EP 724-4 Supporting Statement 5-23-16

Supporting Statement for
Paperwork Reduction Act Submission
United States Rail Service Issues – Performance Data Reporting
The Surface Transportation Board (Board) seeks approval for its proposed revisions to
previously proposed information collections requiring the seven Class I (large) railroads to
publicly file various data reports pertaining to service performance, primarily on a weekly basis.
This data is intended to give both the Board and its stakeholders access to near real-time
information about the operations and performance of the Class I railroads, and the fluidity of the
Chicago gateway. In addition, the data is expected to assist rail shippers in making logistics
decisions, planning operations and production, and mitigating losses when challenging railroad
operating issues arise. This data will be published on the Board’s website for the benefit of the
Board, carriers, shippers, and the general public.
A. Justification
1. Need for Information
The Board is, by statute, responsible for the economic regulation of common carrier
railroads operating in the United States. The shipping community and our economy as a whole
depend on reliable and efficient freight rail service. The proposed information collections would
allow the Board to better understand current service issues and potentially to identify and resolve
possible future regional and national service disruptions more quickly, as well as determine
whether more granular data is needed. Transparency would also benefit rail shippers and
stakeholders, by allowing them to better plan operations and make informed business decisions
based on publicly-available, near real-time data and their own analysis of performance trends
over time.
2. Use of Data Collected
The Board will use this information to monitor Class I railroad performance, identify and assess
service issues as they arise, and, when necessary, address issues as quickly and efficiently as
possible.
3. Reduction through Improved Technology
Respondents will email their responses to the Board.
4. Identification of Duplication
The Board is the only agency tasked with the economic regulation of freight railroads.
This information is not duplicated by any other agency.

5. Minimizing Burden for Small Businesses
No small entities will be affected by the collection of this information. Only Class I
railroads, which have operating revenues in excess of $250 million (1991 dollars) adjusted for
inflation, will be subject to this reporting requirement.
6. Frequency Reduction Consequences
Less frequent collections would fail to provide as near real-time information about rail
service issues and thus would hinder the Board’s ability to address these issues. It would also
provide less insight into variations in performance. The purpose of the collections is to obtain
more frequent data on freight rail service.
7. Special Circumstances
No special circumstances apply to these collections.
8. Consultation Outside Agency
The Board published in the Federal Register a Notice of Proposed Rulemaking on
January 6, 2015, which provided for an approximately 60-day comment period (and an
additional approximately 60-day period for reply comments) regarding proposed collections of
similar data, with specific reference to concerns detailed in the Paperwork Reduction Act,
44 U.S.C. §§ 3501-3521 and Office of Management and Budget regulations at 5 C.F.R. §
1320.8(d)(3). See U.S. Rail Serv. Issues—Performance Data Reporting, EP 724 (Sub-No. 4),
80 Fed. Reg. 473 (Jan. 6, 2015). In response to comments received, the Board has revised its
proposal and is now publishing in the Federal Register a revised Notice of Proposed Rule
Making, which provides for an approximately 60-day comment period (and an additional
approximately 60-day period for reply comments) regarding its revised proposal for this data
collection. See U.S. Rail Serv. Issues—Performance Data Reporting, EP 724 (Sub-No. 4),
81 Fed. Reg. 32268 (May 23, 2016).
9. Payment or Gift
No payment or gift is made in connection with these collections.
10. Assurance of Confidentiality
The collections are posted on the Board’s website.
11. Sensitive Information
The collections do not collect sensitive information.
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12. Estimated Burden Hours.
The recurring burden hours are estimated to be no more than 1,182 hours per year, as
derived in the table below. In addition, there are some one-time, start-up costs of approximately
2 hours for each respondent filing a quarterly report that must be added to the first year’s total
burden hours. To avoid inflating the estimated total annual hourly burden, the two-hour start-up
burden has been divided by three and spread over the three-year approval period. Thus, the total
annual burden hours for each of the three years are estimated at no more than 1,186.67 hours per
year.
Table – Total Burden Hours (per Year)
Type of Responses
Weekly
Semiannually
On occasion
Total

Number of
Respondents
7
7
2

Estimated Time
per Response
3 hours
3 hours
3 hours

Frequency of
Responses
52/year
2/year
1/year

Total Yearly
Burden Hours
1,092 hours
42 hours
6 hours
1,140 hours

13. Non-hourly Costs to Respondents
There are no non-hourly burdens for respondents. The data will be submitted
electronically by email.
14. Annualized Cost to the Federal Government
We estimate a total annual cost to the Board of $65,391.02. This amount is calculated
using the weekly costs set forth in the table below and then annualizing them ($1,257.52 X 52 =
$65,391.02).
Position

Type of Work

Grade
Level

Transportation
Industry Analyst
Section Chief

Review of Weekly Data Submission

GS 13-5

Supervisory Review of Weekly Data
Submission
Processing Weekly Data and
Developing Output
Posting Weekly Submissions to
Board Website

GS 14-5

$76.99

4

$307.96

GS 14-5

$76.99

4

$307.96

ED

$70.05

2.5

$175.13

Data Manager
Web Content
Developer

Hourly
# of
Weekly
Rate
Hours Cost
(with
Benefits)
$65.15
8
$521.20

Total

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$1,312.25

15. Changes in Burden Hours.
Change due to new collection.
16. Publication of Data and/or Results
The collected data will be posted on the Board’s website.
17. Display of Expiration date for OMB approval
There is no form on which to display the expiration date, but the date will be published in
the Federal Register once OMB approves the collection.
18. Exceptions to the Certification for Paperwork Reduction Act Submissions
No exceptions are sought.
B. Collection of Information Employing Statistical Methods
Not Applicable. None of the collections involve statistical methods.

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