0484_ss_072412

3060-0484

July 2012

The Commission is requesting the Office of Management and Budget (OMB) approval for a revision of this information collection. This information collection currently applies to voice and/or paging communications services provided by wireline, wireless, cable circuit-switched telephony, and satellite communications providers. The Commission has extended its rules on outage reporting to interconnected Voice over Internet Protocol (VoIP) services, which means that providers of this service will now be required to report information on significant outages,¹ and the collection requirements and burden estimates for interconnected VoIP will be new.

SUPPORTING STATEMENT

A. Justification:

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.

Beginning in 1992, the Commission has required telecommunications carriers (other than cellular and satellite carriers) to report significant disruptions to voice and paging communications services.² In 2004, by Report and Order, the Commission superseded the original reporting requirements, and created a new Part 4 of Title 47 of the Code of Federal Regulations (C.F.R.) to house the modified and expanded outage reporting requirements embodied in the existing service disruption rules.³ Among others, the Report and Order extended the reporting requirements to include disruptions to wireless and satellite communications: telecommunication providers - any voice and/or paging communications carried on any facilities owned, operated, leased, or otherwise utilized by wireline, wireless, and cable circuit-switched telephony.

On February 15, 2012, the Commission adopted a Report and Order in PS Docket No. 11-82, FCC 12-22, extending its Part 4 outage reporting requirements⁴ to interconnected VoIP. Specifically, the Commission extended mandatory outage reporting rules to facilities-based and non-facilities-based interconnected VoIP service providers, and applied the current Part 4 definition of “outage” to outages of interconnected VoIP service, covering the complete loss of service and/or connectivity to customers at least 30 minutes’ duration that potentially affects at least 900,000 user minutes of interconnected VoIP service and results in complete loss of service; or potentially affects any special offices and facilities such as 9-1-1 facility.

Collecting data on significant outages of interconnected VoIP services will help the Commission monitor compliance with the statutory 9-1-1 obligations of interconnected VoIP service providers, as well as help ensure the Nation’s current and future 9-1-1 systems are as reliable and resilient as possible both on a day-to-day basis and in times of major emergency. The Commission notes that consumers are increasingly relying on Internet Protocol (IP)-based technologies as substitutes for communications services provided by older communications technologies, and increasingly use interconnected VoIP services in lieu of traditional telephone service. As of December 31, 2010, 31 percent of the more than 87 million residential telephone subscriptions in the United States were users of interconnected VoIP providers⁵—an increase of 21 percent (from 22.4 million to 27.1 million) from the end of 2009;⁶ additionally, the Commission estimates that approximately 31 percent of residential wireline 9-1-1 calls are made using VoIP service.

2. Indicate how, by whom and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

The manner in which this information collection is to be used is to gather data of significant outages involving interconnected VoIP, as well as to continue to collect information from telecommunication providers: voice and/or paging communications provided by wireline, wireless, cable circuit-switched telephony, and satellite communications providers.

This information collection is administered by the FCC’s Public Safety and Homeland Security Bureau (PSHSB) which maintains an Internet Web site portal for the electronic submission of the required Outage Reports. In addition, provision is made for the submission of required data by other than electronic means in cases where electronic submission is not feasible.⁷ In cases where special offices and facilities (other than 911 offices and facilities) are affected, any reports from the National Communications System (NCS) are submitted within 120 minutes of an outage to the Commission's duty officer (a post staffed 24 hours a day) in the FCC's Communications and Crisis Management Center in Washington, DC.

In broad terms, the purpose of this information collection is to gather sufficient information regarding disruptions to telecommunications systems to facilitate FCC monitoring, analysis, and investigation of the reliability and security of interconnected VoIP, voice and paging communications service being provided by entities subject to the reporting requirements, and to identify and act on potential threats to our Nation’s telecommunications infrastructure.

In practice, the FCC actually uses this information collection to identify the duration, magnitude, root causes, contributing factors, and preventive measures taken with respect to significant outages, and to take swift remedial action as required in appropriate circumstances. The Commission also maintains an ongoing dialog with reporting entities, as well as with the communications industry at large, generally regarding lessons learned from the information collection in order to foster better understanding of the root causes of significant outages, and to explore preventive measures in the future so as to mitigate the potential impact of such outages on the Nation and the American public.

