2140-0033 Supporting Statement -- Performance Data (to ROCIS)

2140-0033
November 2020
Expires 12/31/2020

SUPPORTING STATEMENT
FOR REQUEST OF OMB APPROVAL
UNDER THE PAPERWORK REDUCTION ACT AND 5 C.F.R. § 1320
The Surface Transportation Board (STB or Board) requests a three-year extension of
approval for the Board’s collection in Rail Service Data (OMB Control Number 2140-0033).
A. Justification:
1. Why the collection is necessary. By statute, the Board is responsible for economic
regulation of common carrier railroads operating in the United States. The shipping public and
the Nation’s economy as a whole depend upon reliable, consistent, and efficient freight rail
service. In 2016, the Board adopted regulations requiring all Class I carriers and the Chicago
Transportation Coordination Office (CTCO), through its Class I members, to report certain
service performance metrics on a periodic basis. U.S. Rail Service Issues—Performance Data
Reporting, EP 724 (Sub-No. 4) (STB served Nov. 30, 2016). Under these regulations, 49 C.F.R.
Part 1250, the Board requires railroads to provide a set of performance data that allows the Board
to monitor current service conditions in the industry and improve the agency’s ability to identify
and help resolve future regional or national service disruptions more quickly, should they occur.
Specifically, they require railroads to report certain railroad service performance metrics on a
weekly basis and certain other information on a semiannual and occasional basis, as outlined
below:
i.

Weekly Reporting. The collection of rail service performance data on a weekly basis
allows the Board to monitor rail service in near real-time, to detect emerging service
problems, and to work proactively with industry to mitigate service issues before they
grow into severe regional or national crises. The collection of weekly data from each
Class I railroad and the CTCO allows the Board to quickly identify aberrations from
service norms, such as a sudden spike in the number of trains holding at origin, which
typically indicate problems affecting vital industries. Weekly data allow the Board to
establish long-term trends, tracking improvement or decline in a given railroad’s
service over time. Additionally, the weekly data allow rail shippers and other
interested stakeholders, including Federal agencies and Congress, to monitor rail
performance. The publicly reported data is useful to rail shippers in making
operational and logistics decisions.

ii.

Semiannual Reporting. The semiannual reporting requires railroads to report on
major rail infrastructure projects on March 1 of each year, followed by a six-month
update. Railroads are instructed to report in narrative fashion, briefly describing each
project and its purpose and location. Reporting of this information facilitates the

Board’s awareness of significant network investments by Class I carriers, and its
ability to monitor rail service at these locations.
iii.

Occasional Reporting. The occasional reporting requires Class I railroads (through
CTCO) to report to the Board instances when the “Alert Level” for the Chicago
gateway is changed. “Alert Levels,” which were established through the cooperation
of railroads serving the Chicago gateway, require railroads to implement operational
contingency measures to proactively counteract congestion, such as by diverting
trains to alternate interchanges. Reporting this information on an occasional basis
enhances the Board’s visibility into the status of a critical component of the nation’s
rail network.

2. Use of Data Collected. The Board will use this information to monitor Class I railroad
performance, identify and assess service issues as they arise, and, when necessary, address issues
as quickly and efficiently as possible.
3. Reduction through Improved Technology. Respondents will email their responses to
the Board.
4. Identification of duplication. The Board is the only agency tasked with economic
regulation of freight railroads. This information is not duplicated by any other agency.
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, under the
Board’s regulations, have annual carrier operating revenues of $250 million or more in 1991
dollars (the revenue threshold for a Class I rail carrier is $489,935,956 when adjusted for
inflation using 2018 data). The Board has adopted an indexing methodology to ensure that
regulated carriers are classified based on real business expansion, rather than the effects of
inflation.
6. Consequences if collection not conducted or conducted less frequently. Less frequent
collection would fail to provide as near real-time information about rail service issues and thus
would hinder the Board’s ability to address these issues in a manner timely enough to make a
difference. Less frequent collection would also deprive the Board of insight into variations in
performance, so that potential problems may be addressed. Indeed, the entire purpose of this
collection is to obtain more frequent data on freight rail service, data that is collected in a manner
that is consistent with the respondent railroad’s current operations. (In fact, some respondents, if
not all of them, could provide the data daily without significant burden.)
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 notice
providing a 60-day comment period regarding this collection. See 85 Fed. Reg. 54614 (Sept. 2,
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2020). No comments were received. A 30-day notice was published concurrently with this
submission to Office of Management and Budget (OMB). 85 Fed. Reg. 69675 (November 3,
2020).
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. No sensitive information of a
personal nature is requested.
12. Estimated burden hours. The following information pertains to the estimate of
burden hours associated with this collection:
Number of Respondents: Seven
Estimated Time per Response: The collection seeks three related responses, as indicated
in the table below.
Table – Estimated Time per Response
Type of Responses
Estimated Time per
Response
Weekly
1.5 hours
Quarterly
1.5 hours
On occasion
1.5 hours

Frequency: The frequencies of the three related collections are set forth in the table
below.
Table – Frequency of Responses
Type of Responses
Weekly
Quarterly
On occasion

Frequency of Responses
52/year
4/year
2/year

Total Burden Hours (annually including all respondents): The recurring burden hours are
estimated to be no more than 591 hours per year, as derived in the table below.
Table – Total Burden Hours (per Year)
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Type of
Responses

Number of
Estimated
Respondents Time per
Response

Frequency
of
Responses

Weekly

7

1.5 hours

52/year

Quarterly
On occasion
Total

7
1

1.5 hours
1.5 hours

4/year
2/year

Total
Yearly
Burden
Hours
546 hours
42 hours
3 hours
591 hours

13. Estimated total annual cost to respondents. There are no non-hourly burdens for
respondents. The data will be submitted electronically by email.
14. Estimated costs to the Board: Board staff spends time gathering, processing, and
evaluating the collection of rail service performance data letters from seven Class I railroads.
The estimated cost to the Board is approximately 0.25 FTEs as “processing” time for the service
performance data, including receipt, review/quality control, troubleshooting, and posting.
15. Changes in burden hours. This is an existing collection with an OMB control
number (2140-0033). The only adjustment is to exclude the one-time hourly burden that was
added in the Board’s previous modification request to include chemical and plastics traffic as a
distinct reporting category for the “cars-held” metric to this collection. That additional traffic
category has been integrated into this collection, so the one-time burden will not be included in
this extension request.
16. Plans for tabulation and publication. The collected data will be posted on the
Board’s website.
17. Display of expiration date for OMB approval. The control number and expiration
date for this collection will appear on the form.
18. Exceptions to certification statement. No exceptions are sought.

B. Collections of Information Employing Statistical Methods:
Not applicable.

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