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Agency Information Collection Activities Under OMB Review: OMB
No. 2139-0002 and 2139-0004 (Financial and Operating Statistics for
Motor Carriers of Property)
Federal Register Notice
October 30, 2002
Volume 67, Number 210
AGENCY: Bureau of Transportation Statistics (BTS), DOT.
ACTION: Notice of final disposition.
SUMMARY: BTS has submitted the following two Information Collection
Requests (ICRs) described in this notice to the Office of Management
and Budget (OMB) for review and approval as required under the
Paperwork Reduction Act of 1995 (PRA), Pub. L. 104-13. The agency has
issued two previous Federal Register notices on related PRA burden
estimates. BTS has received additional public comments on the related
burden estimates for motor carriers of property (Class I and Class II)
subject to BTS regulations, and OMB has asked the agency to conduct a
reevaluation of the ICRs and the related burden estimates. Therefore,
based on comments received to BTS Docket 10909, BTS is providing a
summary of its reevaluation and analysis of the original burden
estimates for each ICR and is requesting an extension from OMB through
May 31, 2005. The current OMB approval expires on May 31, 2003, for
each form.
DATES: Comments must be submitted on or before November 29, 2002.
ADDRESSES: Send comments to the Office of Information and Regulatory
Affairs, Office of Management and Budget, New Executive Office
Building, NW., Room 10202, Washington, DC 20502, ATTN: Desk Officer for
the Bureau of Transportation Statistics. Comments should identify the
docket number and be submitted in duplicate. OMB requests comments by
November 29, 2002, to process the ICR expeditiously.
FOR FURTHER INFORMATION CONTACT: Paula R. Robinson, Compliance Program
Manager, Office of Motor Carrier Information, K-13, Bureau of
Transportation Statistics, 400 Seventh Street, SW., Washington, DC
20590-0001; (202) 366-2984; fax: (202) 366-3364; e-mail:
paula.robinson@bts.gov.
SUPPLEMENTARY INFORMATION:
Title: Financial and Operating Statistics for Motor Carriers of
Property.
OMB Approval Numbers: 2139-0002 (Form QFR) and 2139-0004 (Form M).
The Financial and Operating Statistics (F&OS) for Motor Carriers of
Property is a collection of annual and quarterly financial and
operating statistics data from the motor carrier community. The
regulations require motor carriers of property with annual revenues of
$3 million or more to file annual reports, and carriers with annual
revenues of $10 million or more to file quarterly reports with BTS, as
required by 49 CFR 1420, Reports of Motor Carriers. The agency ensures
that the data and information collected are made publicly available as
mandated by Congress (49 U.S.C. 14123).
In accordance with OMB regulations (5 CFR part 1320), each agency
that is renewing an information collection activity must notify the
public of its intention to renew the collection activity, provide an
opportunity for public comment, and notify the public when the agency
has sent its information clearance package to OMB. Under the PRA (44 U.S.C. 3501-3520), Federal agencies must obtain
approval from OMB for each information collection they conduct or
sponsor. BTS solicited public comment on November 5, 2001, on the
information collection requirements for OMB 2139-0002 (Form QFR) and
OMB 2139-0004 (Form M) contained in BTS regulations, Reports for Motor
Carriers (66 FR 55981). The notice received three comments to the
docket from the Central Analysis Bureau (CAB), International
Brotherhood of Teamsters, and Inland Marine Underwriters Association.
Pursuant to OMB requirements, a second notice was published on March 5,
2002, (67 FR 10043), allowing a 30-day comment period. BTS received 18
additional comments to the docket, some after the comment period closed
on April 4, 2002.
Sixteen motor carriers, one government agency, and one private
insurance organization provided additional comments to the docket. The
motor carriers were All-Pro Transport, Inc.; Burns Motor Freight, Inc.;
Daggett Truck Line, Inc.; Falcon Transport, Inc.; Fikes Truck Line,
Inc.; Howell's Motor Freight, Inc.; Market Transport Ltd.; New Country,
Inc.; Olson Carriers, Inc.; Paschall Truck Lines, Inc.; PFT Transport,
Inc.; Pioneer Transport, Inc.; RJW Transport, Inc.; Stagecoach Cartage
and Distribution, Inc.; USA Truck, Inc.; and Witte Bros. Exchange, Inc.
