Meeting Summary_FRA and AAR

U.S. Department of Transportation
Federal Railroad Administration

MEETING ON FRA RAILROAD LOCOMOTIVE SAFETY STANDARDS AND EVENT
RECORDER OMB #2130-0004, DOCKET NO. FRA-2021-0006
Attendees (via teleconference):
Brenda Moscoso, Assistant Vice President, Safety Policy and Analysis, Association of American
Railroads
Joseph St. Peter, Counsel, Association of American Railroads
Steve Clay, Railroad Safety Specialist, Office of Railroad Safety, Federal Railroad
Administration
Mark Fuller, Staff Director, Office of Railroad Safety, Federal Railroad Administration
Amanda Maizel, Attorney Adviser, Office of Chief Counsel, Federal Railroad Administration
Hodan Wells, Industry Economist, Office of Railroad Safety, Federal Railroad Administration
Summary:
On October 14, 2021, at 9:00 AM ET, Ms. Moscoso and Mr. St. Peter from the Association of
American Railroads (AAR) met with staff from the Federal Railroad Administration (FRA) to
provide oral comments to the Paperwork Reduction Act (PRA) information collection renewal
(ICR) 60-day Federal Register notice titled, “Railroad Locomotive Safety Standards and Event
Recorder” (60-day notice), Office of Management and Budget (OMB) #2130-0004.
FRA held this teleconference in a manner consistent with U.S. Administrative Procedure Act
requirements and the only information that FRA shared on the call was based on public
information that could be accessed on FRA’s website, in the 60-day notice, or reginfo.gov.
AAR explained its concerns with FRA’s proposed burden estimates, namely that the adjusted
estimates were significantly reduced from previous OMB# 2130-0004 ICR packages. AAR
questioned how FRA derived these updated estimates and expressed its specific concerns about
the updated estimate in 49 CFR 229.21(a)- Daily inspection. AAR discussed that time tests and
inspection burdens fall within the scope of the PRA and should not have been removed from the
burden estimation. AAR also requested that going forward, FRA highlight the regulatory
sections in its 60-day notices in which estimates have been significantly adjusted. AAR believes

that this additional information will allow stakeholders to determine significant estimate
adjustments more easily when reviewing FRA’s 60-day notices.
FRA thanked AAR for its feedback and encouraged AAR to follow up with written comments
further detailing its concerns. FRA also stated that it would review its PRA estimates for this
ICR renewal and will address stakeholder comments in the upcoming 30-day notice and
supporting materials that will be submitted to OMB.
At 9:29 AM ET, the teleconference adjourned.
cc: Docket No. FRA-2021-0006