Furthermore, the information collected has been used by the Commission staff to determine weaknesses in communications network reliability and to formulate new tasks for the Communications Security Reliability and Interoperability Council, Federal Advisory Committee formed by the Commission to advise it on, inter alia, matters of network reliability.

The information collected may also be shared and coordinated with DHS in appropriate circumstances with respect to outages having a potential impact on public safety, national defense, and homeland security. As such, the outage reporting requirements are also essential to the FCC’s mission – as described more fully in Section 1, above – of fulfilling its statutory obligations under the Communications Act by ensuring the reliability and security of the nation’s telecommunications networks for the benefit of all Americans.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

The Commission’s outage reporting rules require that all Outage Reports are to be submitted electronically to the Commission.⁸ The mechanism for satisfying this electronic filing requirement entails entering the required information using Commission-approved Web-based outage report templates that are available online at the Commission’s Network Outage Reporting System (NORS) Internet Web portal. The completion of these online templates results in the information being electronically entered into the Commission’s NORS reporting data base in real-time.

In its Report and Order adopting the information collection, the Commission determined that Electronic filing would have several major advantages for the Commission, reporting communications providers, and the public.⁹ These advantages include:

• Providers would be able to file reports more rapidly and more efficiently.

• Information would be updated immediately. The expenses and efforts that are associated with the outage reporting process should be reduced substantially which, in turn, should result in continuing productivity gains.

• Changes to outage report data should be more easily accessible by communications providers and the Commission. Thus, reporting entities should be able to file initial and final report information more easily, and interested parties should also be able to access this information more quickly.

• Changes to electronic input form(s) can be implemented more quickly. Two purposes of the reliability database are to help identify causes of outages and to refine best practices for averting failures in communications networks. As networks evolve and experience is gained, the data fields can be more easily revised to improve the quality of the information received to reflect changes in communications infrastructures and management procedures.

• In addition, security precautions can be implemented to authenticate access by authorized users.

Information Collection Requirements

The rules set forth threshold criteria for determining when an outage is deemed reportable.¹⁰

Telecommunication Providers

The current mandatory reporting procedure requires three submissions to be transmitted electronically to the Commission by each affected provider for each reportable outage as follows:¹¹

(1) A bare-bones Notification (“Notification”) not later than 120 minutes after discovering a reportable outage,

(2) A more detailed Initial Communications Outage Report (“Initial Report”) not later than 72 hours after discovering a reportable outage, and

(3) A comprehensive Final Communications Outage Report (“Final Report”) not later than thirty days after discovering a reportable outage.

As noted above, the information provided in these submissions (collectively “Outage Reports”) enable the Commission to monitor developments affecting telecommunications reliability and security; to facilitate improvements in telecommunications reliability and security; and to serve as a source of information for the public.¹²

Statutory authority for this collection of information is authorized under 47 U.S.C. sections 151, 154(i), 154(j), 154(o), 218, 219, 230, 256, 301, 302(a), 303(f), 303(g), 303(j), 303(r), 403, 621(b)(3), and 621(d).

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

VoIP Providers:

With the objective of ensuring the availability of 9-1-1 service, this Report and Order mandates a reporting procedure that requires two submissions to be transmitted electronically to the Commission by each affected provider for each reportable outage as follows:

(1) Notification:

• 240 minutes of discovering that they have experienced on any facilities that they own, operate, lease, or otherwise utilize, an outage of at least 30 minutes duration that potentially affects a 9-1-1 special facility, in which case they also shall notify, as soon as possible by telephone or other electronic means, any official who has been designated by the management of the affected 9-1-1 facility as the provider’s contact person for communications outages at that facility;

• The provider shall convey to that person all available information that may be useful to the management of the affected facility in mitigating the effects of the outage on efforts to communicate with that facility; or

• 24 hours of discovering that they have experienced on any facilities that they own, operate, lease, or otherwise utilize, an outage of at least 30 minutes duration that:

• Potentially affects at least 900,000 user minutes of interconnected VoIP service and results in complete loss of service; or

• Potentially affects any special offices and facilities;¹³

(2) Final Communications Outage Report will be submitted electronically to the Commission not later than thirty days after discovering the outage.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in item 2 above.

The reporting requirement is not duplicated elsewhere. The annual quality of service reporting requirement (approved under OMB Control No. 3060-0395) to report downtime, trunk blockage, service quality complaints, dial tone response, and customer satisfaction does not contain the particular information collected here regarding the duration, magnitude, root cause, and preventive measures involved in significant telecommunications outages.

