OMB does not approve this collection and is filing the following comments that should be incorporated into the rulemaking for CC Docket 97-181. This information collection, as proposed, represents a fifty percent increase in the FCC burden. In terms of the number of respondents, this collection would be one of the largest collections employed by the Federal government. The collection does not appear to meet the practical utility/burden reduction requirements of Section 1320.9 of the PRA nor does it propose to use statistical survey methods to reduce the burden. Significant burden will be imposed on the local exchange carriers who must administer any self-certification process. Finally, it is not certain that respondents will understand what they are certifying and whether they will, in fact, respond accurately to such a requirement. Because this is an ongoing rulemaking process, there are a number of issues that must be defined before OMB can review this collection. These include definitions of primary and secondary lines, how such lines will be identified and verified, the definition of household and its relationship to primary and secondary line designation, and penalties that may be associated with wrongful certifications. OMB strongly believes that a self-certification process would be burdensome, difficult to manage, and ineffectual. Therefore, the Commission should reexamine use of existing information available to the carriers. A more focused information collection approach could be used to collect additional data needed to augment LEC records. Statistical sampling methods should be used whenever possible. Because of the scope of the proposed collection, and the many significant issues that must be resolved, OMB does not approve this collection as proposed. OMB is filing more detailed comments in an email sent to Judy Boley and Shoko Hair. The FCC may refer to this OMB document number in future correspondence and during the rulemaking process.
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The FNPRM seeks comment on the appropriate definition of primary residential lines. The FNPRM proposes, inter alia, to identify primary lines by asking customers of incumbent LECs subject to Commission price cap regulation to self-certify to the following information: 1) Depending on the definition ultimately adopted, identification of the relevant subscriber, residence, or household; 2) identification of the primary residence of such subscriber, residence, or household; 3) identification of the primary line. Incumbent LECs must use this information to assess the appropriate access.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
In the Matter of State-Federal Joint Board on Universal Service Defining Primary Lines -- CC Docket No. 97-181