SPECIAL BOARD OF ADJUSTMENT NO, 570

Established Under

Agreement of September 25,1964





PARTIES Brotherhood of Railroad Carmen Division Transportation
Communications International Union
TO and
DISPUTE: , Burlington Northern Railroad Company

STATEMENT OF THE CLAINI:








ordered to compensate furloughed Carmen R., L. Todd, D. L.
McCabe, S. C. Young, E. E. Fraerich, J. J. Schoolcraft~ S. D.
Toombs, P. E. Avers, and K. Fi. Eloge in the amount of fifty-five
(55) days pay each for their rate and class account of the deficiency
in notice of the change in Carrier operation and that the Claimants
be afforded a monthly dismissal allowance as provided, for in
Article 1, Section 6 or their option of Section 7 of September 25,
1964 Agreement.
FT?YDLN~,S,:

By bulletin dated January 13, 1987, the Carrier abolished three train yard inspector positions in the Mechanical Department at Guernsey, Wyoming,effecdve January 18, 1987. By bulletin dated January 20, 1987, the Carrier abolished two leadman relief, two leadman and ten Carman positions 'at Alliance, Nebraska, effective January 25, 1987. By bulletin dated January 20, 1987, the Carrier advertised for two leadman, one leadman rslief, two relief carmanlleadrnan and two carman positions at Alliance. By bulletin dated January 20, 1987, the Carrier furloughed seven of the eight named Claimants at Alliance, effective January 30, 1987. By corrected abolishment notice dated January 21, 1987, the

' SBA No. 570
Award No.
Case No. 1 b~
i r Page 2
Carrier abolished two leadman, one Leadman relief and nine Barman positions effective
January 30, 1987.
According to the Carrier, these abolishments occurred as a result of the decision
of Oklahoma Gas and Electric Company (OG&E) to cease coal shipments under a con
tractual arrangement with the Carrier during the remaining two years of that arrange
ment-an arrangement that, according to the Carrier, expired December 31, 1988.' The
Carrier asserts that in December 1986 it was advised by OG&E that OG&E was going to
divert all of the Red Rock tonnage to another carrier effective January 1, 1987Bwhich ul
timately resulted in a loss of approximately 4 million tons of coal, or approximately
40,000 cars of business in 1987, thereby causing the abolishment of certain cw-man posi
tions at Guernsey and Alliance.
This Board does not find that the Organization has sufficiently demonstrated the
existence of an Article I, Section 2 event and therefore we mast deny the claim.
. First, a threshold dispute raised by the Carrier focuses upon the Carrier's assertion
that Article I, Section 2(e)'s reference to "Voluntary or involuntary discontinuance of
contracts" is not applicable to the coal hauling Co=actual arrangement between the
Carrier and OGRE because at the time Article I, Section 2(e) was drafted the kind of
contractual arrangement between the Carrier and OG&x was illegal. Specifically, the
Carrier argues that these types of arrangements were not made lawful until the ICC es
tablished a procedure in 1978 for dete , =ning the legality of such provisions which was
then superseded by the passage of the Staggers Rail Act of 1980 which expressly permit
ted private rate contracting. The Organization asserts that the arrangement between the
Carrier and OG&E constitutes a contract within the meaning of Article I, Section 2(e).
The Carrier's argument is not persuasive. '?his Board is confined to the clear ]an
The record discloses the existence of two contracts between the Carries and OG&E. The fast involves
the movement of Wyoming Powder River Basin coal via BN-Kansas City-MP to OG&H's Muskogee Plant
at Fort Gibson, 01dahoma. The second involves the movement of Wyoming Powder River Basin coal via
BN-Kansas City-ATSF to OG3tE's Sooner Plant at Red Rock, Oklahoma.
















`~ of words, the argument that "a contract is a contract is a contact" is a persuasive one.

~, [emphasis added]. l.-t those cases, at the time the dispute arose the existing statute, regu-


                                      Award No: LO Z

                                      Case No. 1269 Page 4

Hoard would not construe the contract so as to violate the existing law. That is not the case herein- Here, at the time the dispute arose in 1987, there was nothing unlawful about the contractual arrangement between the Carrier and OG&E.

