Appendix A - Supplement to Supporting Statement

Appendix A

Assumptions
Note #
1 Number of interconnected VoIP service provider respondents.
Number of interconnected VoIP service providers subject to Compliance
Letter base based on current 499 filers

393

Number of interconnected VoIP service providers subject to all other
information collection requirements. (Underlying IVoIP providers.)

12

Systems replacing webpage / system each year

3

2 VoIP residential penetration:
YEAR
Accounts at year end in millions (#)
Initial registrations in year
Churn (##)
Other changes in millions (###)
Registrations
IVoIP phone sales (####)

#
##
###

####

2006
5.2
2.6
1.04
1.04
4.68
3.5

2007
9.0
3.8
1.80
1.80
7.40
5.4

2008
10.7
1.7
2.14
2.14
5.98
4.2

2009
12.2
1.5
2.44
2.44
6.38
4.5

2010
13.3
1.1
2.66
2.66
6.42
4.4

2011
13.9
0.6
2.78
2.78
6.16
4.2

We don't have definitive IVoIP customer counts. Data for 2005 through 2007
based on a combination of household penetration data and wireline customer counts.
Percentage of VoIP customers that change providers each year.
20%
Other causes of additional registration, such as laptop users
registering temporary locations, expressed as registrations per
total number of accounts.
20%
Estimated as New accounts +1/3 of churn phones + 20% of prior year
existing accounts (replacement phones)

3 Annual costs for additional server space, memory, communications, and
backup/recovery service associated with registration systems (per provider).
4 Hourly rate for senior attorney and officer time, based on 2009 GS 15 Step 10
[Washington-Baltimore-Northern Virginia] divided by 2000 hours and
increased by 80% to reflect overhead and other loadings.

$1,000
$137.88

5 Hourly rate for development of web based software and internal
data systems based on 2009 GS 13 Step 5 [Washington-Baltimore-Northern Virginia]
annual salary divided by 2000 hours and increased by 80% to reflect overhead
and other loadings.
$88.67
6 Hourly rate for service representatives based on 2009 GS 7 Step 5 [WashingtonBaltimore-Northern Virginia] annual salary divided by 2000 hours and increased
by 80% to reflect overhead and other loadings.

$42.03

7 Value of consumer time based on average hourly earnings for all private
employment for November 2008 (Economic Report of the President, 2009,
Table B-47).

$18.30

1

Appendix A

Assumptions - Continued
Note #
8 Programmer hours needed by a service provider to develop, test & deploy
a webpage to collect registration information, including FAQs, etc., and
to develop a separate tracking system for mail-in registrations (per provider).

300

9 Annual programming maintenance associated with registration information
and E911 notification systems.

300

10 Percentage of existing customers that will require telephone follow-up in order
to obtain registration information and certification statement.

10%

11 Average time to contact a customer, explain the purpose of the call and
obtain registration information and customer certification (hours).

0.25

12 Telephone contacts generated per hundred registrations.

1 = 1 percent

13 Average service representative hours to handle each registration
including time to verify that customer understands any E911 limitations.
14 Average customer hours to complete registration and verify that they
understand the E911 limitations of providers (average for online &
operator calls).
15 Number of consortiums that will develop router based gateways to relay
E911 calls from Internet platforms to the E911 network.

= Minutes
9

hours
0.09

= Minutes
5.4

2

16 Number of gateway routers employed in each E911 network. (Depending
on a number of factors, this value could range from 7 to 200. If the latter,
some might not be deployed in the initial year.)
17 Cost per gateway router (middle of estimated range of $50,000 to $200,000).

hours
0.15

75

$125,000

18 Amortization period in years for router hardware.

5.0

19 Connections to LEC specialized Routers:
Connections in same city.
Connections in different cities.

200
75
125

20 Monthly Cost of T1 connections between gateway routers and specialized routers:
Connections in same city.
Connections in different cities.
21 Programmer hours needed by a service provider to develop, test & deploy
and manage automated systems registering customer information to the ILEC
ALI databas (Assumption that these have largely been developed by 2008
2005
2006
2007
2008
2009
hours
2000
2000
2000
500
500

300
1000

2010 & beyond
500

2

Appendix A

Assumptions - Continued
Note #
22 Monthly charge per telephone number for ILEC handling of E911 calls
(includes access to ALI databases and specialized routers).
2005
2006
2007
2008
charge
$1.25
$0.85
$0.50
$0.50

2009
$0.50

23 Paper records per cubic foot.
24 Monthly cost per cubic foot of storage based on charges for off-site storage.
25 Annual programmer time per provider to monitor storage of computerized
records and perform backups (one hour per month).

