Supporting Statement - wagea&b - 8-9- 2012

2140-0004
July 2012

SUPPORTING STATEMENT - WAGE FORM A & B

A. Justification:
1. 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). For each reporting railroad,
the annual and quarterly Wage Forms A & B, which are required to be filed by Class 1 railroads
pursuant to 49 U.S.C. § 11145 and 49 C.F.R. § 1245, show the number 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 and the Annual Report of Railroad
Employees.
2. How the collection will be used. Information from this form is used by the Board 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:
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. Generally, no improved technology has
been identified by the Board to reduce the burden of these collections. For many years, the
respondent carriers have each maintained this form in a computerized format. Each railroad
enters its data on its own computerized version of the form and submits a fax or emailed pdf of
the required signed form to the Board. The Board facilitates timely filing by permitting
responders to fax or email the required data. The Board has considered electronic filing, but
determined that because the data is maintained in different electronic formats by the respondent
carriers, electronic filing would not be useful to the Board. In addition, any requirement for this
report to be filed in a specific electronic format would necessarily impose a greater cost burden
on the respondents.
4. Identification of duplication. The Board is the primary Federal agency having
jurisdiction over the railroad industry and its holding companies. No other Federal agency
collects the information in this report, and there will be no duplication of information.

5. Effects on small business. No small entities will be affected by the collection of this
information. This reporting requirement applies only to Amtrak and 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 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 consumption. 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 described in question 7 apply to this
collection.
8. Compliance with 5 C.F.R. § 1320.8. The Board published a notice in the Federal
Register, providing a 60-day comments period regarding this collection. See 77 Fed. Reg. 212901 (Jan. 13, 2012). No comments were submitted. As required, the Board has published a notice
providing a 30-day comment period, with comments to be sent to OMB. See 77 Fed. Reg.
27540.
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: 8.
(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 160 hours,
which includes the time needed to gather the information, edit, review, complete, and submit the
quarterly and annual report. It is estimated that each of the eight railroad respondents requires no
more than 30 hours for each of the four quarterly reports and no more than 40 hours for the
annual report. The total annual burden hours on the industry is estimated to be not more than
1280 hours.

13. Other costs to respondents: (a) Continuing this existing information collection will
impose no start-up costs on respondents. (b) No non-hour costs for the operation, maintenance,
or purchase of service associated with this collection have been identified. These forms are
submitted electronically.
14. Estimated costs to the Board: We estimate that it takes three hours annually to
compile (GS 13/1 hourly rate with benefits of $52.90) and one hour post (GS 14/10 hourly rate with
benefits of $81.26) this report (Wage Statistics of Class I Railroads) on our website, resulting in a
cost of $240.
15. Changes in burden hours. No change in burden hours is requested.
16. Plans for tabulation and publication: The Board prepares the Annual Compilation of
Wage Statistics of Class 1 Railroads, which is published on the Board=s website,
www.stb.dot.gov.
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