Second, with respect to the Organization's position, we are not persuaded that the facts herein demonstrate a "discontinuance of contracts" under Article I, Section 2(e). It is undisputed that the arrangement between the Carrier and OG&E "was to expire in December, 1988" as the Carrier asserts. See the Organization's letter of July 21, 1987 (Org. Exh. I). Thus, it is not disputed, that at the time the events arose in January 1987, the contractual arrangement between the Carrrier and OG&E existed and had approx4riately two years to run. Therefore, we cannot say that there was a "discontinuance" of the contractual arrangement between the Carrier and OG&E therefore making the occurrence in this matter an Article 1, Section 2 event- At most, OG&E did not utilize the contractual arrangement to the extent it did in tire past. Hut nevertheless, the contractual arrangement remained in effect after the incident L7volved in this case.z

The Organization's cited authority does not change our conclusion. Reliance upon the line of authority typified by Avrards 95 and 406 of this Board show that in those cases there was an action by the customer to "cancel the arrangement" (Award 95) or a "termination of the agreement" (Award 406). Here, the evidence shows that the contractual arrangement remained in effect for two years after the incidents giving rise to the dispute.


Third, with respect to the notice question, Article 1, Section 4 mandates "at least sixty (60) days ... written notice of the abolition of jobs as a result of changes in operations for any of the reasons set forth in Section 2 hereof ...:' The Carrier clearly did not give 60 days notice in this r"natter. However, because we are not satisfied that an Article


According to the affidavit of Assistant Vice President Y. M. Mmagan (Car. Exh. 8), OG&E continued to nove tonnage under the contract covering ahe Muskogee plant.

' SBA No. 570
                                          Award No.

                                          Case No. 12

' Page 5
      I, Section 2 event has been shown, we axe unable to find a violation of the notice provi

      sions in Article I, Section 4.

      Fourth. we must address the consequences of the Carrier's failure to provide a copy of the OG&E contract to the Organization. Because of confidentiality reasons arising out of the competitive nature of the coal business, the Carrier declined to provide the Organization with a copy of the contract between it and OG&E. Instead, the Carrier provided an affidavit from Assistant Vice President Flanagan addressing certain aspects of the arrangement! Under other circumstances, such a failure to disclose would entitle the Organization to adverse inferences against the Carrier. See Third Division Awardi 28430 and 28229 (the carriers were not pennutted to rely upon the terms of leases that they refused to timely divulge to the Organization). However (with the exception of the Organization's assertion that OG&E bought back the contract discussed immediately below), here the existence of the contractual arrangement between the Carrier and OG&E is not disputed and the duration of that arrangement for two years after the events in qucston is similarly not disputed. Given these undisputed facts essential to the resolution of this dispute, we are not satisfied that disclosure of the terms of that contractual arrangement would have changed the result of this matter. Most significantly, the Carrier has not relied upon a specific term of that contractual arrangement as a defense in this matter wherein the existence of t-hat terns is disputed by the Organization and that term is material for the resolution of the dispute. Again, the operative and undisputed determinative fact is the existence of the contractual arrangement between the Carrier and OG&E which ran until December 1988. Compare Third Division Award 28430 ("after having failed to produce the Lease upon which it relied, the Carrier cannot now rely upon the terms of that Tease as a defense to the Claim.' [emphasis added]). Here, the Carrier has not relied upon a disputed term of the OG&E contract which is material to the resolution of this


      3 According to the Carrier (Car. Submission at 17), confidentiality is further mandated by ICC rules.

- SBA No. 570
' Award No.
                                          Case No. 12

                                          Page 6


      dispute.4

      Fifth, while the record developed on the property shows that the existence of the contractual arrangement between the Carrier and OG&fi lasting until December 1988 was not a disputed fact, the Organization did argue that OG&E "bought back a contract with the Burlington Northern Railroad Company for an arnount of twenty-one million dollars ($21,000,000) which was paid to the Burlington Northern Railroad ... [which] information was received by one of [the Carrier's] supervisors." See Org. Exh. I. We find that, without further detail, such an unsupported assertion is, at most, speculative and not sufficient for this Board to find that the Organization has shown that the contractual arrangement between the Carrier and OG&E which was to last until December 1988 ceased to exist before that date. .