The carriers' comments were virtually identical (similar to form
letters) and each opposed the agency's data collection program. CAB and
the U.S. Department of Commerce's Bureau of Economic Analysis (BEA)
provided comments supporting the program. CAB included supplemental
information to comments previously submitted to this docket. All
comments have been considered and included as part of the agency's
overall reevaluation of the financial reporting requirements for motor
carriers of property (Class I and Class II).
On May 13, 2002, OMB approved a provisional clearance for BTS
information collection requests for one year and instructed the agency
to address concerns expressed by commenters to the previous ICRs. OMB
requested that the agency publish a notice containing any revised
estimates of the burden hours required to comply with the ICR. BTS is
requesting OMB's approval to extend the existing ICR expiration (May
2003) so the data collection instrument may continue being used by
motor carriers to report their annual and quarterly financial and
operating data. This effort will ensure that decision-making of Federal
and private agencies and research activities throughout government,
businesses, and academia will continue with benefit to the public.
Approval of this request will allow the forms to remain effective for a
3-year period, until May 31, 2005. The results of the agency's
reevaluation and analysis are described below.
This notice summarizes the results of the reevaluation and
establishes a public comment period of 30 days from the date of
publication in the Federal Register. The agency is requesting that the
OMB extend the 1-year approval to 3 years once it has conducted a
review of the agency's information collection requests. All public
comments to the agency's reevaluation and analysis should be sent to
OMB at the address shown in the ADDRESSES section above.
Discussion of Comments
BTS has considered the comments to the docket and believes that the
F&OS data and associated information serve a useful purpose for many
users engaged in analytical and decision-making activities. The users
include trucking companies, insurance companies, trade associations and
labor organizations, academics, and Federal agencies where trucking
industry policy is evaluated and formed, and others that rely on motor
carrier statistics to carry out their mandated statistical programs
(e.g., Department of Commerce's Bureau of Economic Analysis). Within
these sectors, researchers and analysts benchmark expenses 1 of
individual trucking companies; investment analysts provide advice to
clients based on industry trends; trade associations and journals use
the F&OS data as the basis for analyses on the current economic status
of trucking (which itself is used as an indicator of change in economic
conditions); and government agencies conduct analysis of F&OS data to
anticipate shifts in industry economics and to support policymaking
decisions. Trucking company comments assert that the data collected
serve no useful purpose. BTS disagrees with that view and invites all
users and interested parties to provide BTS with detailed information
about the various ways the data are used and the importance of the data
to their organizations.
All 16 motor carriers disagreed with the proposed reporting
requirements, stating that the regulations in 49 CFR 1420 should be
eliminated. However, the motor carriers stated in their remarks that if
BTS finds it necessary to continue the reporting requirements, then the
data and information should focus on the ``financial health of
individual motor carriers.'' The carriers proposed that the Form M be
replaced with a postcard that contains only the carrier's name,
address, census number, gross and net revenues and gross expenses on an
annual basis. They stated that the abbreviated filing would reduce the
quantity of the information collected and improve the quality. BTS
believes that the data and information currently collected for motor
carriers of property subject to BTS regulations are consistent with the
requirements of 49 U.S.C. 14123. Given the diversity of the individuals
and groups who use BTS data, the agency disagrees with the carriers'
suggestion that the Form M be replaced with a ``postcard'' requesting
only limited information about the carrier. BTS does not believe a
significant reduction in this reporting requirement would satisfy the
statutory requirement or the intentions of Congress. The statute
requires that, ``at a minimum, such reports shall include balance
sheets and income statements.'' (See 49 U.S.C. 14123(a).) The agency
believes that this postcard version of the form could not provide
meaningful balance sheet and income statement data and thus would fall
below the minimum requirements of the statute.
