Supporting Statement - Form QCS - 2024 extension request (to ROCIS)

2140-0001
Expires 11/30/2024
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. pt. 1248. The Board is
requesting an extension without modification of this information collection, which will otherwise
expire on November 30, 2024.
2. How the collection will be used. Information reported on Form QCS is entered into
the Agency’s Uniform Rail Costing System (URCS). 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. §§ 1321, 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)). 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 a template provided by the agency. The template has been revised to contain all
of the same data elements, but has been reformatted in a way that should allow for more efficient
submission and agency processing.
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, there is no

duplication of information.
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 more than $1.032 billion. The threshold value for Class I railroads is based on the new
thresholds established in Docket No. EP 763.
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 used by the agency and the public to track commodity volumes. Thus, less frequent
collection would diminish the utility of the data for the agency and the public.
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 on August 5, 2024, providing a 60-day comment period regarding this collection.
89 Fed. Reg. 63459. No comments were received. During the 60-day period, agency
representatives held discussions in individual meetings with three carriers (respondents)
regarding the collection and the changes to the forms. As also required, a Federal Register notice
providing an additional 30-day comment period is being published simultaneously with this
submission. 89 Fed. Reg. 88335.
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: Seven
(2) Frequency of response: Quarterly and annually.
(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 one hour
each time a report is prepared. It is estimated that each of the seven Class I railroads requires not
more than 4 hours to complete the four quarterly reports and an additional to complete the annual
report. The total annual burden hours for all seven carriers are estimated to be not more than 35
hours.
13. Other costs to respondents: No non-hour costs for operation, maintenance, or

purchase of services associated with this collection have been identified. This report is
submitted to the agency electronically.
14. Estimated costs to the Board: We estimate that it takes eight hours annually to
process and review the filings and to enter the annual QCS report into the Agency’s costing
system, and two hours annually to post reports on the website. Total costs to the Board are 10
hours annually, or approximately $760.
15. Changes in burden hours. No change in burden hours is requested. The Board is
requesting an extension without modification. While the template format is changing, the fields
collected are identical to the historical collection, so there are no anticipated changes to burden
hours.

16. Plans for tabulation and publication: Reports generated from these data are posted
on the Board’s website at https://prod.stb.gov/reports-data/economic-data/.
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