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EXHIBIT C

(1) WAGE INCREASES

For Roadmen.-The carriers are willing to grant the following increases: Five cents per hour or 40 cents per basic day effective October 1, 1950;

An additional five cents per hour or 40 cents per basic day effective January 1, 1951;

An additional 22 cents per hour or 20 cents per basic day effective March 1, 1951;

Amounts paid under Department of the Army General Order No. 2 to be credited against the above increases;

A cost of living escalator clause based on a Consumers Price Index of 178, with adjustments to be made on a basis of one cent per hour or 8 cents per basic day for each one point change in the index, the first adjustment to be made on April 1, 1951, and adjustments to be made each three months thereafter. Under this clause rates could not be reduced below those in effect March 1, 1951; Under this proposal the current wage increase would amount to 191⁄2 cents per hour or $1.56 per basic day.

For Yardmen.-The carriers are willing to grant the following increases: Twenty-three cents per hour or $1.84 per basic day effective October 1, 1950; An additional two cents per hour or 16 cents per basic day effective January 1, 1951;

An addtional two cents per hour or 16 cents per basic day effective March 1, 1951;

Amounts paid under Department of the Army General Order No. 2 to be credited against the above increases;

A cost-of-living escalator clause based on a Consumers Price Index of 178, with adjustments to be made on a basis of one cent per hour or 8 cents per basic day for each one point change in the index, the first adjustment to be made on. April 1, 1951, and adjustments to be made each three months thereafter. Under this clause rates could not be reduced below those in effect March 1, 1951;

Under this proposal the current wage increase would be 34 cents per hour or $2.72 per basic day;

An additional 4 cents per hour of 32 cents per basic day on railroads or railroad' systems where the organizations elected to adopt the five day week for yard service employees, such increase to be effective if and when the five day week is made effective.

General. The carriers also stand ready to make effective for employees represented by the Order of Railway Conductors the report of Presidential Emergency Board No. 81 and the Memorandum of Agreement of December 21, 1950, with respect to (1) the Daily Earnings Minima for yard service employees, (2) Car Retarder Operators, (3) Footboard Yardmasters and (4) United States Mail Handling Allowance.

(2) SIX DAY WORKWEEK

The carriers are willing to grant the organizations the option to establish a six day workweek for yard service employees on 90 days' notice. If the parties cannot agree on the details of rules covering a six day workweek the carriers are willing to submit them to arbitration as hereinafter provided.

(3) FIVE DAY WORKWEEK

The carriers are willing to grant the organizations the option to establish a five day workweek for yard service employees on or after January 1, 1952, on three months' notice, provided that if it is claimed the manpower situation will not permit the performance of six and seven day service at straight time rates with reasonable regularity the question of whether there is sufficient manpower available to permit the adoption of the five day workweek shall be submitted for final decision to the nominee of the President of the United States. If the parties cannot agree on the detail of rules covering a five day workweek, the carriers are willing to submit them to arbitration as hereinafter provided.

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(4) MORATORIUM

The Agreement shall provide for a moratorium as suggested by the White House on changes in rates of pay, rules, or working conditions until October 1, 1953, provided, however, if government wage stabilization policy permits so-called annual improvement wage increases the parties may meet with the President or his nominee, on or after July 1, 1952, to discuss whether or not further wage adjustments are justified in addition to wage increases received under the costof-living formula. If the parties are unable to agree the question shall be submitted for final decision to a referee to be appointed by the President.

(5) RULES

The carriers propose to settle the following rules and have made definite proposals to that end:

Initial Terminal Delay-employees represented by the Order of Railway Conductors; Interdivisional Runs-employees represented by all three organizations; Pooling of Cabooses-employees represented by the Order of Railway Conductors;

Coupling and Uncoupling Air, Signal, and Steam Hose-employees represented by the Order of Railway Conductors;

More Than One Class of Road Service employees represented by all three organizations;

Switching Limits-employees represented by all three organizations;
Reporting for Duty-employees represented by all three organizations;

and if the parties cannot agree on the foregoing rules, the ecarriers are willing to submit them to arbitration as hereinafter provided.