Moreover, the basic financial data contained in balance sheet and
income statements are generated in the normal course of business by
most trucking companies, permitting managers to assess the results of
their operations. In addition, they can form the basis for the income
tax returns filed by motor carriers. The financial data are often
provided to bankers, vendors, other State and Federal governmental
licensing agencies, financial rating agencies like Dun and Bradstreet,
insurance companies, etc., to assist in the evaluation of a company's
financial results. Further, other government agencies involved in the
trucking industry require other Form M information, such as carriers'
equipment inventory data (number of trucks) and other operational
statistics (e.g., number of employees).
Secondly, the commenters asked that the Form QFR be eliminated
because it's not required by the statute and serves no useful purpose.
Under the governing legislation in 49 U.S.C. 14123, the agency is
allowed to collect other reports, including quarterly reports (Form
QFR). The collection of quarterly data is valuable to researchers analyzing and evaluating F&OS data. In
fact, BTS conducts its own motor carrier industry research on the
financial health of the industry for DOT decision-makers, and the data
are considered an integral part of these evaluations.
The BTS believes that the regulations have not been shown to
represent a significant burden on motor carriers and are critical to
many users. The total burden hours reported for these collections are a
total of 1.8 hours annually per carrier for the four Form QFR
(Quarterly) reports and 9 hours for the Form M (Annual Report). The
agency's objective is to continue to work with motor carriers, the
transportation industry, the financial community, and other public and
private organizations to collect F&OS data and conduct and facilitate
useful analysis. The carriers believe that the burden hours are
underestimated, but do not provide any data that would lead to more
accurate estimates. Therefore, BTS, without any additional data from
the carriers to support their position as to the extent of the burden
or the lack of usefulness of the data, will not implement their
recommendations at this time.
However, BTS will continue to seek ways to reduce the burden on the
motor carrier industry and welcomes any ideas, suggestions, or comments
from interested parties on ways to improve the reporting process.
Specifically, BTS is seeking carrier information that includes details
on the amount of time required to complete both forms (Forms M and
QFR); the type of person the carrier uses or hires to complete the form
(i.e., carrier employees, outside accountant, lawyer, etc.); any
associated costs incurred by the carrier; information on filing methods
used, including electronic (i.e., CD, internet, etc.), to complete the
forms; and form retention activities. BTS notes that while the agency
solicits additional data and clarification from carriers regarding the
accuracy of BTS burden estimates for these collections, any action to
amend the regulations would require substantial rulemaking efforts and
the opportunity for public comment.
The comments of the U.S. Department of Commerce's Bureau of
Economic Analysis (BEA) in support of the BTS' data collection program
stated specifically that they use the program as a ``main data source
for key components of BEA economic statistics.'' Specifically, they
reference the BEA's Annual Input-Output Accounts, as well as
``essential detail or inputs to supplement the information on motor
carriers collected by the Bureau of the Census. * * *''
BTS believes that to continue to benefit the public the decision-
making and research activities made possible by the F&OS data
collection program must continue in a comprehensive and uninterrupted
manner. Some additional public benefits include: government analyses of
the business health of the for-hire trucking industry as a basis for
policies to facilitate an integral part of the nation's transportation
network; continued widespread dissemination and analysis of industry
data by trade associations; enabling trucking companies to improve
their operations by emulating successful companies as they
``benchmark'' their operating results against industry averages and
assess what improvements they need to make to better serve the public;
providing the basis for assessments of profitability by interested
parties, including insurance companies and labor unions; allowing
shippers and their organizations to make more informed choices among
carriers; and supporting the educational process, by providing
objective data for academic research, teaching, and training (e.g., of
future trucking company managers). Except for publicly-held companies,
there are no publicly available individual-carrier-based F&OS other
than those from the Form M and Form QFR; these trucking company
statistics provide ``equal access to data'' to benefit the public--
regulators and the regulated have the same data upon which to base
policy decisions and business planning analyses. In addition, BTS is
involved in extensive analyses of the motor carrier industry using QFR
data. Results of these analyses are used within the Department of
Transportation and will be soon be released and available to the
public.
