Supporting Statement OMB 3060-1084 (2010)

Supporting Statement OMB 3060-1084 (2010).doc

Rules and Regulations Implementing Minimum Customer Account Record Obligations on All Local and Interexchange Carriers (CARE), Report and Order and Further Notice, CG Docket No. 02-386

OMB: 3060-1084

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3060-1084 April 2010

Rules and Regulations Implementing Minimum Customer Account Record Obligations on All Local and Interexchange Carriers (CARE),

CG Docket No. 02-386


SUPPORTING STATEMENT


A. Justification




1. On February 25, 2005, the Commission released a Report and Order (“2005 Report and Order”) and Further Notice of Proposed Rulemaking (“2005 Further Notice”) in Rules and Regulations Implementing Minimum Customer Account Record Exchange Obligations on All Local and Interexchange Carriers, CG Docket No. 02-386, FCC 05-29. 2002.1 In the 2005 Report and Order:


  1. The Commission adopted final rules governing the exchange of customer account information between LECs and IXCs.


  1. The Commission concluded that mandatory, minimum standards are needed in light of record evidence demonstrating that information needed by carriers to execute customer requests and properly bill customers is not being consistently provided by all LECs and by all IXCs.


The 2005 Report and Order identified situations in which information exchanges are needed to ensure the seamless provision of services and establishes carriers’ responsibilities with respect to those exchanges. Specifically, the R&O requires LECs to supply customer account information to IXCs when: (1) the LEC places an end user on, or removes an end user from, an IXC’s network; (2) an end user presubscribed to an IXC makes certain changes to her account information via her LEC; (3) an IXC requests billing name and address information for an end user who has usage on an IXC’s network but for whom the IXC does not have an existing account; and (4) a LEC rejects an IXC-initiated PIC order. The R&O requires IXCs to notify LECs when an IXC customer informs an IXC directly of the customer’s desire to change IXCs.


On September 13, 2006, the Commission released an Order on Reconsideration in Rules and Regulations Implementing Minimum Customer Account Record Exchange Obligations on All Local and Interexchange Carriers, CG Docket No. 02-386, FCC 06-134 (“Order on Reconsideration”). The Commission concluded that minor modifications to § 64.4002 were needed to clarify carriers’ respective obligations under that rule section.


Note: In December 2007, the Commission released a Report and Order declining to adopt the proposals in the 2005 Further Notice on LEC-to-LEC data exchanges.


This information collection does not affect individuals or households; thus, there are no impacts under the Privacy Act because it does not require the collection of personally identifiable information (PII) from individuals.


The statutory authority for these information requirements are found in sections 1-4, 201, 202, 222, 258, and 303(r) of the Communications Act of 1934, as amended; 47 U.S.C. §§ 151-154, 201, 202, 222, 258, and 303(r).


The Commission is seeking a three-year extension of this information collection from the Office of Management and Budget (OMB).

2. The information collection requirements contained in 47 CFR 64.4002 of the Commission’s rules are intended to:


(a) facilitate the timely and accurate establishment, termination, and billing of customer telephone service accounts, and

(b) apply to local exchange carriers and interexchange carriers.


The information generated by LECs pursuant to the information collections is used by IXCs:


(a) to determine when a customer has been placed on or removed from IXCs’ networks,


(b) to enable IXCs to accurately calculate customer telephone service bills,


(c) to identify the correct billing name and address of a telephone service customer; and


(d) to inform IXCs of critical changes to their customers’ telephone service accounts.


The information generated by IXCs pursuant to the information collections is used by LECs:


(a) To notify the LEC to install a telephone service customer onto or remove a telephone service customer from the network of a particular IXC; and


(b) To notify the LEC that a customer no longer wishes to receive long distance services on a presubscribed basis.


3. Customer account records required by these information collection requirements may be transmitted electronically or by any other medium that a carrier may choose to use.


The Commission explained in the 2005 Report and Order that, to the extent that carriers currently are providing timely and adequate notifications to other carriers pursuant to inter-carrier agreements or other information exchange processes (including non-electronic processes), those carriers would not be required to incur additional expenses associated with modifying their current processes.


