supporting statement - formstb54 - July 2012fin

2140-0011
July 2012

SUPPORTING STATEMENT - FORM STB-54

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). The collection in Form STB54Ccarrier annual reports of the number of cars loaded and cars terminated on the reporting
carrier’s lineCis required under 49 C.F.R. § 1247. Information reported in this form is entered
into the Uniform Rail Costing System (URCS), which is a cost-measurement methodology. The
Board is authorized to collect this information pursuant to 49 § U.S.C. 11145.
2. How the collection will be used. 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
URCS to analyze the information that it obtains through the annual railroad waybill sample,
pursuant to 49 U.S.C. §§ 721, 10707, 11144-45 and 49 C.F.R. § 1244, and in railroad
abandonment proceedings to measure off-branch costs (see 49 U.S.C. § 10904(a); 49 C.F.R. §
1152.32(n)). Additionally, many other Federal agencies and industry groups depend on Form
STB-54 for information regarding the number of cars loaded and terminated on the reporting
carrier’s line.
3. Extent of automated information collection. The Board facilitates timely filing by
permitting responders to fax or email as a pdf the required signed form. The Board has
considered electronic filing, but determined that because the data is maintained in different
electronic formats by different 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 this
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 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 annual information on the number of cars loaded and cars terminated on
the reporting carrier’s line.
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. There are no questions of a
sensitive nature with respect to the information collected.
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: 7.
(2) Frequency of response: Each Class I carrier is required to file the annual
STB-54 report.
(3) Annual hour burden per respondent: Based on information provided by the
railroad industry, it is estimated that it takes no more than 4 man-hours each time a report
is prepared. The total annual burden hours for all 7 respondents is estimated at no more
than 28 hours (7 (respondents) x 4 hours each). These estimates include the time needed
to gather the information and edit, review, type, and proofread the data.
13. Other costs to respondents: (a) Continuing this information collection will impose
no start-up costs on respondents. (b) No non-hour costs for the operation, maintenance, or
purchase of services associated with this collection have been identified. These forms are
submitted electronically.
14. Estimated costs to the Board: We estimate that it takes one hour (GS 13/1 hourly rate
with benefits of $52.90) to review each of the seven filings per year, five minutes (0.08 hours)
(GS 14/5 hourly rate with benefits of $70.84) to enter the data into URCS, and two hours (GS 14/10

hourly rate with benefits of $81.26) to post the reports on the website, resulting in a cost to the

Board of $539.
15. Changes in burden hours. No change in burden hours is requested.
16. Plans for tabulation and publication: Past reports are available upon request. Future
reports will be posted on the Board’s website.
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