ombqcs

2140-0001
December 2008

SUPPORTING STATEMENT - FORM QCS

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, and the
construction, acquisition and abandonment of rail lines, as well as carrier mergers and the
interchange of traffic among carriers (49 U.S.C. 10101-11908). The collection in Form QCS,
which is based on information contained in waybills used by railroads in the ordinary course of
business, reports car loadings and total revenues by commodity code for each commodity that
moved on the railroad during the reporting period. See 49 CFR 1248. The Board has authority
to collect this information pursuant to 49 U.S.C. 11145.
2. Information reported on Form QCS is entered into the Uniform Rail Costing System
(URCS), which is a cost measurement methodology. 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 revenue-to-cost (variable cost) ratios to make particular jurisdictional
determinations. Specifically, 49 U.S.C. 10709 now limits the Board’s jurisdiction over
maximum rates to those instances where the revenue-variable cost ratio exceeds a specific
percentage.
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 and 11144-45, as well as in railroad
abandonment proceedings to measure “off-branch costs” (see 49 U.S.C. 10904(a); 49 CFR
1152.32(n)). In addition, this information is essential for determining regional and system costs.
And many other Federal agencies and industry groups, including the Department of
Transportation and the Association of American Railroads (AAR), depend on Form QCS for
information regarding the cost of the movement of goods by railroads.
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
QCS 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 reported on Form QCS, 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 quarterly and annual
information on car loadings and total revenues by commodity code for each commodity that
moved on the railroad during the reporting period.
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 quarterly
and annual QCS report. Quarterly reports are due within 60 days after close of the quarter, and
annual reports are due 90 days after the 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 217 man-hours each time a report
is prepared. This estimate includes the time needed to gather the information, edit, review, type
and proofread the data. It is estimated that each of the seven Class I railroads requires 1,085
hours to complete the four quarterly and one annual report. The total annual burden hours for all
seven carrier responds is, therefore, estimated at 7,595 hours. It is likely that the time required to
produce these reports 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 seven Class I railroad companies

requires an average of no more than 217 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 for this report is estimated at not more than $227,850 (7 (number of respondents) x 1,085
(hours to prepare four quarterly and one annual submission) x $30/hour (average cost per 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 to respondents for
operations, maintenance and purchase of services attributable to this reporting requirement.
14. Estimated costs to the Board: We estimate that it takes 3.75 hours to review each
filing x 35 filings per year x $80 per hour (including staff time to review, as well as overhead
costs), resulting in a cost of $10,500.
15. Estimates in items 13 and 14 are unchanged. However, it is likely that the time
required to produce these reports is overstated, given the advances in computerized data
collection and processing systems.
16. This report is not published.
17. Not applicable.
18. Not applicable
B. Collections of Information Employing Statistical Methods:
Not applicable