Overview
Title
Proposed Agency Information Collection Activities; Comment Request
Agencies
ELI5 AI
The Federal Railroad Administration wants to hear from people about some forms they use to gather information. They want to know if these forms are useful and if there are ways to make filling them out easier. People need to send their thoughts by May 12, 2025.
Summary AI
The Federal Railroad Administration (FRA), Department of Transportation is seeking public comments on their Information Collection Request (ICR) under the Paperwork Reduction Act. They are asking for feedback on the necessity and utility of the information collection activities, the accuracy of their burden estimates, and ways to improve or reduce the burden of these activities. The FRA aims to use this feedback to enhance reporting efficiency, improve information quality, and accurately assess resource expenditures. Public comments must be submitted by May 12, 2025.
Abstract
Under the Paperwork Reduction Act of 1995 (PRA) and its implementing regulations, FRA seeks approval of the Information Collection Request (ICR) summarized below. Before submitting this ICR to the Office of Management and Budget (OMB) for approval, FRA is soliciting public comment on specific aspects of the activities identified in the ICR.
Keywords AI
Sources
AnalysisAI
The document issued by the Federal Railroad Administration (FRA), a division of the Department of Transportation (DOT), is a call for public input on their Information Collection Request (ICR) as outlined under the Paperwork Reduction Act of 1995. This notice is part of a regulatory process that requires federal agencies to solicit feedback from the public regarding the necessity and efficacy of their data collection activities before obtaining approval from the Office of Management and Budget (OMB).
General Summary
The FRA is seeking comments on various aspects of its information collection activities. These activities are mandated by regulations that aim to ensure the safety and efficiency of railroad operations, specifically concerning signal systems. They are asking the public for feedback by May 12, 2025, on both the practical value and implementation of the information collected. The goal is to streamline their processes, make their information collection more efficient, and ensure the resources involved in collecting this information are well-utilized.
Significant Issues and Concerns
There are several issues raised by the document that may cause concern. For instance, there is a lack of detailed explanation on how the total estimated annual dollar cost equivalent of $15,467,984 aligns with specific actions or efforts proposed. This could lead to misunderstandings about financial implications. Furthermore, the language used, such as the phrase "Extension without change (with changes in estimates)", can be confusing and seem contradictory. It needs clarification to ensure stakeholders understand what will actually change with this collection activity.
Another point of concern is the reduction of burden hours by 1,435 hours. Although the document mentions this reduction is due to adjustments, it lacks a detailed breakdown or justification on how these reductions were quantified. Additionally, while the FRA indicates an increase in estimated burden because of previously excluded activities, there is no detailed context or examples of these omitted activities, leaving stakeholders in the dark about what exactly has changed.
The document also references specific and technical regulatory codes which, without explanation, may not be easily understood by a general audience. This technical language could deter meaningful public engagement or comments.
Impact on the Public and Stakeholders
Broad Public Impact: The general public is invited to participate in the regulatory process by providing comments. This is an opportunity for citizens to influence government regulations, potentially leading to reductions in unnecessary administrative burdens and more efficient use of taxpayer resources.
Specific Stakeholders: Railroad companies and employees, especially those involved with signal systems, are directly impacted by this request. Changes to reporting requirements can affect operational procedures, compliance costs, and administrative efforts. Positive impacts can arise from reduced paperwork and streamlined processes, while negative impacts might include the initial adjustment to any new reporting systems or increased scrutiny from regulatory compliance.
Overall, while the document's intention is to refine and potentially ease regulatory burdens, it contains ambiguities that stakeholders might find challenging. Clearer explanations and transparency in how estimates are determined would likely improve trust and participation in the feedback process.
Financial Assessment
In reviewing the document titled "Proposed Agency Information Collection Activities; Comment Request," it is important to focus on how financial aspects are addressed. The document mentions financial estimates and costs associated with information collection activities that the Federal Railroad Administration (FRA) is proposing under the Paperwork Reduction Act of 1995 (PRA).
Financial Summary
The document states a Total Estimated Annual Dollar Cost Equivalent of $15,467,984. This figure represents the estimated cost of compliance associated with the proposed Information Collection Request (ICR) activities that involve railroad signal systems. The estimate suggests a significant financial impact on stakeholders, specifically the railroads participating in sustaining and adhering to compliance requirements set by the FRA.
Relation to Identified Issues
While the document specifies a total cost figure, it does not adequately explain how this cost is distributed across the various activities outlined in the ICR. This oversight aligns with the identified issue of ambiguity surrounding the financial distribution and the cost-effectiveness of the proposed activities. Stakeholders may find it challenging to understand how the total cost aligns with specific compliance activities or efforts, as the document lacks a thorough breakdown of this spending.
Additionally, the document describes efforts to reduce administrative burdens by 1,435 hours, yet it does not include comprehensive details to justify the quantified cost savings or the financial implications of this reduction. This lack of detail may confuse readers attempting to assess the financial efficiency of the proposed changes given the absence of in-depth financial analysis.
The phrase "Extension without change (with changes in estimates)" also contributes to potential confusion regarding financial decisions. It is unclear if the financial cost estimated at $15,467,984 reflects existing processes or anticipated future adjustments that might occur due to changes in estimates described in the document.
Lastly, the increase in estimated burden due to previously excluded activities highlights a gap in addressing increased costs resulting from adding these activities. Without offering examples or context regarding these new requirements, stakeholders might find it difficult to comprehend the financial implications of the expanded compliance obligations.
In summary, while the financial information provided gives a high-level cost overview, the document would benefit from offering greater transparency and depth concerning the financial allocations regarding proposed activities. Stakeholders might seek a clearer explanation of how costs impact the broader regulatory framework and potential areas for further cost efficiency and resource allocation.
Issues
• The document does not specify any measures to ensure the minimization of burden in terms of cost-effectiveness or alternative methods of data collection.
• There is ambiguity around how the 'Total Estimated Annual Dollar Cost Equivalent' of $15,467,984 aligns with specific activities or efforts proposed in the document.
• The phrase 'Extension without change (with changes in estimates)' is contradictory and may cause confusion regarding what exactly is being proposed to change in the collection activities.
• The reduction in burden hours by 1,435 hours is discussed, but there is no detailed justification or thorough breakdown of how these specific reductions were quantified or achieved.
• The document language includes specific and technical regulatory references (such as CFR sections) without clear explanations for a general audience, which may make it difficult for some stakeholders to understand the implications.
• The document increases total estimated burden due to previously excluded activities, but it does not provide a detailed context or examples of these previously omitted requirements.