The carriers are also willing to apply the report of Presidential Emergency Board No. 81 with respect to Restoration of Standard Wage Rates Between the Territories if the Order of Railway Conductors desires.

All other rules proposed by the parties are to be withdrawn.

The carriers are not willing to submit to arbitration the requests of the Order of Railway Conductors with respect to the 100-mile day in passenger service and graduated rates of pay based on the weight of the locomotive pulling the train.

AFFIDAVIT OF J. M. DONALDSON, POSTMASTER GENERAL OF THE UNITED STATES UNITED STATES OF AMERICA,

District of Columbia, ss:

J. M. Donaldson, being first duly sworn upon oath deposes and says: He is Postmaster General of the United States, and is charged by law with superintending generally the business of the Post Office Department and executing all laws relative to the Postal Service. In his official capacity he knows the functions of the railroads of the Nation in the carriage of the mails.

The New York Central Railroad Company and its subsidiaries, constituting the New York Central System, are post roads of the United States. The System operations extend over 10,735 miles of railroad within and between the States of New York, Pennsylvania, Ohio, Indiana, Illinois, Michigan, Massachusetts, Kentucky, Missouri, New Jersey, and West Virginia. The operations west of Buffalo, New York, constituting a major portion of the system, directly or indirectly physically connect and interchanges, among other traffics, United States mail with thirty (30) large or important railroads.

The New York Central System is strategically located in the heart of the industrial area of the United States, serving particularly in the movement of United States mail important local and transcontinental traffic. At the present time it handles the largest volume of mail of any railroad in the United States.

Terminal Railroad Association of St. Louis is a switching and belt-line railroad, serving all railroads entering St. Louis from the East, West, North, and South. It is strategically located in the heart of the United States, serving particularly in the movement of United States mail in transcontinental traffic. Failure of this switching and belt-line facility to function would virtually paralyze the movement of mail through St. Louis.

The business and commercial life of the Nation depends upon daily mail service, which in turn is dependent upon rail transportation. Many remote

communities look to mail service not only for communication in social and financial affairs but for food and other necessities. The defense of the United States is dependent upon uninterrupted transportation of the mails.

The strike on the New York Central System west of Buffalo, New York, and on the Terminal Railroad Association of St. Louis, has seriously disrupted the movement of mail. The stoppage of mail traffic over the railroads and facilities described herein has compelled the Post Office Department to suspend prearranged dispatches and to utilize circuitous routes, which in turn has overloaded postal facilities and caused serious delays to the mails, domestic and foreign. Continued stoppage of the movement of mail over the railroads and facilities described herein will result in incalcuable hardships and in damage to the interests of the Postal Service and the safety of the United States.

J. M. DONALDSON.
Postmaster General.

Subscribed and sworn to before me this 10th day of March 1952.

[SEAL]

My commission expires February 1, 1953.

CHARLOTTE B. STILLWELL, Notary Public, Washington, D. C.

EXHIBIT

AFFIDAVIT OF HOMER C. KING, ACTING ADMINISTRATOR, DEFENSE TRANSPORT ADMINISTRATION

UNITED STATES OF AMERICA,

District of Columbia, ss:

Homer C. King being first duly sworn on oath deposes and says:

He is the Acting Administrator of the Defense Transport Administration, and, as such, maintains his office in the City of Washington, District of Columbia. In his official capacity he is familiar with the domestic transportation facilities and services of the Nation and the Nation's needs therefor, and, in particular the needs of the Nation for railroad common carrier service. In his official capacity he is also familiar with the effects of cessations and inadequacies in rail transport services.

He is intimately connected and familiar with the national railroad transportation system and the supply of cars and equipment thereon, as well as the needs of the various sections of the country for railroad transportation. He also knows the absolute dependence of those sections on such transportation, including also the needs of the military services during defense mobilization and the present need of the military forces and civilian population in that respect.