Furthermore, there is no source of contemporaneous 9-1-1 outage reporting data elsewhere available to the Commission. In addition, the Part 25 reporting requirements pertinent to satellite, communications providers and operators (e.g., OMB Control Nos. 3060-1007, and 3060-1013) do not provide the Commission with sufficiently timely or specific information regarding service disruptions. Nor do those reports require interconnected VoIP or satellite communication providers or operators to evaluate and report the apparent or known causes of service disruptions or the steps taken to restore service and to prevent further outages.

The reporting requirement has been carefully designed to require the reporting of only the data needed for the Commission to achieve its objectives of assuring the reliability and security of the nation’s telecommunications networks for the purposes of public safety and the national defense and security, including homeland security. If no reporting – or less frequent reporting ­– were to be required, outages having a detrimental effect on the public and outages and incidents that could provide valuable network reliability information could escape timely analysis by FCC monitoring efforts.

5. If the collection of information impacts small businesses or other small entities (item 5 of OMB Form 83-I), describe any methods used to minimize burden.

In order to limit the impact on small businesses or other small entities, the reporting requirement is subject to threshold criteria specified in the rules. As noted throughout the Report and Order, it is highly likely that all parties covered by these rules, including small businesses, already collect the information the Commission seeks because the have a strong interest to know the existence of and the circumstances behind a significant network outage. In the Commission’s view, establishing a generally-applicable reporting rule will promote both safety and network reliability.

Finally, the Commission’s experience suggests that few, if any, small interconnected VoIP providers will ever experience an outage that reaches the reportable threshold. Based on NORS data for the past seven years, only a handful of small entities ever have experienced an outage that reaches the 30 minutes/900,000 user minutes threshold in the FCC’s rules. Were a small interconnected VoIP provider to experience an outage of reportable impact, the availability of electronic filing and the elimination of one interim report originally proposed would help to minimize the burden of reporting to the Commission.

6. Describe the consequences to a Federal program or policy activity, if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reduce burden.

If no reporting – or different thresholds for reporting ­– were to be required, the Commission would be impeded from fulfilling its statutory obligations under the Communications Act¹⁴ to ensure the reliability and security of the nation’s telecommunications networks for the benefit of all Americans, in particular the availability of 9-1-1 service.

More specifically, the absence of – or less frequent – reporting would prevent the FCC from monitoring and analyzing significant outages and incidents that could provide valuable network reliability information that bear on public safety, homeland security, and national defense concerns. In addition, some of the data collected could constitute “Critical Infrastructure Information,” as defined in 6 U.S.C. §131, which may be shared with the Department of Homeland Security in furtherance of its missions to protect the United States from terrorist activity and to otherwise protect domestic security. Less frequent, or no, reporting could jeopardize these vital Federal programs and activities.

As noted above, if the information contained in the Outage Reports were not collected – or less frequently collected – the Commission would have considerably greater difficulty determining the state of network reliability and security in a timely manner. For example, it would be forced, instead, to depend on delayed, incomplete and second-hand analysis as a basis for recommending any future Commission action that might be needed to encourage carriers to enhance their reliability and security efforts. Furthermore, it would have difficulty determining the implementation and efficacy of its own and industry’s present and future recommendations for enhancing reliability and security. Finally, it would be less able to identify reliability and security weaknesses as they begin to appear in connection with rapidly evolving communications network technologies.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner inconsistent with the criteria listed in supporting statement.

This collection of information is consistent with the guidelines delineated in the instructions in that this will not be a general collection of information where carriers would be required to prepare a form at specific intervals, or to prepare a written response in less than 30 days after receipt of a form or request. Reporting is required only for outages that meet the threshold filing requirements. However, because the frequency of outages for each carrier cannot be predicted, respondents may be required to submit reports to the Commission more than once a quarter. Beyond this, there is no periodic reporting requirement. Thus, the requirement is “occasional.”

The benefits derived from the occasional reporting requirement, for which there is substantial need, are explained in the preceding paragraphs. As discussed above, service providers customarily gather the information collected for their own internal purposes. Thus, providing it to the Commission results in little additional burden.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice, required by 5 CFR 1320.8(d), soliciting comments on the information prior to submission to OMB.

-Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

The Notice of Proposed Rulemaking (“Notice”) in this proceeding requested comment on extending outage reporting under Part 4 of the Commission’s rules to interconnected VoIP services as well as to broadband Internet services. In addition, the Notice included a proposal to treat as outages both the complete loss of service and technical performance conditions that effectively prevent communication. Ultimately, based on the record developed in this proceeding, including in-person meetings with representatives of affected providers, the Commission extended mandatory outage reporting to only interconnected VoIP services and only for situations involving a complete loss of service. Furthermore, the Report and Order adopted in this proceeding on February 15, 2012, contained extensive discussion on the potential impact of information collections, in which the Commission analyzed in detail parties’ comments.¹⁵

Pursuant to 5 CFR Section 1320.8, the Commission published a 60 day notice which appeared in the Federal Register on May 3, 2012 (77 FR 26278). No PRA comments were received.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

No payment or gift to respondents has been or will be made.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

Outage reports filed pursuant to Part 4 of the Commission’s rules are presumed confidential.¹⁶ The information filings may be shared with the Department of Homeland Security only under appropriate confidential disclosure provisions. Other persons seeking disclosure must follow the procedures delineated in 47 C.F.R. Sections 0.457 and 0.459 of the Commission's rules for requests for and disclosure of information.

11. Provide additional justification for any questions of a sensitive nature.

As noted elsewhere herein, the information to be collected – particularly with respect to major communications disruptions – are potentially of a nature that constitutes “Critical Infrastructure Information,” as defined in 6 U.S.C. 131, which may be shared with the Department of Homeland Security in furtherance of its missions to protect the United States from terrorist activity and to otherwise protect domestic security. Such information is protected from routine disclosure under the Freedom of Information Act (FOIA). Furthermore, the information collected could also contain trade secrets which likewise are protected from routine disclosure under FOIA.

12. Provide estimates of the hour burden of the collection of information. The statement should: indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance.

Total Annual Burden combined – Part 4 Participants Excluding VoIP (12a) and VoIP only Providers (12b)

Number of respondents 118

Total annual responses 15,444

Total annual hours requested 29,647

Part 4 Participants Excluding VoIP (12a) and VoIP only Providers (12b) each have separate burden requirements; see 12a and 12b for breakdown and explanations.

12a. Part 4 Participants Excluding VoIP:

Total reporting costs to the respondents will be:

Total Number of Respondents: 80 respondents (this is the number of different carriers who provided outage reports in 2011).

Frequency of response: On occasion reporting requirements

Total Number of Responses Annually:

We estimate a total of 13,789 responses per year based on the number of responses in 2011. This is an average of 172 reports per respondent for the 80 respondents that had any outage reports. Most providers do not file any outage reports in a year. Most providers that do file an outage typically experience only one reportable outage per year. Most outage reports are filed by the large carrier providers.

80 carriers x 172 reports/annually = 13,789 responses

Total Annual Hourly Burden:

80 carriers x 172 reports/respondent/annually x 2 hours/report = 27,578 hours.

Method of estimation of burden: As described more fully above, the information submission that respondents must file with the Commission is made up of three components: a Notification that an outage has occurred, an Initial Report containing detailed information on the outage, and a Final Report containing detailed information concerning the outage and how it was resolved.

The method of burden estimation takes into consideration the fact that the information collected by the Commission is generally of the type that the respondents would routinely gather in the normal course of business as part of their internal outage diagnosis and restoration efforts. Accordingly, under 5 C.F.R. § 1320.3(b) (2), our estimates deduct that portion of the reporting analysis attributable to what respondents would normally do to identify and report on outages for their internal purposes. In addition, the time estimates are based on what is anticipated would be the actual time needed for data entry and submission – which, as just noted, does not include the underlying gathering and analysis of data that respondents routinely collect in the normal course of business. Finally, the Commission has also taken into account that all filings are to be made electronically, through a “fill in the blank” template, thereby minimizing the burden on all reporting entities.

Thus, it is estimated that reporting entities will ordinarily not need more than 15 minutes to file a Notification with the Commission. It is further estimated that the more detailed Initial Report that is required to be filed electronically 72 hours after the outage was discovered will ordinarily not take more than 45 minutes to complete and submit to the Commission. The Final Report that is required to be filed electronically 30 days after the outage was discovered must contain complete information regarding the outage, and must be submitted with an attestation to its accuracy and completeness. It is estimated that respondents will ordinarily not need more than one hour to complete and submit electronically the Final Report to the Commission.