The agency also disagrees that BTS forms are not available for on-
line filing. For more than a year, the agency has placed additional
resources on BTS' Web site in order to reduce the burden on the
industry and to encourage more electronic filing. The agency has
determined that there has been a 30% increase in the number of motor
carriers filing reports (Form M and Form QFR) using on-line and other
electronic methods. In addition, the agency has implemented automated
quality control and edit-check (QC/EC) systems to improve the
completeness of filed reports and the accuracy of the data. The agency
expects these efforts to increase the total number of motor carriers
filing on-line reports.
CAB is also in support BTS' efforts to collect financial and
operating statistics for motor carriers. CAB submitted comments that
were discussed in the agency's second notice published on March 5, 2002
(67 FR 10043). CAB, in its remarks, requested the agency to include
additional data items on the Form M. CAB supports BTS' need for the
data collection program and, as a major user of the data, believes the
Form M can be completed in less than 9 hours, based on motor carriers
compiling the same data for corporate and tax purposes. CAB felt the
burden estimate for the second ICR, Form QFR, was reasonable.
The CAB provided additional comments to the docket containing
supplemental information to support its original comments in the
docket. CAB's suggested that its proposal added no discernible impact
on the reporting burden. BTS will consider the CAB's comments in future
rulemakings associated with these information collections.
As noted above, the BEA is in strong support of the agency's
continued collection of F&OS data. BEA commented that the data are
essential to its Annual Input-Output Accounts, which are used to
prepare estimates of industry output and in understanding the
infrastructure of the economy.
Based on the statutory requirements, BTS considered some of the
comments in the docket beyond the scope of its data collection program
evaluation. Below is a brief summary of the agency reevaluation for
each ICR under the appropriate approval number. The estimates that
appear in the agency's evaluation are identical to those used in the
ICR submission to OMB for renewal of the BTS Forms.
I
OMB Approval Number: 2139-0002 (Form QFR).
Title: Quarterly Report of Class I Motor Carriers of Property.
Estimated annual burden hours: The Quarterly Report of Class I
Motor Carriers of Property (Form QFR) imposes 1,800 (27 minutes per
quarter) total annual burden hours on motor carriers reporting to BTS.
The figures shown on the information collection supporting statement
(on file with OMB) for this collection are estimates based on the total
number of filers (including new entrants and repeat filers), the
frequency of reporting, and the time needed to compile the information
and record information on the form (used to comply with the BTS
regulations in 49 CFR part 1420).
Reporting: BTS regulations for the Form QFR are applicable to for-
hire (common and contract) carriers that generate $10 million or
greater in gross annual operating revenues. Motor carriers that meet this requirement must report their quarterly F&OS
data to BTS. The data collected include selected income statement
information along with information on tonnage, mileage, and number of
shipments. These data are contained on a single page and are extracted
from normal trucking management reports and accounting information that
most carriers have readily available. BTS estimates that approximately
1,000 respondents each take an estimated 1.8 hours (27 minutes per
quarter) annually to file quarterly reports with BTS. The total annual
burden-hour estimate is 1,800 hours (1.8 hours x 1,000). The total
number of respondents is based on the maximum average number of
respondents per quarter, including new entrants and repeat filers. New
entrants are typically motor carriers that are reporting data on the
Form QFR for the first time. This group of carriers normally requires
additional time to complete the two-page form with additional
assistance from BTS as well as other sources. These estimates were
based in part on estimates contained in the last approved ICR.
Agency data show that about 30% of the repeat filers report on the
Form QFR through electronic means (i.e., Internet, disk, or CD) while
70% use written reports to file using downloadable forms or forms
provided by BTS. The time needed to meet the reporting requirement for
this collection is more for the first time filer and less for the
repeat. As part of its overall estimate, the agency considered
previously reported figures and recalculated the estimates based on the
total number of electronic filers.
II
OMB Approval Number: 2139-0004 (Form M).
Title: Annual Report of Class I and Class II Motor Carriers of
Property.