      Thus, the record sufficiently demonstrates that as a result of OG&E's actions, the

      Carrier incurred a loss of approximately 4 million tons of coal, or approximately 40,000

      cars of business in 1987 thereby causing the abolishment of certain positions at Guernsey

      and Alliance. See SBA 5?0, Award 409 (no violation where a shipping route was

      changed at the request of shippers). «'e are therefore unable to sustain the claim.


          Based on the above, the claim must be denied.


Perhaps this entire problem could have been avoided through a disclosure of the terms of the contract with the competitive material 6eteted. However, given a circumstance where the Carrier specifically relies upon a term of a non-disclosed contract which term is material to the resolution of the dispute. we cannot say the result would be cltc same. See Awards 28430, 28229, supra and cases cited Herein. While we recognize the need (and. indeed the requirement in some circumstances) for confidentiality, by the same wkm the Organization is entitled to see the information material to the resolution of a dispute upon which the Carrier may rely. Procedures for disclosure of arguably confidential material are routine in litigation (c.g.. through use of protective agreements preventing disclosure to outside interests, excising of competitive material and the like). The same could have been accomplished here which would have efeczively balanced the Carrier's right to confidentiality and the organization's right to see evidence.

                                    SBA No. 570

                                    Award No. W4

                                    Case No. i1

                                    Page 7


      Claim denied.


      This Board, after consideration of the dispute identified above, hereby orders that


an award favorable to the Claimants not be made.

                  Edwin H. Benn, Neutral ~,._x-~-


        J


atrcerMembe~ Labor ~ e bets

Adopted at Chicago, lllinois, this 0 day of JA,vro,4.,%J') , 1993.

S
                    SPECIAL BOARD OF ADJUSTMENT NO. 570

                    AWARD NO. ZD 94

                    (SBA CASE NO. 12699)

                    REFEREE: EDWIN H. BENN

                CONCURRING AND DISSENTING OPINION OF THE LABOR MEMBERS OF SPECIAL BOARD OF ADJUSTMENT AWARD NO. 570


        The Labor Members of SBA 570 concur in the findings of the eminent and distinguished neutral in this instant case wherein he stated:


            "According to the Carrier, these abolishments occurred as a result of the decision of the Oklahoma Gas and Electric Company (OG&E) to cease coal shipments under a contractual arrangement with the carrier during the remaining two years of that arrangement-an arrangement that, according to the Carrier, expired December 31, 1988.I/ The Carrier asserts that in December 1986 it was advised by OG&E that OG&E was going to divert all of the Red Rock tonnage to another carrier effective January 1, 1987, which ultimately resulted in a loss of 4 million tons of coal, or approximately 40,000 cars of business in 1987, thereby causing the abolishment of certain carmen positions at Guernsey and Alliance."


        Labor Members point out to the interested reader of this document that the referee has accurately and factually set forth


        The record discloses the existence of two contracts between the Carrier and oG&E. The first involves the movement of Wyoming Powder River Basin coal via BN-Kansas City-MP to OG&E's Muskogee Plant at Fort Gibson, Oklahoma. The second involves the movement

`°' of Wyoming Powder River Basin coal. via BN-Kansas City-ATSF to
        OG&E's Sooner Plant at Red Rock, Oklahoma.

