Supporting Statement for Extension of Generic Clearance for STB (to ROCIS)

2140-0019
August 2021

Supporting Statement for Paperwork Reduction Act Generic Information Collection
Submissions for
“Generic Clearance for the Collection of Qualitative Feedback on Agency Service
Delivery”
A. JUSTIFICATION
1. Circumstances Making the Collection of Information Necessary
Executive Order 12862 directed Federal agencies to provide service to the public that matches or
exceeds the best service available in the private sector. In order to work continuously to ensure
that our programs are effective and meet our customers’ needs, the Surface Transportation Board
(hereafter “the Agency”) seeks to obtain OMB approval of a generic clearance to collect
qualitative feedback on our service delivery. By qualitative feedback we mean information that
provides useful insights on perceptions and opinions, as opposed to statistical surveys that yield
quantitative results that can be generalized to the population of study.
This collection of information will enable the Agency to garner customer and stakeholder
feedback in an efficient, timely manner in accordance with our commitment to improving service
delivery. The information collected from our customers and stakeholders will help ensure that
users have an effective, efficient, and satisfying experience with the Agency’s programs. This
feedback will provide insights into customer or stakeholder perceptions, experiences, and
expectations; provide an early warning of issues about how the Board provides service to the
public; or focus attention on areas where communication, training or changes in operations might
improve delivery of products or services. These collections will allow for ongoing,
collaborative, and actionable communications between the Agency and its customers and
stakeholders. It will also allow feedback to contribute directly to the improvement of program
management.
2. Purpose and Use of the Information Collection
Improving agency programs requires ongoing assessment of service delivery, by which we mean
systematic review of the operation of a program compared to a set of explicit or implicit
standards, as a means of contributing to the continuous improvement of the program. The
Agency will collect, analyze, and interpret information gathered through this generic clearance to
identify strengths and weaknesses of current services and make improvements in service delivery
based on feedback. The solicitation of feedback will target areas such as: timeliness,
appropriateness, accuracy of information, courtesy, efficiency of service delivery, and resolution
of issues with service delivery. Responses will be assessed to plan and inform efforts to
improve or maintain the quality of service offered to the public.
The Agency will only submit a collection for approval under this generic clearance if it meets the
following conditions:

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Information gathered are used only internally for general service improvement and
program management purposes and are not to be released outside of the agency;
Information gathered are not used for the purpose of substantially informing
influential policy decisions;1
Information gathered will yield qualitative information; the collections will not be
designed or expected to yield statistically reliable results or used as though the results are
generalizable to the population of study;
The collections are voluntary;
The collections are low-burden for respondents (based on considerations of total burden
hours, total number of respondents, or burden-hours per respondent) and are low-cost for
both the respondents and the Federal Government;
The collections are non-controversial and do not raise issues of concern to other Federal
agencies;
Any collection is targeted to the solicitation of opinions from respondents who have
experience with the program or may have experience with the program in the near future;
and
With the exception of information needed to provide renumeration for participants of
focus groups and cognitive laboratory studies, personally identifiable information is
collected only to the extent necessary and is not retained.

If these conditions are not met, the Agency will seek clearance by submitting an
information collection request to OMB for approval through the normal PRA process.
To obtain approval for a collection that meets the conditions of this generic clearance, a
standardized form will be submitted to OMB along with supporting documentation (e.g., a copy
of the comment card). The submission will have automatic approval, unless OMB identifies
issues within 5 business days.
The types of collections that this generic clearance covers include, but are not limited to:
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Customer comment cards/complaint forms
Small discussion groups
Focus Groups of customers, potential customers, delivery partners, or other stakeholders
Cognitive laboratory studies, such as those used to refine questions or assess usability of
a website;
Qualitative customer satisfaction surveys (e.g., post-transaction surveys; opt-out web
surveys); and
In-person observation testing (e.g., website or software usability tests).

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As defined in OMB and agency Information Quality Guidelines, “influential” means
that “an agency can reasonably determine that dissemination of the information will have or does
have a clear and substantial impact on important public policies or important private sector
decisions.”
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The Agency’s PRA Officer will serve as a manager for this generic clearance and will conduct
an independent review of each information collection to ensure compliance with the terms of this
clearance prior to submitting each collection to OMB.
3. Consideration Given to Information Technology
If appropriate, the Agency will collect information electronically and/or use online collaboration
tools to reduce burdens.
4.

Duplication of Information
No similar data are gathered or maintained by the Agency or are available from other sources
known to the Agency.

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Reducing the Burden on Small Entities
Small business or other small entities may be involved in these efforts, but the Agency
will minimize the burden on them of information collections approved under this
clearance by sampling, asking for readily available information, and using short, easy-tocomplete information collection instruments.

6. Consequences of Not Conducting Collection
Without these types of feedback, the Agency might not have timely information to adjust its
services to meet customer needs.
7. Special Circumstances
There are no special circumstances. The information collected will be voluntary and will not be
used for statistical purposes.
8. Consultations with Persons Outside the Agency
In accordance with 5 C.F.R. § 1320.8(d), on June 24, 2021, a 60-day notice for public comment
was published in the Federal Register. No comments were received by the STB.
9. Payment or Gift
The Agency will not provide payment or other forms of remuneration to respondents of its
various forms of collecting feedback.
10. Confidentiality
If a confidentiality pledge is deemed useful and feasible, the Agency will only include a pledge
of confidentiality that is supported by authority established in statute or regulation, that is
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supported by disclosure and data security policies that are consistent with the pledge, and that
does not unnecessarily impede sharing of data with other agencies for compatible confidential
use. If the agency includes a pledge of confidentiality, it will include a citation for the statute or
regulation supporting the pledge.
11. Sensitive Nature
No questions will be asked that are of a personal or sensitive nature.
12. Burden of Information Collection
A variety of instruments and platforms may be used to collect information from respondents.
The annual burden hours requested (277) are based on the number of collections we expect to
conduct over the requested period for this clearance.

Estimated Annual Reporting Burden
Type of Collection

No. of
Respondents

Annual
Frequency per
Response

Hours per
Response

Focus Group

15

1

2

Comment Card/Brief
Survey

200

2

.17

Surveys

150

Total
Hours

30

67
2

.6

180

13. Costs to Respondents
No costs are anticipated.
14. Costs to Federal Government
The anticipated cost to the Federal Government is approximately $16,240.00 annually. These
costs are entirely attributable to staff hours to develop and print the collection instruments and to
review the feedback.
15. Reason for Change
Not applicable. Renewing without change.
16. Tabulation of Results, Schedule, Analysis Plans

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Feedback collected under this generic clearance provides useful information, but it does not yield
data that can be generalized to the overall population. Findings will be used for general service
improvement, but except in a context such as the Freedom of Information Act, will not be
published or otherwise released publicly.
Although the Agency does not intend to publish its findings, the Agency may receive requests to
release the information (e.g., congressional inquiry, Freedom of Information Act requests). The
Agency will disseminate the findings when appropriate, strictly following the Agency's
"Guidelines for Ensuring the Quality of Information Disseminated to the Public"
(https://www.stb.gov/stb/InformationQualityGuidelines.htm) and will include specific reference
to the limitation of the qualitative results discussed above.
17. Display of OMB Approval Date
We are requesting no exemption.
18. Exceptions to Certification for Paperwork Reduction Act Submissions
These activities comply with the requirements in 5 C.F.R. § 1320.9.

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