PRA-2126-0033 SS Renewal.061609-FORM QFR-USE2.ew.hd1

Department of Transportation

Office of the Chief Information Officer

SUPPORTING STATEMENT

Quarterly Report of Class I Motor Carriers of

Property

(Formerly OMB Control Number 2139-0002)

Introduction: The Federal Motor Carrier Safety Administration (FMCSA) submits to the Office of Management and Budget (OMB) its request to revise a currently-approved information collection request (ICR) titled, “Quarterly Report of Class I Motor Carriers of Property,”(including Household Goods Carriers) covered by OMB Control Number 2126-0033. This ICR is due to expire on June 30, 2009.

Part A. Justification.

1. Circumstances that Make the Collection of Information Necessary

Section 103 of the ICC Termination Act of 1995 (ICCTA), Public Law 104-88, 109 Stat. 803, 852 (Dec. 29, 1995) (See Attachment A), now codified at 49 United States Code (U.S.C.) § 14123 (See Attachment B), transferred to the Secretary of Transportation (Secretary) the responsibility to require Class I and Class II motor carriers to file annual financial and safety reports that include balance sheets and income statements. Under section 14123, the Secretary may also require motor carriers, freight forwarders, brokers, lessors, and associations, or classes of them, to file quarterly, periodic, or special reports with the Secretary and respond to surveys concerning their operations. This ICR applies only to Class I motor carriers of property and household goods carriers. The ICR for passenger carriers is located under OMB Control 2126-0031.

Initially, the Secretary transferred this reporting authority to administer the Financial and Operating Statistics (F&OS) program to the former Bureau of Transportation Statistics (BTS) on September 30, 1998 (63 FR 52192) (See Attachment C). Pursuant to this authority, the BTS, now part of the Research and Innovative Technology Administration (RITA), became the responsible DOT modal administration for implementing the F&OS program and requirements set forth in part 1420, title 49 of the CFR (See Attachment D). On September 29, 2004, the Secretary transferred the responsibility for the F&OS program from BTS, to FMCSA (69 FR 51009) (See Attachment E). On August 10, 2006 DOT published a final rule (71 FR 45740) (See Attachment F) that transferred and redesignated certain motor carrier financial and statistical reporting regulations of BTS, that were formerly located at chapter XI, title 49 CFR part 1420, to FMCSA under chapter III of title 49 CFR part 369 (Attachment G).

FMCSA is requesting OMB’s approval to renew this IC so the quarterly report (Form QFR) and other data collection instruments may be used by motor carriers of property and household goods to report their quarterly financial and operating data (See 49 CFR 369.1(b)).

This IC supports the Department of Transportation’s strategic goal of safety.

2. How, by Whom, and for What Purpose is the Information Used

The quarterly report (Form QFR) will be used to collect financial, operating, equipment and employment data from individual motor carriers of property and household goods. All for-hire (common and contract) motor carriers of property having $10 million or more in gross annual operating revenue must file Quarterly Reports (Form QFR).

FMCSA makes the data available to users in various forms, e.g., tables, graphs, photocopies, raw data, etc. The data are used by the USDOT, trucking associations, insurance companies, consultants, law firms, academia, trade publications, and others to track the performance of the trucking industry and subgroups within it. The information is valuable in analyzing various aspects of the motor carrier industry, such as, productivity and its role in the economy. The data is also used by public and private entities to review the financial status of Class I motor carriers and evaluate any aggregate relationship between their financial conditions and safety performance.

The Bureau of Economic Analysis (BEA) uses the data to help develop the national annual input-output accounts and GDP estimates. The BEA uses the data to prepare estimates of industry output and provide details on inputs to supplement the information on motor carriers collected by the Bureau of the Census.¹ The DOT uses the information for special studies of the motor carrier industry. Other Federal agencies, such as the Department of Defense’s Military Traffic Management Command use the data to assess potential carriers for shipping military goods while the General Services Administration uses it to set rates. The insurance industry uses the data as part of their underwriting operations. Trucking companies regularly use the data to benchmark their performance to strive for continuous improvement and efficiency. Other users include the International Brotherhood of Teamsters, shippers, investment and industry analyst, and data vendors. The FMCSA has worked closely with BEA and others in designing the data collection instruments to ensure they meet the needs of the Federal, public and private entities noted above.