Estimated annual burden hours: BTS estimates that the Annual Report
of Class I and Class II Motor Carriers of Property (Form M) ($3 million
or greater in adjusted operating revenue) imposes 27,000 annual burden
hours on motor carriers reporting to BTS. The figures shown in the
supporting statement are estimates based on the total number of filers
(including new entrants and repeat filers), the frequency of reporting,
and the time needed to compile the information (including recording the
information on the form).
Reporting: BTS regulations for the Form M are applicable to for-
hire (common and contract) carriers that generate $3 million or more
gross annual operating revenues. These carriers are required to report
their F&OS data to BTS. The data collected include selected balance
sheet and income statement data along with information on tonnage,
mileage, employees, transportation equipment, and other related data.
BTS records show that in FY 2001 approximately 3,000 motor carriers
filed a Form M. BTS estimates that each Form M (8 pages) takes about 9
hours (average) to complete. Approximately 30% of the carriers use
electronic methods (Internet, CD, or disk), which require less than 9
hours to file; carriers that do not file on-line may require more time.
The respondent carriers employ their own staff as well as outside
accountants, lawyers, and other experts to complete the forms. BTS data
indicate that although a large number of carriers that file the Form M
are repeat filers, a substantial number of filers are new entrants,
which require additional time to complete the Form M. Although the
agency has seen an increase in new entrants over the years due to
educational and outreach campaigns to the industry, this increase has
been offset somewhat by the number of bankruptcies and firms going out
of business (as shown in recent industry financial reports such as Dun
and Bradstreet and Standard and Poor's). BTS includes these factors
when determining estimates of the time required for this information
collection.
Estimated Annual Cost of Burden: The combined estimated cost to the
government is $1.2 million dollars for the Form M and Form QFR. This
figure includes salary costs based on hours, overhead, printing, and
payment to contractors. The agency, having received no supporting data
as to the magnitude of the burden on carriers, employs the following
estimate of normal costs of motor carriers associated with filing BTS'
Form M (annual) and Form QFR (quarterly). The number of burden hours is
9 hours for the Form M and 1.8 hours for the Form QFR. Based on Bureau
of Labor Statistics (BLS) data, an accountant's cost is $21.56 per hour
with a fringe benefit percentage of 44.4%. If we apply these dollars to
the hourly efforts for motor carriers for each form, the result is
$895,968 (for Form M) and $55,998 (for Form QFR), for a combined total
of $951,966 for the motor carrier industry.
BTS Burden Hours Estimates
Number of Respondents |
1,000 |
3,000 |
Frequency of Responses |
Quarterly |
Annual |
Estimated Time Per Carrier |
1.8 hours (27 minutes per quarter) |
9 hours |
Prior Total Annual Burden Hours |
1,800 |
27,000 |
Revised Total Annual Burden Hours |
No Change |
No Change |
Estimated Costs on Motor Carriers |
Change: $55,998 (est) |
Change: $885,968 (est.) |
Data and Sources
- Mean hourly wage estimate for accountants: $21.56. (Source: 2000 National Industry-Specific Occupational Employment and Wage
Estimates, SIC 421--Trucking and Courier Services, Except Air, 13-2011
Accountants and Auditors, 09/06/02; http://www.bls.gov/oes/2000/oesi3--421.htm)
- Mean hourly earnings for accountants: $21.51. (Source: Table 1:
Hourly Earnings of Full-time and Weekly and Annual Work Hours, National
Compensation Survey, 2000, ``Accountants and Auditors,'' BLS Monthly
Labor Review, March 2002, p. 49.)
- Employer costs per hour worked for employee compensation;
``total compensation'': $20.01 (Source: BLS News, USDL: 02-346, June
19, 2002.)
Russell B. Capelle, Jr.,
Assistant BTS Director for Motor Carrier Information, U.S. Department of Transportation.
[FR Doc. 02-27527 Filed 10-29-02; 8:45 am]
BILLING CODE 4910-FE-P
1 A process of comparing a trucking company's expenses,
operating statistics, and other characteristics (e.g., aggregates,
compilations, or averages for line item data on Form M (annual
report) and/or Form QFR (quarterly report)) with those of other
trucking companies or groups of them for the purpose of evaluating
how one's company differs from the industry generally, with the end
of improving one's results.
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