A strike of conductors, locomotive engineers, and firemen on certain lines of the New York Central System and of the Terminal Railroad Association of St. Louis has been called by the Brotherhood of Locomotive Firemen and Enginemen, the Brotherhood of Locomotive Engineers, and the Order of Railway Conductors. Such strike is now in effect and rail service has been interrupted on the lines of the New York Central System west of Buffalo, New York, including the New York Central Railroad and certain lines of its subsidiaries, to wit: Michigan Central west of Detroit River, the Big Four, and the Toledo and Ohio Central. Rail service has been interrupted as a result of said strike on the lines of the Terminal Railroad Association of St. Louis and will result in the immediate and virtually complete stoppage of rail movements into, out of, and through St. Louis, Missouri. Service on railroads other than those mentioned having trackage rights over their lines is also affected.

The railroads directly affected by the strike constitute an important segment of the principal railroads which now provide common carrier freight and passenger service, including express and United States mail, within the United States, and it is apprehended that the strike will be extended to additional railroads. For continued operation all railroads are dependent upon the services of qualified and experienced conductors, locomotive engineers, and firemen. With the exception of a relatively few supervisory employees, railroads do not have in their employ, outside of the members of their labor unions, personnel qualified to operate their trains, nor can they during the period of any strike called by the said labor unions obtain the services of qualified conductors, locomotive engineers, and firemen, or have assurance

that members of other unions would perform the service. The volume of rail transportation service that can be provided by these railroads through the use of supervisory employees, as compared with the volume of rail transportation service they normally provide with the use of the members of the aforesaid and other labor unions, is estimated at less than one-half of one per cent. The transportation activities of the railroads of the United States which are not directly subject to said strike are so correlated with, and dependent for traffic interchange and equipment upon, the rail transportation provided by those railroads directly subject to the strike that cessation of rail service on the lines of the latter will result in a partial stoppage of rail service on the railroads not subject to the strike.

The railroads of the United States constitute the most important segment of the Nation's transport system. They handle approximately 60 percent of the intercity commercial freight and about 50 percent of all commercial intercity passenger traffic handled by all agencies of transport in the United States. Moreover, other forms of public transportation-air, highway, and waterare largely dependent upon railroad transportation for the fuel used in performing their services.

At the present time the rail carriers of the United States are engaged in transporting daily over their lines an average of approximately 1,286,772 passengers. The current average daily carloadings of revenue freight (based on a five-day loading week) total 151,125 carloads of all types of freight. Distributed among the various classes of freight handled, the average daily carloadings are follows:

as

Grain and grain products 10,608, livestock 1,614, coal 29,173, coke 3,202, forest products 8,833, ore 4,330, less-than-carload (merchandise) 15,395, and miscellaneous (including petroleum and petroleum products) 77,970.

The effect of the strike of the above-mentioned labor unions is and will be immediate, far-reaching and catastrophie. It will paralyze a substantial portion of the Nation's economy and will inflict upon the people of this country and its industries irreparable damage and injury. The situation will become increasingly difficult because of shortages of equipment, military activity, and the evergrowing expansion of the defense effort to meet the requirements of the present emergency.

We have faced many difficult transportation situations, but with the exception of such times as railroad operations have been interfered with by crippling strikes, they have met the demands for military and civilian transportation. The Nation has an insufficient supply of cars to meet the present national needs and has been experiencing difficulties with respect to the supply of cars. Under such conditions a railroad strike immediately interferes with the orderly flow of goods and commodities vital to the national economy and the manufacture and production of articles necessary in the procurement of military needs.

Without

The entire economy of the United States is geared to transportation. means of transportation raw materials cannot move to mills, refineries, or manufacturing and processing plants, and without means of transportation the products of the mills, refineries, and manufacturing and processing plants cannot move to consumers. In other words, this Nation can only produce and only consume that which its transport system is capable of moving.

