Supporting Statement - wageab - 2018 extension (to ROCIS)

2140-0004

September 2018

SUPPORTING STATEMENT –

QUARTERLY WAGE FORM A & B

A. Justification:

1. (a) Why the collection is necessary. 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). Under 49 U.S.C. § 11145, the Board may require regulated carriers to submit financial and statistical data and reports that the Board needs to carry out its mission. For each reporting railroad, the annual and quarterly Wage Forms A & B, which are required to be filed by Class I (large) railroads pursuant to 49 U.S.C. § 11145 and 49 C.F.R. pt. 1245, show the numbers of employees, service hours, and compensation by employee group (executive, professional, maintenance-of-way, maintenance-of-equipment, transportation (train and engineer), and transportation (other than train and engineer)). This information is collected on the same form (Wage Form A & B) in two phases: the Quarterly Report of Railroad Employees, Service, and Compensation; and the Annual Report of Railroad Employees, Service, and Compensation. The Board is requesting an extension without modification of this information collection, which will otherwise expire on October 31, 2018.

2. How the collection will be used. The Board uses information from this form to forecast labor costs, to measure the efficiency of the reporting railroads, and to evaluate proposed regulated transactions under 49 U.S.C. §§ 10902-03 and 11326 that may impact rail employees, such as mergers, acquisitions of control, purchases, and abandonments. Other federal agencies and industry groups, including the Railroad Retirement Board, Bureau of Labor Statistics, and Association of American Railroads, depend on the information contained in these reports to monitor railroad operations.

3. Extent of automated information collection. The railroads submit this report electronically in Excel spreadsheet format.

4. Identification of duplication. No other federal agency has economic regulatory authority over freight rail transportation. Because no other federal agency collects the information in this report, nor is this information available from any other source, no duplication of information. In most instances, the information sought is unique to each carrier.

5. Effects on small business. No small entities will be affected by the collection of this information. This reporting requirement applies only to Class I railroads, which have operating revenues in excess of $250 million (1991 dollars) (adjusted for inflation using 2017 data, the revenue threshold for a Class I rail carrier is $463,860,933). The Board has adopted an indexing methodology that will ensure that regulated carriers are classified based on real business expansion, rather than the effects of inflation.

6. Impact of less frequent collections. The agency collects the quarterly and annual reports primarily for public use. Collecting both the quarterly and annual reports provides more utility to those members of the public who are interested in specific quarterly data, as well as those who work only with annual data. Therefore, the utility of the data would be diminished if collected less frequently.

7. Special circumstances. No special circumstances apply to this collection.

8. Compliance with 5 C.F.R. § 1320.8. As required, the Board published a Federal Register notice on July 11, 2018, providing a 60-day comment period regarding this collection. 83 Fed. Reg. 32,180. No comments were received. As required, a Federal Register notice providing an additional 30-day comment period is being published simultaneously with this submission.

9. Payments or gifts to respondents. The Board does not provide any payment or gift to respondents.

10. Assurance of confidentiality. All information collected through this report is available to the public.

11. Justification for collection of sensitive information. This collection contains no information of a sensitive nature.

12. Estimation of burden hours for respondents. The following information pertains to the estimate of burden hours associated with this collection:

(1) Number of respondents: Seven

(2) Frequency of response: Quarterly and annually

(3) Annual hour burden per respondent: Based on information provided by the railroad industry, we estimate a per-respondent-railroad burden of not more than 16 hours, which includes the time needed to gather the information, edit, review, complete, and submit the quarterly and annual reports. It is estimated that each of the seven railroad respondents requires no more than 3 hours for each of the four quarterly reports, and no more than 4 hours for the annual report. The total annual burden hours on the industry is estimated to be not more than 112 hours.

13. Other costs to respondents: No non-hour costs for operation, maintenance, or purchase of services associated with this collection have been identified. This report is submitted to the agency electronically.

14. Estimated costs to the Board: We estimate that it takes 13 hours annually (analyst at $62.24 per hour, including benefits) to review the annual and quarterly filings, and one hour (Auditor at $90.57 per hour, including benefits) to post this report (Wage Statistics of Class I Railroads) on our website, resulting in a total annual cost of $899.69.

15. Changes in burden hours. This is an existing collection, which is being adjusted to update the burdens and costs based on industry information. Due to technology, the burden hours to file each report has decreased significantly, resulting in a decrease of the overall annual hourly burden.

16. Plans for tabulation and publication: These reports are submitted in the form of Excel spreadsheets and are posted on the Board’s website at http://www.stb.gov/stb/industry/econ_reports.html.

17. Display of expiration date for OMB approval. No exception is sought. The control number and expiration date for this collection appear on the form.

18. Exceptions to Certification Statement. Not applicable

B. Collections of Information Employing Statistical Methods:

Not applicable