4. The information collection requirements are not duplicative of any currently existing federal regulatory obligation.


5. The Commission’s rules afford carriers flexibility in both the format and medium of information exchanges and, thus, does not require carriers to use CARE or other automated methods, unless they so choose.


In addition, the rules impose no specific time limits or performance measurements on the exchange of customer account information.


These determinations appear to be consistent with the views expressed by a number of small and rural carriers in the Commission’s rulemaking proceeding. The Commission continues to consider ways to minimize the burden of the new rules on small businesses and small entities.


  1. If the information collections required by the Commission were not implemented, certain obligations of carriers regarding the exchange of customer information would remain unclear.


7. The information collections do not require respondents to report information to the agency, but may require respondents to report basic customer account information to other carriers more often than quarterly:


(a) The frequency of the notification requirements depends upon how frequently each carrier’s customers change carriers or make other account changes.


(b) Carriers are required only to exchange basic account information that is reasonably available to them:


(i) Carriers must provide the required notifications promptly and without unreasonable delay but there is no specific timeframe within which the notifications must take place.


(ii) Carriers are not required to retain records for more than three years.


The information collection is not conducted in any manner that is inconsistent with the guidelines in 5 C.F.R. § 1320.6.


8. The Commission published a notice in the Federal Register pursuant to 5 CFR § 1320.8(d) on MONTH XX, 2010. See 75 FR XXXXX. The Commission received no comments.


9. The Commission does not anticipate providing any payment or gift to any of the respondents.


10. Assurance of confidentiality is not offered because this information collection does not require the collection of personally identifiable information (PII) from individuals. The information that is required to be disclosed under the Commission’s rules includes:


  1. basic customer account information that carriers need to accurately bill customers and to execute carrier changes and other requests.


  1. carriers that receive customer account information under the rules may use that information for billing and provisioning purposes only and may not use it for marketing purposes, unless they obtain customer approval to do so.


  1. There are no questions of a sensitive nature with respect to the information collected.



12. The Commission estimates the annual burden on LECs and IXCs to be:


LECs:

(a) There are approximately 2,316 LECs operating in the United States.2


(b) Approximately 1,942 of these LECs are affected by the information collection reporting requirements contained in 47 C.F.R. § 64.4002(a)-(h), as adopted in the 2005 Report and Order.


(c) The Commission did not include estimates for the largest 374 of the total 2,316 based on its understanding that:


    1. Those LECs already conducted their operations as required by the 2005 Report and Order, and therefore,

    1. Those LECs are not be subject to any new information collection reporting requirements.


(d) Accordingly, LEC respondents subject to the notification requirements contained in 47 C.F.R. § 64.4002(a)–(h), as adopted in the 2005 Report and Order, include approximately 1,942 LECs (respondents).


IXCs:

(a) Similarly, the Commission estimates that there are approximately 300 IXCs operating in the United States.3


(b) Approximately 268 of these IXCs are affected by the information collection reporting requirements contained in 47 C.F.R. § 64.4003(a).


(c) The Commission did not include estimates for the largest 32 of the total 300 IXCs based on the Commission’s understanding that:


(i) Those IXCs already conducted their operations as required by the 2005 Report and Order, and therefore,


(ii) Those IXCs are not be subject to any new information collection reporting requirements.


(d) Based on the Commission’s understanding that most IXCs do not have in place mechanisms for communicating the information required by 47 C.F.R. § 64.4003(b), the Commission estimates that all 300 IXCs are affected by the information collection reporting requirements contained in that section.


(e) IXC respondents subject to the notification requirements contained in 47 C.F.R. § 64.4003(a), as adopted in the 2005 Report and Order, include approximately 268 IXCs (respondents).


(f) IXC respondents subject to the notification requirements contained in 47 C.F.R. § 64.4003(b), as adopted in the 2005 Report and Order, include approximately 300 IXCs (respondents).


The Commission notes that the amount of time it will take for each respondent to provide each of the required notifications will vary significantly depending on, among other things, whether the carrier uses automated or manual processes.


