supporting statement - Wage Form C - 8-9-2012fin

2140-0007
July 2012

SUPPORTING STATEMENT - WAGE FORM C

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). Class I railroads are required
to provide wage statistics pursuant to 49 U.S.C. § 11145. Amtrak also files this report. This
collection shows, for each reporting carrier, the average number of employees at mid-month in
the six job classification groups (executive, professional, maintenance-of-way, maintenance-ofequipment, transportation (train and engineer), and transportation (other than train and engineer))
that encompass all railroad employees. See 49 C.F.R. § 1246.
2. How the collection will be used. The information in this collection is used by the
Board to forecast labor costs and measure the efficiency of the reporting railroads. The
information also is used by the Board to evaluate proposed regulated transactions that may
impact rail employees, including mergers and consolidations, acquisitions of control, purchases,
and abandonments under 49 U.S.C. §§ 10902-03 and 11326. Other Federal agencies, including
the Railroad Retirement Board and the Bureau of Labor Statistics, as well as industry groups,
depend on this report for information regarding the regulated railroad industry.
3. Extent of automated information collection. No improved technology has been
identified by the Board to reduce the burden of these collections. For many years, the respondent
carriers have maintained this form in a computerized format. The railroads enter their data on the
computerized version of the form and submit a 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. No other Federal agency collects the information in the
Wage Form C report, 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. Effects on small business. No small entities will be affected by the collection of this
information. This report is applicable only to Amtrak and to the Class I railroads, which have
operating revenues in excess of $250 million (1991 dollars) adjusted for inflation. 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 Board cannot fulfill its statutory
responsibilities without monthly information on employment.
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, and is available on the Board’s website.
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: monthly
(3) Annual hour burden per respondent: Based on information provided by the
railroad industry, we estimate an annual per-respondent-railroad burden of not more than 15
hours, based on a per monthly report estimate of not more than 1.25 hours, which includes the
time needed to gather the information and edit, review, and complete the monthly employment
report. Based on this estimate, the eight Class I railroads require a total of not more than 120
hours to complete the monthly report.
13. No other costs to respondents: (a) Continuing this existing collection will impose no
start-up costs on respondents. (b) This report is submitted to the agency electronically. No nonhour costs for operation, maintenance, or purchase of services associated with this collection has
been identified.
14. Estimated costs to the Board: We estimate that it takes 24 hours (GS 13/1 at $52.90
salary, including benefits) annually to prepare a monthly compilation for our website and an

additional hour (GS 14/10 at $81.26, including benefits) to post the results on the website
resulting in a total annual cost to the government of $1,351.
15. Changes in burden hours. No change in burden hours is requested.
16. Plans for tabulation and publication: The monthly data is compiled, printed, and
prepared for PDF file to be 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