoming to power plants and rail connections in Texas. Staff also recommended infrastructure and operational improvements and conducted numerous simulations to evaluate and demonstrate railroad capacity to handle coal unit trains.

RLBA's mission was to demonstrate, using the simulation model, that the proposed stand-alone railroad would meet the needs of shippers and be more cost efficient than the service currently provided by BNSF Railway, and assist in justifying lower AEP transportation rates. As part of the effort, RLBA's staff tested the inputs and design of the model, developed alternatives to be considered by other consultants, sponsored testimony before the STB on the validity of the results produced by the model, evaluated and critiqued BNSF Reply Testimony and presented Rebuttal evidence.