The frequency with which each respondent will be required to provide particular notifications also will vary significantly depending on, among other things:


  1. Whether the respondent’s service territory is primarily urban or rural, and


  1. Depending upon the number of account changes that a particular respondent’s customers happen to make in a given year.


As a general matter, the Commission’s estimates assume that larger carriers will rely more on automated processes, and that smaller carriers will rely more on manual processes.


These estimates also assume that, because many smaller carriers operate in rural areas where there may be fewer PIC changes and fewer changes in local service providers than in urban areas, certain smaller carriers may be required to provide notifications less frequently than their larger counterparts.



The following represents the Commission’s best effort to estimate the hour and cost burdens associated with the required notifications in the 2005 Report and Order:


a. 47 C.F.R. § 64.4002(a). Requirement that a LEC notify the appropriate IXC when the LEC has processed a PIC selection submitted by a customer and placed the customer on the network of the customer’s preferred IXC.


The Commission estimates that 60% of the 1,942 LECs, or approximately 1165 LECs, experience a processing burden of approximately 2 minutes per notification and would be required to provide the notification 48 times per year, for an annual processing burden of 1.6 hours per respondent:


1165 LECs (respondents) x 1.6 hours per year = 1,864 hours


1165 respondents x 48 notifications = 55,920 notifications/responses yearly


The Commission assumes that the respondents will use “in-house” personnel whose pay is comparable to a low-to-mid level federal employee (GS-7/Step 5, plus 30% overhead: $29.80/hour) to process the notifications:


1,864 hours x $29.80 per hour = $55,547.20


The remaining 40% of the 1,942 LECS, or approximately 777 LECs, would experience a processing burden of approximately 15 minutes per notification. Because these smaller LECs tend to process fewer PIC changes, the Commission estimates that they would be required to provide the notification only 24 times per year. Accordingly, the annual processing burden would be approximately 6 hours per respondent, as calculated below:


777 LECs (respondents) x 6 hours per year = 4,662 hours

777 respondents x 24 notifications = 18,648 notifications/responses


The Commission assumes that the respondents will use “in-house” personnel whose pay is comparable to a low-to-mid level federal employee (GS-7/Step 5, plus 30% overhead: $29.80/hour) to process the notifications:


4,662 hours x $29.80 per hour = $138,927.60


b. 47 C.F.R. § 64.4002(b). Requirement that a LEC that has placed a customer on an IXC’s network in response to an IXC-submitted PIC order sends a confirmation to the submitting IXC.


The Commission estimates that 60% of the 1,942 LECs, or approximately 1165 LECs, would experience a processing burden of approximately 1 minute per notification and would be required to provide the notification 68 times per year, for an annual processing burden of 1.13 hours per respondent, as calculated below:


1165 LECs (respondents) x 1.13 hours per year = 1316.45 (1316 hours)


1165 respondents x 68 notifications = 79,220 notifications/responses


The Commission assumes that the respondents will use “in-house” personnel whose pay is comparable to a low-to-mid level federal employee (GS-7/Step 5, plus 30% overhead: $29.80/hour) to process the notifications:


1316 hours x $29.80 per hour = $39,216.80


The remaining 40% of the 1,942 LECs or 777 LECs would experience a processing burden of approximately 8 minutes per notification. Because these smaller LECs tend to process fewer PIC changes, the Commission estimates that they would be required to provide the notification only 32 times per year. Accordingly, the annual processing burden would be approximately 4.27 hours per respondent, as calculated below:


777 LECs (respondents) x 4.27 hours per year = 3,317.79 (3,318 hours)


777 respondents x 32 notifications = 24,864 notifications/responses


The Commission assumes that the respondents will use “in-house” personnel whose pay is comparable to a low-to-mid level federal employee (GS-7/5, plus 30% overhead) to process the notifications. The Commission estimates respondents’ cost to be about $29.80 per hour.


3,318 hours x $29.80 per hour = $98,876.40


c. 47 C.F.R. § 64.4002(c). Requirement that a LEC that rejects or otherwise does not act upon a PIC order submitted to it by an IXC notify the IXC and provide reason(s) why the PIC order could not be processed.


The Commission estimates that approximately 10% of IXC-submitted PIC orders each year are rejected or are not acted upon by a LEC.