3. Extend of Automated Information Collection

Information relative to collection of the data and the necessary forms are available on FMCSA’s website, http://www.fmcsa.dot.gov/forms/reporting/mcs_info.htm#fos. The forms can be printed and mailed to FMCSA. FMCSA anticipates that thirty percent (30%) of the Form QFR information will be submitted to the agency electronically.

4. Effort to Identify Duplication

The Bureau of the Census, through its Services Annual Survey, provides similar statistical data for the transportation industry. However, the Census Bureau does not collect the information as does the FMCSA. The Bureau is prohibited under law from providing data about individual carriers available to the public. Further, some Federal agencies, such as, Department of Defense (DoD) and General Service Administration (GSA), and private entities have requested continued public access to carrier-level data that would enable monitoring financial and operating measures of particular carriers.

5. Efforts to Minimize the Burden on Small Businesses

For motor carriers of property, the Small Business Administration (SBA) defines small trucking businesses as those with annual revenues or receipts up to $23.5 million. Approximately 67 companies that file Form QFR would be considered small businesses under SBA guidelines. The Agency estimates that about 155,000 for-hire property carriers operate in the United States and that over 100,000 of them would be considered small businesses. The 67 small businesses that file Form QFR represent a minor fraction of this total.

Form QFR was reduced to two pages in 1999, which reduced burden hours for all carriers.

6. Impact of Less Frequent Collection of Information

As referenced in number 4 above, the FMCSA is aware of the following users: The Bureau of Economic Analysis (BEA), the DOD Military Traffic Management Command and the General Services Administration. Specifically, BEA uses ton and ton-mile information estimating the Producer Price Index for transportation and uses carrier revenue and expense information to estimate trucking industry profits. For the latter, BEA needs quarterly financial data to prepare its quarterly Gross Domestic Product (GDP) estimates.

7. Special Circumstances

There are no special circumstances.

8. Compliance with 4 CFR 1320.8

On April 08, 2009, FMCSA published a notice in the Federal Register (74 FR 16037)(See Attachments H) with a 60-day comment period announcing its intentions to seek OMB review and approval to extend this ICR. FMCSA received no comments to the above notice.

On June 16, 2009, FMCSA published a second notice in the Federal Register (74 FR 28587)(See Attachment I) with a 30-day comment period that announced this information collection will be submitted to OMB for approval.

9. Payments or Gifts to Respondents

There are no payments or gifts to respondents.

10. Assurance of Confidentiality:

Currently all data are made available at the respondent level. Our regulations at 49 CFR Part 369 allow a motor carrier to request an exemption from filing (369.8) and that its financial reporting data and reports be kept confidential (369.9). The decision to grant the exemption is based on whether the motor carrier meets the criteria established within those regulations.

11. Justification for Collection of Sensitive Information

The forms do not include any questions of a sensitive nature.

12. Estimate of Burden Hours for Information Requested

Class I motor carriers of property are required to file Form QFR. Class I carriers are those with more than $10 million in operating revenue. Revenue is adjusted to account for inflation since the $10 million threshold was implemented in 1994. Currently, 120 carriers submit this report. The data for completing reports are available from carrier records. FMCSA estimates that each carrier will spend an average of 27 minutes completing Form QFR. Responses to this form are submitted quarterly, and the total annual burden per respondent is 1.8 hours. Total annual burden for all 120 respondents is 206 hours.

FMCSA estimates that the total annual hour burden associated with this information collection is 1,800 hours. A breakout of this burden is provided below:

Title	Number of Respondents	Frequency of Responses	Estimated Time per Response	Total Annual Burden Hours
Quarterly Report of Class I Motor Carriers of Property (including Household Goods Carriers)	120	Quarterly	1.8 hours (27 Minutes x 4 quarters/60 minutes)	216

Estimated Annual Number of Respondents: 120 Class I motor carriers of property and household goods carriers.

Estimated Annual Number of Responses: 480 [120 Class I motor carriers of property and household goods x 4 quarterly reports = 480].

Estimated Annual Burden Hours: 216 hours [120 respondents x 1.8 hours per response = 216].

