ombformstb54

2140-0011
December 2008

SUPPORTING STATEMENT - FORM STB-54

A. Justification:
1. The Surface Transportation Board (Board) has broad statutory authority to provide
economic regulatory oversight of railroads, addressing such matters as rates, service, the
construction, acquisition and abandonment of rail lines, carrier mergers, and interchange of
traffic among carriers (49 U.S.C. 10101-11908). The collection in Form STB-54—carrier annual
reports of the number of cars loaded and cars terminated on the reporting carrier’s line—is
required under 49 CFR 1247. Information reported in this form is entered into the Uniform Rail
Costing System (URCS), which is a cost-measurement methodology. The Board is authorized to
collect this information pursuant to 49 U.S.C. 11145.
2. . URCS was developed by the Board pursuant to 49 U.S.C. 11161-62 and is used in
rail rate proceedings as a tool to calculate the variable costs of providing a particular rail service
in accordance with 49 U.S.C. 10707(d). The Board also uses URCS to analyze the information
that it obtains through the annual railroad waybill sample, pursuant to 49 U.S.C. 721, 10707,
11144-45 and 49 CFR 1244, and in railroad abandonment proceedings to measure off-branch
costs (see 49 U.S.C. 10904(a); 49 CFR 1152.32(n)). And many other Federal agencies and
industry groups, including the Department of Transportation and the Association of American
Railroads (AAR), depend on Form STB-54 for information regarding the number of cars loaded
and terminated on the reporting carrier’s line.
3. Generally, no improved technology has been identified by the Board to reduce the
burden of these collections. However, the Board does not prohibit the use of improved
technology where appropriate. For many years, the respondent carriers have maintained Form
STB-54 form in a computerized format. The railroads enter their data on the computerized
version of the form and submit the required signed hard copy to the Board. The Board facilitates
timely filing by permitting responders to fax or email the required data and then follow-up with
the hard copies. The Board has considered electronic filing, but determined that because the data
is maintained in a different format by each of the seven respondent carriers, electronic filing
would not be useful to the Board. In addition, any requirement for this report to be filed in a
specific format would necessarily impose a greater cost burden on the respondents.
4. No other Federal agency collects the information in this report, nor is this information
available from any other source. Therefore, there will be no duplication of information. In most
instances, the information sought is unique to each carrier.
5. No small entities will be affected by the collection of this information. This report is

applicable only to Class I railroads, which have operating revenues in excess of $250 million
(1991 dollars) adjusted for inflation. The Board has adopted an indexing methodology which
will insure that regulated carriers are classified based on real business expansion and not from the
effects of inflation.
6. The Board cannot fulfill its statutory responsibilities without annual information on
the number of cars loaded and cars terminated on the reporting carrier’s line.
7. No special circumstances described in question 7 apply to this collection.
8. The Board’s 60-day notice was published in the Federal Register on August 12, 2008.
See 73 FR 46977.
9. The Board does not provide any payment or gift to respondents.
10. All information collected through this report is available to the public.
11. There are no questions of a sensitive nature with respect to the information collected.
12. The following represents the estimates of hour burden of the collections of
information:
(1) Number of respondents: 7.
(2) Frequency of response: Each Class I carrier is required to file the annual
STB-54 report, which is due within 90 days after close of the year.
(3) Annual hour burden per respondent: Based on information provided by the
railroad industry during the 1990's, it is estimated that it takes no more than 4 man-hours
each time a report is prepared. The total annual burden hours for all 7 respondents is
estimated at no more than 28 hours (7 (respondents) x 4 hours each). These estimates
include the time needed to gather the information, edit, review, type and proofread the
data. It is likely that the time required to produce this report is overstated, given the
advances in computerized data collection and processing systems.
(4) Total estimate of annualized cost to respondents for the hour burdens for
collection of information: It is estimated that each of the 7 Class I railroad companies
requires an average of no more than four hours to prepare each report. Because this
collection involves data that respondents already compile to make internal business
decisions, this collection does not otherwise increase the respondent’s accounting burden.
The total industry cost is estimated at no more than $840 (7 (number of respondents) x 4
(hours to prepare one annual submission x $30/hour)).
13. Other costs to respondents: (a) These information collection requirements impose no
start-up costs on respondents. (b) We estimate that there are no costs for the operation,

maintenance, or purchase of services associated with these reporting requirements.
14. Estimated costs to the Board: We estimate that it takes 1.25 hours to review
each filing x 7 filings per year x $80 per hour (including staff time to review, as well as
overhead costs) resulting in a cost to the Board of $700.
15. Estimates in items 13 and 14 are unchanged. However it is possible that the
time required to produce this report is overstated, given the advances in computerized
data collection and processing systems.
16. Plans for tabulation and publication:
Past reports are available upon request. Future reports will be posted on the
Board’s website.
17. Not applicable.
18. Not applicable
B. Collections of Information Employing Statistical Methods: Not applicable