Accordingly, the Commission estimates that 60% of these 1,942 LECs, or approximately 1165 LECs, would experience a processing burden of approximately 10 minutes per notification and would be required to provide a reject notification 8 times per year, for an annual processing burden of 1.3 hours per respondent, as calculated below:


1165 LECs (respondents) x 1.3 hours per year = 1,514.5 (1,515 hours)


1165 respondents x 8 reject notifications = 9,320 notifications/responses


The Commission assumes that the respondents will use “in-house” personnel whose pay is comparable to a low-to-mid level federal employee (GS-7/5, plus 30% overhead) to process the reject notifications. The Commission estimates respondents’ cost to be about $29.80 per hour.


1,515 hours x $29.80 per hour = $45,147.00


The remaining 40% of the 1,942 LECs, or 777 LECs, would experience a processing burden of approximately 20 minutes per reject notification. Because these LECs tend to process fewer PIC changes, the Commission estimates that they would be required to provide reject notifications only 4 times per year. Accordingly, the annual processing burden would be approximately 1.3 hours per respondent, as calculated below:


777 LECs (respondents) x 1.3 hours per year = 1,010.1 (1,010 hours)


777 respondents x 4 reject notifications = 3,108 notifications/responses


The Commission assumes that the respondents will use “in-house” personnel whose pay is comparable to a low-to-mid level federal employee (GS-7/5, plus 30% overhead) to process the notifications. The Commission estimates respondents’ cost to be about $29.80 per hour.


1,010 hours x $29.80 per hour = $30,098.00


d. 47 C.F.R. § 64.4002(d). Requirement that a LEC notify the appropriate IXC(s) when the LEC has removed a presubscribed customer from an IXC’s network, either in response to a customer order or upon receipt of a properly verified PIC order submitted by another IXC.


The Commission estimates that 60% of the 1,942 LECs, or approximately 1165 LECs, would experience a processing burden of approximately 3 minutes per notification and would be required to provide the notification 55 times per year, for an annual processing burden of 2.75 hours per respondent, as calculated below:


1165 LECs (respondents) x 2.75 hours per year = 3,203.75 (3,204 hours)


1165 respondents x 55 notifications = 64,075 notifications/responses


The Commission assumes that the respondents will use “in-house” personnel whose pay is comparable to a low-to-mid level federal employee (GS-7/Step 5, plus 30% overhead: $29.80/hour) to process the notifications:


3,204 hours x $29.80 per hour = $95,479.20


The remaining 40% of the 1,942 LECs, or 777 LECs, would experience a processing burden of approximately 12 minutes per notification.


Because these LECs tend to process fewer PIC changes, the Commission estimates that they would be required to provide the notification only 33 times per year. Accordingly, the annual processing burden would be approximately 6.6 hours per respondent, as calculated below:


777 LECs (respondents) x 6.6 hours per year = 5,128.2 (5,128 hours)


777 respondents x 33 notifications = 25,641 notifications/responses


The Commission assumes that the respondents will use “in-house” personnel whose pay is comparable to a low-to-mid level federal employee (GS-7/Step 5, plus 30% overhead: $29.80/hour) to process the notifications:


5,128 hours x $29.80 per hour = $152,814.40



e. 47 C.F.R. § 64.4002(e). Requirement that a LEC communicate certain account or line information changes that occur on a presubscribed customer’s account to the customer’s PIC.


The Commission estimates that 60% of the 1,942 LECs, or approximately 1165 LECs, would experience a processing burden of approximately 2.2 minutes per notification and would be required to provide the notification 80 times per year, for an annual processing burden of 2.9 hours per respondent, as calculated below:


1165 LECs (respondents) x 2.9 hours per year = 3,378.5 (3,379 hours)


1165 respondents x 80 notifications = 93,200 notifications/responses


The Commission assumes that the respondents will use “in-house” personnel whose pay is comparable to a low-to-mid level federal employee (GS-7/5, plus 30% overhead) to process the notifications. The Commission estimates respondents’ cost to be about $29.80 per hour.


