supports FCC efforts to establish reasonable telecommunications
carrier protections for CPNI and encourage the Commission to work
with carriers, State Public Utility Commissions and privacy
organizations, and consumer advocacy groups to reach consensus on
these requirements. The Commission should ensure that equitable
access to CPNI is provided to firms seeking this information, and
should include provisions that allow the requestor to obtain this
data in any format already being generated by the collector. The
FCC should also try to minimize the written reporting and
recordkeeping requirements imposed on the carriers and public.
Finally, when these rules are finalized, the FCC should include
estimates of the cost and hour burden imposed on the public in
responding to requests to use their CPNI for other purposes.
Inventory as of this Action
The attached Notice of Proposed
Rulemaking (NPRM) seeks to clarify and specify in more detail the
obligations of telecommunications carriers under the customer
proprietary network information (CPNI) subscriber list information
provisions of the Telecommunications Act of 1996 (see 47 U.S.C.
section 222). (The NPRM also seeks to implement data safeguards for
information about calls received by alarm monitoring services,
pursuant to 47 U.S.C. section 275(d), but the Commission does not
anticipate that such safeguards will require any information