13. Estimate of Total Annual Cost to Respondents

The estimated total annual cost to respondents is $9,044, which includes costs of employee time and those associated with printing and mailing forms. The Agency, having not received supporting data as to the magnitude of the burden costs on carriers, based its estimates on data from the Bureau of Labor Statistics (BLS). BLS data indicate that the median hourly wage for accountants working for passenger carriers is $24.59.² To this, fringe benefit costs equal to 49.25 percent of wages³ and overhead costs equal to 12 percent of wages⁴ were added, resulting in a total hourly compensation of $39.65. This hourly cost is multiplied by the 216-hour annual burden estimate to yield the total cost of $8,564 for employee time. Printing and mailing Form QFR estimated to cost $1 per form, $480 (120 respondents multiplied by 4 responses per year) in total per year for all respondents.

Estimated Annual Cost to Respondents: $9,044 [($39.65 cost per hour wage x 216 annual hours) + ($1.00 printing and mailing cost per form x 120 forms x 4 times per year) = $9,044].

14. Estimate of Cost to the Federal Government

The combined estimated annual cost to the government is $11,000 for Form M and QFR. This figure includes salary cost based on hours, overhead, printing and payment to contractors. FMCSA estimates that about $2,700 of that combined cost is attributable to Form QFR.

Estimate of Annual Cost to Federal Government: $2.700.

15. Explanation of Program Changes or Adjustments

The program adjustment to the annual burden estimates for this ICR are due to the number of respondents decreasing from 1,000 to 120.

The method of estimating costs to respondents was also revised. Wages used to assess the cost of employee time devoted to entering data in Form QFR changed from $25.00 to $24.59 per hour. The adjustment to hourly compensation for fringe benefits was revised from 45 percent of wages to 49.25 percent, and a second adjustment equal to 12 percent of wages was added to account for overhead. Last, costs to carriers associated with printing and mailing forms to FMCSA have been included for the first time.

16. Publication of Results of Data Collection

It is required by Federal law to make the data collection information publicly available. There are no plans at this time to publish analytical reports.

17. Approval for not Displaying the Exemption Date of OMB Approval

The FMCSA is not seeking approval to not display the expiration date of the OMB approval number.

18. Exceptions to Certification Statement

None.

Part B. Collection of Information Employing Statistical Methods

This information collection does not employ statistical methods.

Attachments

A. Section 103 of the ICC Termination Act of 1995 (ICCTA) Public Law 104-88, 109 Stat. 803, 852 (Dec. 29, 1995).

B. Section 14123, Title 49, U.S.C.

C. DOT Secretary’s transfer of the authority to administer the F&OS program to the Bureau of Transportation Statistics on September 30, 1998 (63 FR 52192).

D. Part 1420, Title 49 of the CFR.

E. DOT Secretary’s transfer of the Responsibility for the F&OS program from BTS, to FMCSA on August 17, 2004 (69 FR 51009).

F. Motor Carrier Transportation; Redesignation of Regulations From the Research and Innovative Technology Administration, Final Rule (71 FR 45740), August 10, 2006.

G. Title 49 CFR part 369.

H. Federal Register Notice requesting 60-day comment period (74 FR 16037), April 08, 2009.

I. Federal Register Notice requesting 30-day comment period, (74 FR 28587), June 16, 2009.

Form QFR

1 The United States Census Bureau (officially the “Bureau of the Census,” as defined in title 13 U.S.C.

§ 11), is the government agency that is responsible for the United States Census. It also gathers other national demographic and economic data. The Bureau of the Census is part of the United States Department of Commerce.

2 Bureau of Labor Statistics, “Occupational Employment Survey.” May 2007. http://www.bls.gov/oes/current/naics4_484000.htm (accessed November 23, 2008). North American Industry Classification System (NAICS) 484000, Truck Transportation, Standard Occupational Classification (SOC) 13-2011, Accountants and Auditors.

3 Bureau of Labor Statistics, “Employer Costs for Employee Compensation”. June 2008. http://stats.bls.gov/news.release/archives/ecec_09102008.pdf (accessed November 23, 2008). As indicated in Table 2 of this report, for “transportation and material moving occupations,” 67 percent of total employee compensation is wages, and 33 percent is benefits. The ratio of benefits to wages is 33/67=49.25 percent.

4 Overhead is difficult to estimate, and few industrial-level estimates are available. The Agency relied on guidance from the Office of Management and Budget (OMB) for evaluating and budgeting commercial services. OMB Circular A-76, http://www.whitehouse.gov/omb/circulars/a076/a76_incl_tech_correction.html (accessed November 23, 2008).

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