3,379 hours x $29.80 per hour = $100,694.20


The remaining 40% of the 1,942 LECs, or approximately 777 LECs, would experience a processing burden of approximately 11 minutes per notification and would be required to provide the notification 40 times per year. Accordingly, the annual processing burden would be approximately 7.3 hours per respondent, as calculated below:


777 LECs (respondents) x 7.3 hours per year = 5,672.1 (5,672 hours)


777 respondents x 40 notifications = 31,080 notifications/responses


The Commission assumes that the respondents will use “in-house” personnel whose pay is comparable to a low-to-mid level federal employee (GS-7/Step 5, plus 30% overhead: $29.80/hour) to process the notifications:


5,672 hours x $29.80 per hour = $169,025.60



f. 47 C.F.R. § 64.4002(f). Requirement that a LEC notify the appropriate presubscribed carrier upon receipt of an end user customer’s request to terminate his entire local service account or disconnect one or more lines (but not all lines) of a multi-line account.


The Commission estimates that 60% of the 1,942 LECs, or approximately 1165 LECs, would experience a processing burden of approximately 3 minutes per notification and would be required to provide the notification 20 times per year, for an annual processing burden of one (1) hour per respondent, as calculated below:


1165 LECs (respondents) x 1 hour per year = 1165 hours


1165 respondents x 20 notifications = 23,300 notifications/responses


The Commission assumes that the respondents will use “in-house” personnel whose pay is comparable to a low-to-mid level federal employee (GS-7/Step 5, plus 30% overhead: $29.80/hour) to process the notifications:


1165 hours x $29.80 per hour = $34,717.00


The remaining 40% of the 1,942 LECs, or approximately 777 LECs, would experience a processing burden of approximately 15 minutes per notification and would be required to provide the notification 10 times per year. Accordingly, the annual processing burden would be approximately 2.5 hours per respondent, as calculated below:


777 LECs (respondents) x 2.5 hours per year = 1,942.5 (1,943 hours)


777 respondents x 10 notifications = 7,770 notifications/responses


The Commission assumes that the respondents will use “in-house” personnel whose pay is comparable to a low-to-mid level federal employee (GS-7/Step 5, plus 30% overhead: $29.80/hour) to process the notifications:


1,943 hours x $29.80 per hour = $57,901.40


g. 47 C.F.R. § 64.4002(g). Requirement that a former LEC notify a customer’s PIC(s) when the customer changes LECs.


The Commission estimates that 60% of the 1,942 LECs, or approximately 1165 LECs, would experience a processing burden of approximately 3.3 minutes per notification and would be required to provide the notification 15 times per year, for an annual processing burden of 0.825 hours per respondent, as calculated below:


1165 LECs (respondents) x 0.825 hours per year = 961.125 (961 hours)


1165 respondents x 15 notifications = 17,475 notifications/responses


The Commission assumes that the respondents will use “in-house” personnel whose pay is comparable to a low-to-mid level federal employee (GS-7/Step 5, plus 30% overhead: $29.80/hour) to process the notifications:


961 hours x $29.80 per hour = $ 28,637.80


The remaining 40% of the 1,942 LECS, or approximately 777 LECs, would experience a processing burden of approximately 16.5 minutes per notification and would be required to provide the notification 5 times per year. Accordingly, the annual processing burden would be approximately 1.375 hours per respondent, as calculated below:


777 LECs (respondents) x 1.375 hours per year = 1,068.375 (1,068 hours)


777 respondents x 5 notifications = 3,885 notifications/responses


The Commission assumes that the respondents will use “in-house” personnel whose pay is comparable to a low-to-mid level federal employee (GS-7/5, plus 30% overhead) to process the notifications. The Commission estimates respondents’ cost to be about $29.80 per hour.


1,068 hours x $29.80 per hour = $ 31,826.40



h. 47 C.F.R. § 64.4002(h). Requirement that a LEC, upon the request of an IXC, provide the billing name and address information necessary to facilitate a customer’s receipt of a timely, accurate bill for services rendered and/or to prevent fraud.


