Supporting Statement - Form QCS - 2015extension

2140-0001
August 2015

SUPPORTING STATEMENT – ANNUAL AND QUARTERLY
FREIGHT COMMODITY STATISTICS, FORM QCS

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 the 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. 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 C.F.R. § 1248. The Board is
requesting an extension without modification of this information collection, which will otherwise
expire on August 31, 2015.

2. How the collection will be used. Information reported on Form QCS is entered into
the Uniform Rail Costing System (URCS), which is a cost measurement methodology. URCS,
which was developed by the Board pursuant to 49 U.S.C. §§ 11161-62, 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 uses variable costs, for example, to calculate
revenue-to-variable cost ratios to make threshold determinations about whether a rate complaint
can proceed. Specifically, 49 U.S.C. § 10709 now limits the Board’s jurisdiction over maximum
rates to those instances where the revenue-to-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 C.F.R. § 1152.32(n)). In addition, this information is essential for determining regional and
system costs. And many other federal agencies and industry groups depend on Form QCS for
information regarding the cost of the movement of goods by railroads.
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 2014 data, the
revenue threshold for a Class I rail carrier is $475,754,803). 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 QCS data is aggregated in the annual QCS
report. The agency uses the annual QCS data in its URCS calculations, while the quarterly data
is primarily for public consumption. Thus, less frequent collection would either diminish the
utility of the data for the agency or diminish the public availability of the quarterly information.
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 providing a 60-day comment period regarding this collection. No comments
were received.. 80 Fed. Reg. 32201 (June 5, 2015). 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: 7.
(2) Frequency of response: Each Class I carrier is required to file the quarterly
and annual QCS reports.
(3) Annual hour burden per respondent and total for all respondents: Based on
information provided by the railroad industry, it is estimated that it takes not more than 217 manhours each time a report is prepared. This estimate includes the time needed to gather the
information; edit, review, type, and proofread the data; and submit the form. It is estimated that
each of the seven Class I railroads requires not more than 1,085 hours to complete the four
quarterly reports and the one annual report. The total annual burden hours for all seven carrier

responds is, therefore, estimated at 7,595 hours.
13. Other costs to respondents: There are no non-hour start up costs associated with the
proposed modification to this collection. This report is sent to the agency electronically; so no
non-hour costs for operation, maintenance, or purchase of services associated with this collection
have been identified.
14. Estimated costs to the Board: We estimate that it takes two hours annually (GS 13/1
at $55.49 per hour, including benefits) to review these seven filings; five minutes (0.08 hours) (GS
14/9 at $83.05 per hour, including benefits) to enter the annual QCS report data (which is
provided in spreadsheet form by the Association of American Railroads) into URCS; and four
hours annually (Expert/Consultant at $68.37 per hour, including benefits) to post on the website,
resulting in a total annual cost of $391.
15. Changes in burden hours. No change in burden hours is requested. The Board is
requesting an extension without modification.
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.dot.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