In sum, it is estimated the total time needed to file all reports pertinent to each outage that meets or exceeds the reporting threshold criteria to be less than two (2) hours as follows:

15 minutes [Notification] + 45 minutes [Initial Report] + 1 hour [Final Report]

= 2 hours maximum (but, more likely, estimated to be approximately 1 to 1.5 hours).

This estimate is based on the assumptions that the 80 respondents file reports for 172 outages annually per respondent, using 2 hours per outage for preparing a Notification, an Initial and Final Report. These assumptions result in an overall estimated time for report preparation of 27,578 hours annually, as follows:

80 respondents x 172 reports annually/respondent x 2 hours/report = 27,578 hours

2b. VoIP only Providers:

The Commission believes the cost of complying with the new rules will be relatively low, particularly in light of the public benefit obtained from getting a complete picture of interconnected VoIP network reliability. Because the Commission adopted only a portion of its original proposal, the Commission is responding to those that expressed opinions on the effect of the rules on small providers. Further, interconnected VoIP respondents are subject to a reduced reporting burden (two filings per reportable outage instead of three).

Total reporting costs to the interconnected VoIP service provider respondents will be:

Total Number of Respondents: 38 carriers. There were a total of 38 respondents who provided wireline outage reports in 2011. Wireline outage reports are the closest analogue to VoIP outage reports. We assume that the number of respondents providing VoIP responses will be approximately the same as the number of respondents providing wireline reports. Note that at least half these respondents already provide outage reports.

Frequency of response: On occasion reporting requirements

Total Number of Responses Annually:

We estimate a total of 1,655 responses per year based on the number of wireline outage reports in 2011, the closest analogue to VoIP outages. This is an average of 44 reports per respondent for the 38 expected respondents.

38 carriers x 44 reports/annually = 1,655 responses

Total Annual Hourly Burden:

38 carriers x 44 reports/carrier/annually x 1.25 hours/report = 2,069 hours.

Method of estimation of burden: As described more fully above, the information submission that respondents must file with the Commission is made up of two components (Notification and Final):

Notification:

Providers submit electronically a Notification to the Commission within:

• 240 minutes of discovering that they have experienced on any facilities that they own, operate, lease, or otherwise utilize, an outage of at least 30 minutes duration that potentially affects a 9-1-1 special facility, in which case they also shall notify, as soon as possible by telephone or other electronic means, any official who has been designated by the management of the affected 9-1-1 facility as the provider’s contact person for communications outages at that facility;

• The provider shall convey to that person all available information that may be useful to the management of the affected facility in mitigating the effects of the outage on efforts to communicate with that facility; or

• 24 hours of discovering that they have experienced on any facilities that they own, operate, lease, or otherwise utilize, an outage of at least 30 minutes duration that:

• Potentially affects at least 900,000 user minutes of interconnected VoIP service and results in complete loss of service; or

• Potentially affects any special offices and facilities¹⁷

Final Communications Outage Report:

Providers submit electronically a Final Communications Outage Report to the Commission not later than thirty days after discovering the reportable outage.

Method of Burden:

The method of burden estimation takes into consideration the fact that the information collected by the Commission is generally of the type that the respondents would routinely gather in the normal course of business as part of their internal outage diagnosis and restoration efforts. Accordingly, under 5 C.F.R. § 1320.3(b) (2), our estimates deduct that portion of the reporting analysis attributable to what respondents would normally do to identify and report on outages for their internal purposes. In addition, the time estimates are based on what is anticipated would be the actual time needed for data entry and submission – which, as noted, does not include the underlying gathering and analysis of data that respondents routinely collect in the normal course of business. Finally, the Commission has also taken into account that all filings are to be made electronically, through a “fill in the blank” template, thereby minimizing the burden on all reporting entities.

Thus, it is estimated that reporting entities will ordinarily not need more than 15 minutes to file a Notification with the Commission. The Final Report that is required to be filed electronically 30 days after the outage was discovered must contain complete information regarding the outage, and must be submitted with an attestation to its accuracy and completeness. It is estimated that respondents will ordinarily not need more than one hour to complete and submit electronically the Final Report to the Commission.