The Commission estimates that 60% of the 1,942 LECs or approximately 1165 LECs would experience a processing burden of approximately 3 minutes per notification and would be required to provide the notification 15 times per year, for an annual processing burden of 0.75 hours per respondent, as calculated below:


1165 LECs (respondents) x 0.75 hours per year = 873.75 (874 hours)


1165 respondents x 15 notifications = 17,475 notifications/responses


The Commission assumes that the respondents will use “in-house” personnel whose pay is comparable to a low-to-mid level federal employee (GS-7/Step 5, plus 30% overhead: $29.80/ hour) to process the notifications:


874 hours x $29.80 per hour = $26,045.20


The remaining 40% or 777 LECs would experience a processing burden of approximately 15 minutes per notification and would be required to provide the notification 5 times per year. Accordingly, the annual processing burden would be approximately 1.25 hours per respondent, as calculated below:


777 LECs (respondents) x 1.25 hours per year = 971.25 (971 hours)


777 respondents x 5 notifications = 3,885 notifications/responses


The Commission assumes that the respondents will use “in-house” personnel whose pay is comparable to a low-to-mid level federal employee (GS-7/Step 5, plus 30% overhead: $29.80/hour) to process the notifications:


971 hours x $29.80 per hour = $28,935.80


i. 47 C.F.R. § 64.4003(a). Requirement that an IXC provide to a customer’s LEC the customer’s properly verified PIC order when the customer contacts the IXC to establish interexchange service on a presubscribed basis.


The Commission estimates that 100% of the 268 IXCs would experience a processing burden of approximately 10 minutes per notification and would be required to provide the notification 30 times per year. Accordingly, the annual processing burden would be approximately 4.98 hours per respondent, as calculated below:


268 IXCs (respondents) x 4.98 hours per year = 1,334.64 (1,335 hours)


268 respondents x 30 notifications = 8,040 notifications/responses


The Commission assumes that the respondents will use “in-house” personnel whose pay is comparable to a low-to-mid level federal employee (GS-7/Step 5, plus 30% overhead: $29.80/hour) to process the notifications:


1,335 hours x $29.80 per hour = $39,783.00


j. 47 C.F.R. § 64.4003(b). Requirement that an IXC notify a customer’s LEC when the customer contacts the IXC to discontinue interexchange service on a presubscribed basis when it is the customer’s desire to have no PIC.




Based on the Commission’s understanding that most IXCs do not have in place mechanisms for communicating the information required by 47 C.F.R. § 4.4003(b), the Commission anticipates that this requirement will have PRA effects for all of the 300 IXCs currently operating in the United States.


The Commission estimates 300 IXCs would experience a processing burden of approximately 15 minutes per notification and would be required to provide the notification 20 times per year. Accordingly, the annual processing burden would be approximately 5 hours per respondent, as calculated below:


300 IXCs (respondents) x 5 hours per year = 1,500 hours


300 respondents x 20 notifications = 6,000 notifications/responses


The Commission assumes that the respondents will use “in-house” personnel whose pay is comparable to a low-to-mid level federal employee (GS-7/5, plus 30% overhead) to process the notifications. The Commission estimates respondents’ cost to be about $29.80 per hour.