2010 & beyond
$0.50

500
$0.80

12

26 Cost of mailout for each existing customer.

$2.75

27 Cost of E911 sticker and associated explanation material.

$0.25

28 Attorney time to prepare a compliance letter and officer time to review
and sign the letter.

16

3

Appendix A
Estimated Burden Hours
to the Public

2009

2010

2011

Estimated Dollar Burden
to the Public
Average
2009 to
2011

Average
2011 2009 to 2011

2009

2010

$12,000

$12,000

$12,000

$12,000

A. Collection of the "registered Location" from each VoIP customer
1) Development and operation of registration location databases:
Annual costs for additional server space, memory, communications, and
backup/recovery service associated with registration systems
Annual cost X number of service providers. See notes 1 and 3.
Programmer hours needed by a service provider to develop, test & deploy
a webpage to collect Registered Location information, including FAQs,
etc., and to develop a separate tracking system for mail-in registrations.
Hours X cost per hour X number of service providers (Startup cost
allocated 3 years). See notes 1, 5 and 8.
Annual programming maintenance associated with registration information
systems and databases.
Programmer & analyst hours X cost per hour X number of service providers.
See notes 1, 5 and 9.
Subtotal

900

900

900

900

$26,600

$26,600

$26,600

$26,600

3,600
_______

3,600
_______

3,600
_______

3,600
_______

$319,198
_______

$319,198
_______

$319,198
_______

$319,198
_______

4,500

4,500

4,500

4,500

$357,798

$357,798

$357,798

$357,798

9,570

9,630

9,240

9,480

$402,270

$404,792

$388,399

$398,487

574,200

577,800

554,400

2) Costs to service providers of collecting registration information from existing
customers that require telephone follow-up (i.e., those that do not respond to
emails, billing inserts or separate letters).
Estimated accounts on June 1 X percent follow-up X minutes per contact
X cost per hour. (Start up cost allocated over 3 years.)
See notes 2, 10, 11 and 6.
NOTE: no startup cost after 2007
3) Cost of handling new customers, churn customers, and existing customers
that register additional locations, where the customer prefers to deal with
a live service representative. Included also is the cost of handling
complaints and customer inquiries about the registration requirement.
(Registrations + Churn + changes) X percent requiring handling
X time per call X hourly rate. See notes 2, 12, 13 and 6.
4) Burden to customers for providing information via webpage, mail, or calls
to customer service.
Registrations X time per registration X value of customer time
See notes 2, 14 and 7.

568,800 $10,507,860 $10,573,740

$10,145,520 $10,409,040

1

Appendix A
Estimated Burden Hours
to the Public

2009

2010

2011

587,370

591,030

567,240

900

900

900

588,270

591,930

568,140

Estimated Dollar Burden
to the Public
Average
2009 to
2011

2009

2010

Average
2011 2009 to 2011

A. Continued
Subtotal Q12: Total Hours
Subtotal Q13A: Capital & Startup Cost

581,880 $11,229,328 $11,297,731
900

$38,600

$38,600

$10,853,117 $11,126,725
$38,600

$38,600

Subtotal Q13B: O&M and Services Cost
Total burden for collection of the registered location from each customer

582,780 $11,267,928 $11,336,330

$10,891,717 $11,165,325

B. Making registered location information available to or through
the ALI databases
1) Annual equipment cost of VoIP gateway routers.
(number of routers X cost per router / amortization years) X consortiums
See notes 16, 17, 18 and 15.
2) Monthly telecommunications costs of connections between
gateway routers and ILEC Selective Routers.
( number of connections X cost per router X 12 months ) X consortiums
See notes 19, 20 and 15.
3) Programming and operations cost associated with updating
ILEC ALI databases.
Programmer hours X cost per hour X providers
See notes 21, 5 and 1.