In sum, it is estimated the total time needed to file all reports pertinent to each outage that meets or exceeds the reporting threshold criteria to be substantially less than one hour and fifteen minutes (1.25) hours as follows:

15 minutes [Notification] + 1 hour [Final Report] = 1.25 hours maximum (but, more likely, estimated to be approximately 1 to 1.5 hours).

This estimate is based on the assumptions that the 38 respondents file reports for 44 outages annually per respondent, using 1.25 hours per outage for preparing a Notification and a Final Report. These assumptions result in an overall estimated time for report preparation of 2,069 hours annually, as follows:

38 respondents x 44 reports annually/respondent x 1.25 hours/report = 2,069 hours.

Totals of items 12a and 12b: 80 + 38 respondents = 118 total respondents;

13,789 + 1,655 responses = 15,444 total responses;

27,578 + 2,069 hours = 29,647 total annual hours.

12c. Annual In House Costs:

From the preceding section, we estimate that outage reporting will result in 29,647 annual burden hours = 27,578 hours for non-VoIP outages + 2,069 hours for VoIP outages.

It is further estimated that each report will be prepared by a full-time employee who works 2080 hours annually and receives a yearly salary of $60,000.

Next, the total annual “In House” costs in salary for report preparation is computed as follows:

29,647 hours yearly / 2080 hours annual work time = 14.25 work years

$60,000 x 14.25 working years = $855,000

Total Annual “In House” Costs: = $855,000.

13. Provide estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in items 12 and 14).

The following represents the Commission’s estimate of the annual cost burden to respondents or recordkeeping resulting from the collection of information:

(a) Total capital and start up cost component (annualized over its useful life): $0.00. The requirement does not require the purchase of additional equipment.

(b) Total operation and maintenance and purchase of services: $0.00. The requirement will not result in additional operating and maintenance expenses, other than the hourly cost outlined above.

(c) Total annualized cost requested: $0.00

14. Provide estimates of annualized costs to the Federal government. Also provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expenses that would not have been incurred without this collection of information.

We estimate that the total annual cost to the Federal Government, based on the salaries of three engineers (GS-15 step 10), an engineer (GS-13 step 4), two engineers (GS-13 step 4), an attorney (GS-15 step 10), and an IT Developer (GS-15 step 8):

Each spends approximately ½ (1040 hours) of their work time each year on the information collected as follows:

(One) Attorney GS-15 step 10 at $74.51/hr wage. $74.51 x 1040 x 1 = $ 77,490.40

(Three) Engineers GS-15 step 10 at $74.51/hr wage. $74.51 x 1040 x 3 = $232,471.20

(One) IT Developer GS-15 step 8 at $73.14/hr wage. $73.14 x 1040 x 1 = $ 76,064.60

(Two) Engineers GS-13 step 4 at $46.93/hr wage. $46.93 x 1040 x 2 = $ 97,614.40

TOTAL $483,640.60

Total Annual Cost to the Federal Government: $483,640.60

15. Explain the reasons for any program changes or adjustments reported in items 13 or 14 of the OMB Form 83-I.

The total number of reports increased over the past two years. The number of respondents differed minimally over the two-year period that we used as the basis for our estimates. The Commission is reporting a 9,909 hour program change increase. This program change is due to an addition of new respondents (interconnected VoIP providers) now subject to the requirements in this collection which were adopted in FCC 12-22.

16. For collections of information whose results will be published, outline plans for tabulation and publication.

The FCC does not plan to publish the results of this information collection.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

The Commission does seek continued OMB approval to not display the OMB expiration date in the NORS database. This is in the Commission’s interest because each time this collection is submitted to the OMB for renewal or revision, the OMB expiration date would need to be updated. This is not cost effective or efficient. The Commission displays all OMB-approved collections in 47 CFR 0.408 of the Commission’s rules.

18. Explain any exceptions to the Certification Statement identified in Item 19, “Certification of Paperwork Reduction Act Submissions,” of OMB Form 83-I.

There are no exceptions to the Certification Statement.

B. Collections of Information Employment Statistical Methods:

This information collection does not employ any statistical methods.

1 “Outage” is defined by the Commission’s rules as a significant degradation in the ability of an end user to establish and maintain a channel of communication as a result of failure or degradation in the performance of a communications provider's network. See 47 C.F.R. Section 4.5 (a).

