Supporting Statement OMB 3060-1059 January 2013

OMB Control No: 3060-1059

Global Mobile Personal Communications

by Satellite (GMPCS)/E911 Call Centers

January 2013

SUPPORTING STATEMENT

A. Justification:

1. The Federal Communications Commission ("Commission") is requesting a three-year extension of the information collection titled, “Global Mobile Personal Communications by Satellite (GMPCS)/E911 Call Centers,” under OMB Control No. 3060-1059.

Rulemaking

On August 25, 2004, the Commission released a Second Report and Order titled, "Revision of the Commission’s Rules to Ensure Compatibility With Enhanced 911 Emergency Calling Systems; Amendment of Parts 2 and 25 to Implement the Global Mobile Personal Communications by Satellite (GMPCS) Memorandum of Understanding and Arrangements; Petition of the National Telecommunications and Information Administration (NTIA) to Amend Part 25 of the Commission’s Rules to Establish Emissions Limits for Mobile and Portable Earth Stations Operating in the 1610-1660.5 MHz Band," CC Docket No. 94-102; IB Docket No.

99-67, FCC 04-201. (This rulemaking is hereinafter referred to as the “E911 Scope Second R&O”).

Annual Reporting Requirement and Recordkeeping Requirement

Post-Implementation Status Reports

In the E911 Scope Second R&O, the Commission concluded that Mobile Satellite Service (MSS) carriers that operate in the 1.6/2.4 GHz and 2 GHz bands must file annual reports with the Commission beginning October 15, 2005 and MSS carriers that operate in other bands

(e.g., L-band) will submit their first annual report on June 30, 2006 pursuant to 47 CFR 25.284. The reports will include carrier and call center contact information, the aggregate number of calls received by the call center each month during the relevant reporting period, and the number of those calls that required forwarding to a Public Safety Answering Points (PSAP). The MSS carriers' filing of post-implementation status reports with the Commission annually will help the Commission to monitor compliance with the call center requirement and determine whether modification to the requirement is warranted. Records of the reports must also be kept by respondents.

The Commission has authority for this information collection pursuant to Sections 1, 4(i), 7, 10, 201, 202, 208, 214, 222(d)(4)(A)-(C), 222(f), 222(g), 222(h)(1)(A), 222(h)(4)-(5), 251(e)(3), 301, 303, 308 and 310 of the Communications Act of 1934, as amended; 47 U.S.C. Sections 151, 154(i), 157, 160, 201, 202, 208, 214, 222(d)(4)(A)-(C), 222(f), 222(g), 222(h)(1)(A), 222(h)(4)-(5), 251(e)(3), 301, 303, 308 and 310.

This information collection does not affect individuals or households; thus, there are no impacts under the Privacy Act.

2. The information collections that result from the E911 Scope Second R&O are used by the Commission under its authority to license commercial satellite services in the United States. Without the collection of information that would result from these rules, the Commission would not be able to monitor the MSS carriers’ establishment of call centers which are essential to provide emergency services, such as handling emergency 911 telephone calls from American citizens. The recordkeeping and reporting requirements include data on MSS call center use such as the aggregate number of calls that the call centers receive and the number of calls that required forwarding to a local PSAP. The Commission will use this data to monitor compliance with the call center requirement and track usage trends. Such information would be useful to the Commission in considering whether FCC rules require modification to accommodate the changing market.

3. The OMB approved the mandatory electronic filing of annual post-implementation status reports. This Supporting Statement reflects that 100 percent of documents are filed with the Commission electronically.

4. The information in this collection is not duplicated elsewhere and similar information is not available.

5. The Commission sought comment from the public on the potential impact of the Commission’s rules on small entities during the NPRM stage of the rulemaking process.

Small businesses are not likely to have the financial ability to become MSS system operators because of the high implementation costs, including construction of satellite space stations and rocket launch, associated with satellite systems and services. The Commission requested comment on the number and identity of small entities that would be significantly impacted by the rule changes. Furthermore, the agency sought comment on whether the rules would have a disproportionate impact on small entities. Additionally, the Commission sought comment generally on steps that it can take to ensure that small entities are not disproportionately impacted, if any such steps are necessary. The agency did not receive comments from the public that indicated that the rule changes would adversely impact small entities.

6. The rules require that MSS carriers file a post-implementation report with the Commission annually and maintain record of this report. Without the collection of information, the Commission would not be able to confirm the MSS carriers' compliance with the call center rules. Additionally, the agency would not have data on MSS call center use in order to determine whether the Commission should modify its rules to accommodate the current market.

7. The collection of information will not be conducted in any manner known to be inconsistent with the guidelines stipulated in 5 C.F.R. 1320.

8. On September 11, 2012, the Commission published a 60-day notice in the Federal Register

(FR Cite 77 FR 55838) to solicit comments from the public on the extension of this information collection. The comment period ended on November 13, 2012. No comments were received from the public.

9. The Commission will not provide any payment or gift to respondents for fulfilling their information collection requirements.

10. The Commission does not provide assurances of confidentiality to entities submitting their filings to the Commission. However, entities may request confidential treatment of their applications and filings under 47 C.F.R. 0.459 of the Commission's rules. With regard to certifications filed pursuant to Part 2 of the Commission's rules, parties receive minimal exemption from the Freedom of Information Act (FOIA).

11. The collection does not ask questions of a sensitive nature.

12. The Commission estimates that there are approximately 25 Mobile Satellite Service (MSS) carriers. The estimated time per response is one (1) hour for the annual post-implementation status reports and maintaining copies of these reports in respondents’ files.

Total Number of Respondents: 25 MSS Carriers

Total Number of Annual Responses: 25 status reports per year

Total Annual Burden Hours: 25 status report/year x 1 hour/report = 25 hours

13. Respondents will also require one hour of outside legal assistance with the reports at $300/hour. Therefore, the costs for outside legal consultants are as follows:

25 status reports x $300/hour for outside legal consultants x 1 hour per report = $7,500 per year

14. It is estimated that attorneys and analysts will be involved in the review and processing of an average of 25 submissions of the status reports per year. It is estimated that the attorneys will

spend a total of two hours reviewing each report and the analysts will spend a total of one hour reviewing each report. A breakdown of costs to the agency is as follows:

Federal Government	Total	Hours to Review	Annual	Hourly Salary	Total
Staff	Reports	Each Submission	Hours	(Step 5)	Salary
GS-14/Step 5 Attorneys	25	2 hrs. of legal review/report	50	$57.13	$2,856.50
GS-11/Step 5 Analysts	25	1 hr. of review per report by analysts	25	$33.92	$ 848.00
					$3,704.50

15. There are no program changes or adjustments to this information collection.

16. The data will not be published for statistical use.

17. We do not seek approval to not display the expiration date of OMB approval of the collection.

18. There are no exceptions to this certification statement.

B. Collections of Information Employing Statistical Methods:

No statistical methods are employed.

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