It will not be possible for forms of transport, other than rail, to adequately serve the public need and welfare during the period of the rail strike in the area directly involved.

HOMER C. KING.

Subscribed and sworn to before me this 10th day of March 1952.
[SEAL]
(Signed) LILLIAN L. COOLEY,

My commission expires January 31, 1955.

Notary Public.

AFFIDAVIT

CITY OF WASHINGTON,

District of Columbia, ss:

Charles E. Wilson, being duly sworn, deposes and says as follows:

1. I am Director of Defense Mobilization, at the head of the Office of Defense Mobilization, established by Executive Order 10193 of December 16, 1950. Paragraph 2 of Executive Order 10193 provides as follows:

"2. The Director shall on behalf of the President direct, control, and coordinate all mobilization activities of the Executive Branch of the Government, including but not limited to production, procurement, manpower, stabilization, and transport activities."

I am making this affidavit on the basis of information obtained by the Office of Defense Mobilization and the agencies of the Executive Branch of the Government engaged in mobilization activities under my direction and control.

2. A strike of locomotive engineers, firemen, and conductors has been called and is now in effect on certain lines of the New York Central System and of the Terminal Railroad Association of St. Louis. Rail service has been interrupted on the lines of the New York Central System west of Buffalo and on the lines of the Terminal Railroad Association of St. Louis. The areas affected by this strike include portions of the States of Illinois, Indiana, Kentucky, Michigan, Missouri, New York, Ohio, Pennsylvania, and West Virginia. Interruption of service on the lines of the Terminal Railroad Association of St. Louis will result in a stoppage of rail movements into, out of, and through St. Louis, Missouri. Service on other railroads using trackage rights over these lines has also been curtailed. I am informed and believe that there is a grave possibility that the strike may be extended to other lines and to other railroads.

3. The Government has been using the powers granted by the Defense Production Act of 1950, as amended, and other statutes to increase production of military equipment for our Armed Forces in Korea and elsewhere overseas and in the United States and for aid to our allies and friendly nations having community of interest with the United States; to expand the basic resources and productive capacity of the United States; and otherwise to increase the military and economic strength of the Nation in order to promote peace and oppose acts of aggression. Between 10 and 15 percent of the annual total goods and services of the United States is being devoted to defense mobilization. The rail transportation system of the United States is vital to the execution of the mobilization program for increasing military production and expanding basic resources and industrial capacity, and to the national economy in general. Without rail transportation movement of raw materials to points of manufacture and processing and the movement of products to military, industrial, and other users cannot be maintained. Domestic railroads are the most important single form of transportation in the United States, handling approximately one-half of all intercity commercial freight and passenger traffic in the country.

4. The railroads affected by the strike are an important segment of the national rail transportation system of the United States. The operation of railroads not directly subject to the strike is so dependent upon the service of the railroads whose employees have struck that the stoppage of rail service on the lines of the latter is resulting and will result in impairment of service of other railroads.

5. Qualified and experienced employees of the types now engaged in the strike are essential to continued operation of the railroads involved. I am informed and believe that it will not be possible for substitute means of transportation to meet adequately the transportation requirements of the defense mobilization program and the national economy in the areas affected during this strike. 6. The strike is having and will have detrimental effects upon manufacturing and processing plants and other business enterprises engaged in defense and essential civilian production and service in the States served by the railroads involved in and affected by the strike.

7. On the basis of the above facts it is my opinion that the work stoppage now existing in the domestic rail transportation system is, because of its effect upon defense and civilian production, causing serious damage to the national economy. Continuation of the stoppage will do irreparable damage to the mobilization effort of the United States in that it will impair many programs which are vital to the national defense and security.

CHARLES E. WILSON.

Subscribed and sworn to before me this 10th day of March 1952.

My commission expires June 14, 1953.

MARTHA E. HELWEGE, Notary Public.

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