2 See former 47 C.F.R. Section 63.100 (2003) (first adopted in 1992). See “In the Matter of Notification by Common Carriers of Service Disruptions,” CC Docket No. 91-273, Report and Order, 7 FCC Rcd 2010 (1992); Memorandum Opinion and Order and Further Notice of Proposed Rulemaking, 8 FCC Rcd 8517 (1993); Second Report and Order, 9 FCC Rcd 3911 (1994); Order on Reconsideration of Second Report and Order, 10 FCC Rcd 11764 (1995).

3 See “In the Matter of New Part 4 of the Commission’s Rules Concerning Disruptions to Communications,” ET Docket No. 04-35, FCC 04-188, Report and Order and Further Notice of Proposed Rule Making, 19 FCC Rcd 16830 (2004) (Report and Order).

4 47 C.F.R. Part 4.

5 See Local Telephone Competition: Status as of December 31, 2010, Industry Analysis and Technology Division, Wireline Competition Bureau, Federal Communications Commission (Oct. 2011), Figure 2 - Wireline Retail Local Telephone Service Connections by Technology and Customer Type as of December 31, 2010, http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db1007/DOC-310264A1.pdf (last visited Oct. 17, 2011).

6 See Local Telephone Competition: Status as of December 31, 2009, Industry Analysis and Technology Division, Wireline Competition Bureau, Federal Communications Commission (Jan. 2011), Figure 2 -Wireline Retail Local Telephone Service Connections by Technology and Customer Type as of December 31, 2009, http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-304054A1.pdf (last visited Oct. 17, 2011).

7 See 47 C.F.R. Section 4.11.

8 See 47 C.F.R. Section 4.11. In the event of technical impediments to using the Web-based system during the Notification stage, then a written Notification to the Commission by email, Fax, courier, or U.S. mail may alternatively be used.

9 See Report and Order, 19 FCC Rcd 16830, at ¶ 150.

10 See 47 C.F.R. Section 4.9. Under these criteria, submission of the Outage Reports described above is required for any outage of at least 30 minutes duration that also:

(1) Potentially affects at least 900,000 user minutes of telephony or paging service; or

(2) Affects at least 1,350 DS3 minutes; or

(3) Potentially affects any special offices and facilities (in accordance with paragraphs (a) - (d) of 47 C.F.R. Section 4.5); or

(4) Potentially affects a 911 special facility (as defined in paragraph (e) of 47 CFR section 4.5), in which case they also shall notify, as soon as possible by telephone or other electronic means, any official who has been designated by the management of the affected 911 facility as the provider’s contact person for communications outages at that facility, and they shall convey to that person all available information that may be useful to the management of the affected facility in mitigating the effects of the outage on callers to that facility.

In the case of wireless communications, criterion (1), above, is replaced by the criteria that the outage of at least 30 minutes duration is of a Mobile Switching Center (MSC) or potentially affects at least 900,000 user minutes of either telephony and associated data service or paging service. For providers of paging service solely, however, instead of criteria (1) – (3), above, the applicable criterion is that there is a failure of a switch for at least 30 minutes duration potentially affecting at least 900,000 user-minutes.

11 The Notification, Initial and Final Reports must be filed by persons authorized by the communications provider to prepare such submissions; and in the case of Final Reports, must include specific information about the outage, and must be attested to by authorized individuals for their truth, completeness, and accuracy. See 47 C.F.R. Section 4.11.

12 Information provided in the Notification must include:

(1) The name of the reporting entity;

(2) The date and time of onset of the outage;

(3) A brief description of the problem;

(4) The particular services affected;

(5) The geographic area affected by the outage; and

(6) A contact name and contact telephone number by which the Commission’s technical staff may contact the reporting entity.

The Initial Report must contain all pertinent information then available on the outage and shall be submitted in good faith. The Final Report must contain all pertinent information on the outage, including any information that was not contained in, or that has changed from that provided in, the Initial Report.

13 See 47 C.F.R. §4.5(b).

14 See Communications Act of 1934 (as amended) (“Communications Act”), 47 U.S.C. § 151 et seq.

15 See The Proposed Extension of Part 4 of the Commission’s Rules Regarding Outage Reporting

To Interconnected Voice Over Internet Protocol Service Providers and Broadband Internet Service

Providers, PS Docket No. 11-82, FCC 12-22, Report and Order (rel. Feb. 21, 2012).

16 See 47 C.F.R. Section 4.2.

17 See 47 C.F.R. §4.5(b).

16