FR 2025-04893

The document titled "Proposed Agency Information Collection Activities; Comment Request" issued by the Federal Railroad Administration (FRA), a part of the Department of Transportation, seeks public feedback on a specific Information Collection Request (ICR) related to Passenger Equipment Safety Standards. The goal is to gather input before submitting this request for approval to the Office of Management and Budget (OMB).

General Summary

Under the Paperwork Reduction Act (PRA) of 1995, federal agencies are required to seek public comments on certain information collection activities. The document describes the FRA's collection of information pertaining to safety standards for passenger rail equipment, emphasizing the need for public involvement to ensure these activities are effectively managed and necessary. It highlights the FRA's commitment to maintaining safety in passenger train operations through periodic assessments and inspections.

Significant Issues or Concerns

The document contains certain technical language and references to specific regulations, such as sections of the Code of Federal Regulations (CFR), which might not be readily accessible to a general audience. This technical jargon could hinder understanding and reduce the potential for meaningful public engagement.

The estimated burden hours have been adjusted slightly from 95,946 to 95,947 hours, a change that seems trivial and might be perceived as excessively detailed, offering negligible practical insight into the data collection's real-world impact.

Additionally, the document mentions the exclusion of specific requirements under sections §§ 238.133(c) and 238.21(f) from information collection activities without clearly explaining the reasons for their removal or the consequences, potentially leaving readers confused.

The phrase "Extension without change (with changes in estimates)" appears contradictory. It might benefit from clearer articulation to convey whether it implies substantial modifications or minor adjustments to existing practices.

Impact on the Public

Broadly speaking, this initiative offers the public an opportunity to weigh in on how passenger train safety is regulated, potentially affecting how information is collected and applied to safeguard train operations.

While the document aims to incorporate public perspective in reducing administrative burdens and enhancing data collection practices, the complexity of the language and reporting might discourage active participation, particularly from individuals without a background in regulatory affairs or rail transportation.

Impact on Specific Stakeholders

For businesses, particularly those operating within the railroad industry, the document underscores a direct implication on operational standards and potentially the cost of compliance. The precise calculation of the burden-hour cost equivalent, while potentially unrealistic, signals the FRA's attempt to provide transparent and accountable reporting to stakeholders involved.

For regulatory bodies and enforcement agencies, the document represents a step towards refining processes to meet mandated safety standards efficiently. By inviting feedback, the FRA encourages collaboration among multiple stakeholders to improve safety protocols, thereby fostering a proactive safety culture within the industry.

In summary, while the document performs an essential function of engaging the public in regulatory processes, its effectiveness could be enhanced through clearer language and more approachable terms that resonate with a wider audience. This would ensure more comprehensive and constructive dialogue among all parties involved.

The document under review pertains to the Federal Railroad Administration's (FRA) intent to collect information, as allowed under the Paperwork Reduction Act of 1995. The focus of this commentary lies on the financial estimate provided for the burden associated with these information collection activities.

Financial Estimate of Burden Hours

The document estimates the Total Estimated Annual Burden Hour Dollar Cost Equivalent as $8,296,770. This figure attempts to quantify the cost associated with the time spent by businesses, particularly railroads, in complying with information collection requirements. The estimation is based on multiplying the total burden hours by a certain hourly rate, reflecting the economic impact of such regulatory requirements on the businesses involved.

Relation to Identified Issues

1. Precision of Financial Estimate:

The estimate of $8,296,770 is presented with precise accuracy down to the dollar. While accuracy is generally desirable, the document might give an impression of undue precision in what is inherently an estimate. Financial projections often carry a degree of uncertainty, and the exactness could appear misleading to readers not familiar with such processes. It's important for readers to understand these figures as approximations rather than absolute certainties.

1. Significance of the Estimate Changes:

The document notes an incremental change in the estimated burden from 95,946 to 95,947 hours. This trivial adjustment by a single hour results in a potentially negligible financial impact, which raises questions about the threshold of reporting such changes. Stakeholders might find this overly detailed, leading them to question the overall transparency and communication regarding financial estimations.

1. Context for Exclusion of Certain Requirements:

The document mentions certain requirements under sections 238.133(c) and 238.21(f), which were excluded from the burden estimate, implying they don’t constitute information collection. While there’s no direct financial implication from their exclusion, understanding why certain activities are excluded or included can provide a clearer picture of how the financial burden is calculated.

Overall Assessment

The inclusion of a specific dollar amount aims to convey the scope of the economic impact regulatory compliance has on businesses, serving as a key consideration for public feedback. However, the presentation of this financial data also highlights potential communication issues surrounding the precision and clarity of such estimates, as identified in the document. Clarity about the nature of these estimates and the rationale for reported changes could enhance understanding and trust among stakeholders.