6,000

6,000

6,000

6,000

4) Monthly payments to ILECs for access to specialized routers,
dedicated E911 network, and PSAP functions.
Avg. customers per year X ILEC charge X months )
See notes 2 and 22.
Subtotal Q12: Total Hours

$3,750,000

$3,750,000

$3,750,000

$3,540,000

$3,540,000

$3,540,000

$3,540,000

$531,997

$531,997

$531,997

$531,997

$68,700,000 $76,500,000

6,000

6,000

6,000

Subtotal Q13A: Capital & Startup Cost
Subtotal Q13B: O&M and Services Cost
Total burden for making registered location information available to or
through the ALI databases.

$3,750,000

6,000

6,000

6,000

6,000

$531,997

$531,997

$3,750,000

$3,750,000

$81,600,000 $75,600,000

$531,997

$531,997

$3,750,000

$3,750,000

$72,240,000 $80,040,000

$85,140,000 $79,140,000

6,000 $76,521,997 $84,321,997

$89,421,997 $83,421,997

2

Appendix A
Estimated Burden Hours
to the Public

2009

2010

2011

Estimated Dollar Burden
to the Public
Average
2009 to
2011

Average
2011 2009 to 2011

2009

2010

$2,198

$2,448

$2,611

$2,419

$5,453

$6,538

$7,258

$6,416

C. Customer notification
1) Verifying that current customers have been notified of the E911 capabilities
of the provider: hours and costs included with A-2.
2) Verifying that new customers have received notification of the E911
capabilities of the provider: hours and costs included with A-3.
3) Customer time spent reading / listening to E911 limitations and
confirming that they have been notified: Covered in A-4.
D. Record of Customer notification
1) Cost of storing paper records for registration information and notification
certifications where customer contact via phone for that year
[ [ ( Accounts on June 1 X percent follow-up ) + (Registrations X
percent requiring handling) ] divided by accounts per cubic foot ] X cost
per foot X 12 months
Cost for storage for current plus two prior years
See notes 2, 10, 12, 23 and 24.
2) Computer records associated with certifications provided over the web.
Hours per provider X cost per hour X number of providers
See notes 12, 1 and 5.
Subtotal Q12: Total Hours

144

144

144

144

$12,768

$12,768

$12,768

$12,768

144

144

144

144

$12,768

$12,768

$12,768

$12,768

$5,453

$6,538

$7,258

$6,416

$14,966

$15,216

$15,379

$15,187

Subtotal Q13A: Capital & Startup Cost
Subtotal Q13B: O&M and Services Cost
Total record keeping burden

144

144

144

144

3

Appendix A
Estimated Burden Hours
to the Public

2009

2010

2011

Estimated Dollar Burden
to the Public
Average
2009 to
2011

2009

2010

$1,113,333

$1,106,667

Average
2011 2009 to 2011

E. User Notification Stickers
1) Cost of mailing stickers to existing customers and to new customers that
previously subscribed to a different provider (termed 'churn' in assumptions).
[ Existing customer (1995) + Churn Customers ] X cost per mailout
See notes 2 and 26.
2) Cost of including stickers in newly sold phones.
New Registrations X cost per sticker
See notes 2 and 27.

$1,046,667

$1,088,889

Subtotal Q12: Total Hours
Subtotal Q13A: Capital & Startup Cost
Subtotal Q13B: O&M and Services Cost
Total

$0

$0

$0

$0

$1,113,333

$1,106,667

$1,046,667

$1,088,889

$1,113,333

$1,106,667

$1,046,667

$1,088,889

F Compliance Letter to be submitted by the VoIP provider to the
Commission
1) Cost to prepare, review, sign and transmit letter.
Hours X cost per hour X number of providers
NOTE: THIS REQUIREMENT DROPPED SEE NOTES 28, 1 and 4.
Subtotal Q12: Total Hours
Subtotal Q13A: Capital & Startup Cost
Subtotal Q13B: O&M and Services Cost
Total
Summary for all cost elements
Subtotal Q12: Total Hours
Subtotal Q13A: Capital & Startup Cost
Subtotal Q13B: O&M and Services Cost
Total All

593,514

597,174

573,384

900

900

900

0

0

0

594,414

598,074

574,284

588,024 $11,774,094 $11,842,496
900

$3,788,600

$3,788,600

0 $73,358,786 $81,153,204

$11,397,882 $11,671,491
$3,788,600

$3,788,600

$86,193,924 $80,235,305

588,924 $88,918,225 $96,780,210 $101,375,760 $95,691,398

4