                                      SBA 570

                                      Award No. / t

                                      `~tr case No. 1269 Page 2


the exact position of the carrier and the employees in this instant dispute. This dispute is bottomed on Article I of the September 25, 1964 Agreement, as amended and it is noted that certain provisions of this agreement reads specifically:


      "The protective provisions of the Washington Job Protection Agreement of May, 1936, shall be applicable, as more specifically outlined below, with respect to employees who are deprived of employment or placed in a worse position with respect to compensation and rules governing working conditions as a result of any of 'the following changes in their operations of this individual carrier:


          e. Voluntary or involuntary discontinuance of contracts;"


The Labor Members carefully point out that the exact contract language above (e. Voluntary or Involuntary Discontinuance of Contracts) does not contain the word cancellation and/or termination. it is discontinuance. It was and is the position of the employees that the OG&E was engaged in the voluntary discontinuance of its contract with this carrier when it diverted 40,000 cars of business away from this carrier. It was and continues to be the position of the employees that this carrier was involved in an involuntary discontinuance of contracts, over which it had no control, when the customer (OG&E) discontinued the use of its contract. It is simply pointed out that in the agreement

                                      SSA S7o

                                      Award No. j~.

                                      Case No. 1269

                                      Page 3


itself there is no necessity and no need for a cancellation or a cessation of a contract but rather the voluntary or involuntary discontinuance of that contract will trigger benefits.

      The employees dissent to the referees finding that:


      OThe Board does not find that the organization has sufficiently demonstrated the existence of an Article I, section 2 event, and therefore, we Taust deny the claim."


The employees simply point out that the learned and revered referee has clearly indicated a connective cause or a causal nexus that directly affected the named claimants when this carrier lost approximately 40,000 cars of business by a discontinuance of a contract. by its customer. In the same breath this referee finds that there is no connective cause between the placing of these employees in a worse position with respect to compensation and working rules and the discontinuance of contracts that covered approximately 40,000 cars of business. The employees vigorously dissent to the finding that there was not a connective cause between the furloughing of the named claimants in this claim and the carrier being affected by an involuntary discontinuance of the contract on its part and these named claimants were affected by a voluntary discontinuance of a contract with this carrier on the part of the OGSE. With SBA 570 Awards 658, 704 and 739, in front

of him the referee elected to find that there was no nexus or connective cause between these two events. SBA 570 award 6S8, 704 and 739 define, by referee's, a connective cause or a causal nexus

                                      SBA 570

                                      Award No.

                                      Case No. 1269

                                      Page 4


between events and claimants under Article a of the September 25,
1964 Agreement, as amended.
The findings of this Board also state:

      "The organization's cited authority does not change our conclusion. Reliance upon the line of authority typified by Awards 95 and 406 of this Board show that in those cases there was an action by the customer to "Cancel the arrangement" (Award 95) or a "termination of the agreement'* (Award 406). Here, the evidence shows that the contractual arrangement remained in effect for two years after the incidents giving rise to the disput&."

It is once again carefully pointed out to the interested reader of this document that the words of that agreement itself 'do not contain "cancellation" or "termination" but rather the !'voluntary or involuntary discontinuance" of a contract.

The employees respectfully submit that this award contains palpable error and is, therefore, worthless for any use as precedental value in any arbitration forum, including but not limited to those created under the Railway Labor Act.


                                  Labor Member


                                      a

                                          r


                                  Laborer


                                  habor~tjhaber

                CARRIER MEMBERS' CONCURRING

                AND DISSENTING OPINION

                TO

                AWARD 1096 CASE 1269

                (Referee Jenny


The Referee denied the claim on the basis "...the operative and undisputed determinative fact is the ,existence of the contractual arrangement between the Carrier and the OG&E which ran until December 1988." The record supports the existence of the contract and the Referee's decision is clearly correct in that regard.

We cannot agree, however, with the Referee's dicta rejecting the carrier's assertion that the 8N-OG&E Agreement could not properly be characterized as a "contract" within the meaning of Article I, Section 2 of the September 25, 1964 Agreement.

While there is much that could be said about this matter in 'support of the Carrier's argument, inasmuch as the issue is moot insofar as this case is concerned, we will refrain from doing so. in our view, the Referee erred by addressing the matter and further


                                              erred with respect to his conclusion concerning it. s

M. C. Lesnik M. W. FifigerWE-

E. Yos t I
January 20, 1993 _