1,500 hours x $29.80 per hour = $44,700.00




Rule Sections


Providers


Hours per Response


Total Hours per Year


Notifications


Notifications perYear

TotalTotal

Total “In House” Costs

Information Collection Requirements

47 CFR § 64.4002(a)

1165 LECs

1.60

1,864

48

55,920

$55,547.20


777 LECs

6.00

4,662

24

18,648

$138,927.60

47 CFR § 64.4002(b)

1165 LECs

1.13

1,316

68

79,220

$39,216.80


777 LECs

4.27

3,318

32

24,864

$98,876.40

47 CFR § 64.4002(c)

1165 LECs

1.30

1,515

8

9,320

$45,147.00


777 LECs

1.30

1,010

4

3,108

$30,098.00

47 CFR § 64.4002(d)

1165 LECs

2.75

3,204

55

64,075

$95,479.20


777 LECs

6.60

5,128

33

25,641

$152,814.40

47 CFR § 64.4002(e)

1165 LECs

2.90

3,379

80

93,200

$100,694.20


777 LECs

7.30

5,672

40

31,080

$169,025.60

47 CFR § 64.4002(f)

1165 LECs

1.00

1,165

20

23,300

$34,717.00


777 LECs

2.50

1,943

10

7,770

$57,901.40

47 CFR § 64.4002(g)

1165 LECs

0.825

961

15

17,475

$28,637.80


777 LECs

1.375

1,068

5

3,885

$31,826.40

47 CFR § 64.4002(h)

1165 LECs

0.75

874

15

17,475

$26,045.20


777 LECs

1.25

971

5

3,885

$28,935.80

Totals



38,050


478,866

$1,133,890.00


47 CFR § 64.4003(a)

268 IXCs

4.98

1,335

30

8,040

$39,783.00

47 CFR § 64.4003(b)

300 IXCs

5.00

1,500

20

6,000

$45,700.00

Totals



2,835

14,040

$85,483.00

Total Report and Order Information Collection Requirements



40,885


492,906

$1,219,373.00


Cumulative Totals for the Information Collection Requirements


Cumulative Total Number of Respondents: 1,942 LECs + 300 IXCs = 2,242 respondents


Cumulative Total Number of Responses: 492,906 responses


Cumulative Total Annual Burden Hours: 40,885 hours


Cumulative Total In-House Cost: $1,219,373.00


13. The following represents the Commission’s estimate of annual cost burden to respondents’ resulting from the collections of information:


(a) Total annualized capital/start-up costs: $0.00


(b) Total annual costs (operations and maintenance): $0.00


(c) Total annualized costs requested: $0.00


The Commission anticipates that the respondents will not incur any new capital or start-up costs and most will be inclined to continue to hire in-house staff to perform these functions:


  1. It is unclear how many respondents currently use or in the future may hire third parties to provide their intercarrier notifications.


(ii) The Commission estimates, however, that the potential cost to the respondents, whether they perform the requirements in-house or hire a third party to perform this function, will be roughly the same.


In particular, although smaller entities may be more likely to use labor-intensive manual processes rather than automated processes, they also may have limited staff resources to perform these functions.

Because of limited staffing, certain smaller entities may elect to use third party clearinghouses, which use automated processes to provide the required notifications.


Although no data is available to establish the precise cost of using a third-party clearinghouse, the Commission estimates that the cost to provide the notifications in-house using manual processes may be approximately the same as hiring a third party to perform the same functions using automated processes.


14. The information collections contained in the CARE rules result in no costs to the Federal government.


15. The information collection is necessary to ensure the seamless provision of services and establishes carriers’ responsibilities with respect to those exchanges.


Due to the revised estimates of the number of LECs and IXCs operating in the United States, and to the Commission’s re-evaluation of the percentage of those carriers which require more time to make the required notifications, the Commission now estimates:


the total number of respondents increased by +464, from 1,778 to 2,242 respondents, the total number of responses increased by +59,866, from 433,040 to 492,906 responses, and the total annual burden hours increased by +1,045, from 39,840 to 40,885 hours;


There are no programs changes.


16. There are no plans to publish the result of the collection of information.


  1. The Commission does not intend to seek approval not to display the expiration date for OMB approval of this information.


18. On February 25, 2010, the Commission published a 60 day Federal Register Notice (Notice) in the Federal Register at 75 FR 8703 (February 25, 2010). In its Notice, the Commission stated that the type of review for this collection will be a “Revision of a currently approved collection.” The Commission corrects the type of review to read as an “Extension of a currently approved collection.” There are no exceptions to the Certification Statement.

B. Collections of Information Employing Statistical Methods.


The Commission does not anticipate that the collection of information will employ statistical methods.


1 Throughout this information collection requirement submission, the Commission will be referring to incumbent local exchange carriers (ILECs), competitive local exchange carriers (CLECS) as local exchange carriers (LECs), and (IXCs) as interexchange carriers.


2 See FCC, Wireline Competition Bureau, Industry Analysis and Technology Division, “Trends in Telephone Service” at Table 5.5, Pages 5-5 (August 2008).

3 Id. at Table 5.3, Pages 5-5.

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File Typeapplication/msword
File Title3060-0519
AuthorDavid Marks
Last Modified Bycathy.williams
File Modified2010-04-27
File Created2010-03-19

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