3060-0848_SS_1_2015 (final2)

Deployment of Wireline Services Offering Advanced 3060-0848

Telecommunications Capability, CC Docket No. 98-147 January 2015

SUPPORTING STATEMENT

This submission is being made as an extension to an existing information collection pursuant to 44 U.S.C. § 3507 to the Office of Management and Budget (OMB) in order receive the full three-year approval.

1. Justification:

1. The following collections of information implement Section 251 of the Communications Act of 1934, as amended. In CC Docket Nos. 98-147 and 96-98, the Commission sought to further Congress’s goal of promoting innovation and investment by all participating in the telecommunications marketplace, in order to stimulate competition for all services, including advanced services. In furtherance of this goal, the Commission imposed certain collections of information on incumbent local exchange carriers (LECs) in order to ensure compliance with the incumbent LECs’ collocation obligations and to assist incumbent LECs in protecting network integrity.

a. Processing of Collocation Applications. Where neither the state nor the parties to an interconnection agreement set a different deadline, an incumbent LEC must tell the requesting telecommunications carrier whether a collocation application has been accepted or denied within ten calendar days after receiving the application. If the incumbent LEC deems that application unacceptable, it must advise the competitive LEC of any deficiencies within the ten calendar-day period. The incumbent LEC must provide sufficient detail so that the requesting carrier has a reasonable opportunity to cure each deficiency. The competitive LEC must cure any deficiencies in its collocation application and resubmit the application within 10 calendar days after being advised of them. The requesting carrier must inform the incumbent LEC that physical collocation should proceed within seven calendar days after receiving the incumbent LEC’s price quotation. See 47 CFR Section 51.323(l).

b. Amendment of Collocation Agreements, Collocation Tariffs, and Collocation-Related Provisions in Statements of Generally Available Terms. An incumbent LEC must offer to provide all forms of physical collocation (i.e., caged, cageless, shared, and adjacent) in accordance with the Commission’s application processing and provisioning interval requirements, except to the extent a state sets its own application processing and collocation interval deadlines. To make an offer to provide physical collocation, an incumbent LEC must propose in response to a request from a competitive LEC an interconnection agreement or an amendment to an interconnection agreement including all necessary rates, terms, and conditions. The incumbent LEC also must file with the state commission proposed amendments to any tariff or statement of generally available terms and conditions that does not comply with the national standards for processing collocation applications and provisioning collocation arrangements. These amendments must provide for application processing intervals and physical collocation intervals no longer than the national standards except to the extent a state sets its own standard. See Order on Reconsideration, paragraph 36.

c. State Commission Approval. If collocation becomes available in a previously exhausted incumbent LEC structure, the incumbent LEC must obtain the state commission’s express approval before requiring a competitive LEC to move, or prohibiting a competitive incumbent LEC from moving, a collocation arrangement into that structure, unless the incumbent LEC and the collocation have an interconnection agreement that expressly provides for a different outcome. See Order on Reconsideration, paragraph 46. Safe-time work practices that the incumbent may waive to keep from competitively disadvantaging its or an affiliate’s operations or that prevents a collocator from restoring service in the event of an outage are inherently suspect and must receive explicit state commission approval. See Order on Reconsideration, paragraph 60.

d. Showing Regarding Loop Condition. Incumbent LECs that refuse a competitive carrier’s request to condition a loop must make an affirmative showing to the relevant state commission that conditioning the specific loop in question will significantly degrade voiceband services. The incumbent LEC must also show that there is no adjacent or alternative loop available that can be conditioned or to which the customer’s service can be moved to enable line sharing. See 47 CFR Section 51.319(h)(5).

e. Showing of Significant Degradation. An incumbent LEC may not deny a carrier’s request to deploy a technology that is presumed acceptable for deployment unless the incumbent LEC demonstrates to the relevant state commission that deployment of the particular technology will significantly degrade the performance of other advanced services or traditional voiceband services. Where a carrier seeks to establish that deployment of a technology falls within the presumption of acceptability under 47 CFR 51.230(a)(3), the burden is on the requesting carrier to demonstrate to the state commission that its proposed deployment meets the threshold for a presumption of acceptability and will not, in fact, significantly degrade the performance of other advanced services or traditional voice band services. Upon a successful demonstration by the requesting carrier before a particular state commission, the deployed technology shall be presumed acceptable for deployment in other areas. See 47 CFR Sections 51.230(b) and (c).

f. Information on Type of Technology. A requesting carrier that seeks access to a loop or a high frequency portion of a loop to provide advanced services must provide to the incumbent LEC information on the type of technology that the requesting carrier seeks to deploy. Where the requesting carrier asserts that the technology it seeks to deploy fits within a generic power spectral density mask, it also must provide Spectrum Class information for the technology. Where a requesting carrier relies on a calculation-based approach to support deployment of a particular technology, it must provide the incumbent LEC with information on the speed and power at which the signal will be transmitted.

The requesting carrier also must provide the information required above when notifying the incumbent LEC of any propose change in advanced services technology that the carrier uses on the loop. See 47 CFR Sections 51.231(b)‑(c).

g. Petition. Any party seeking designation of a technology as a known disturber should file a petition for declaratory ruling. See 47 CFR Section 51.232(b).

h. Showing of Network Harm. Where a deployed advanced service is significantly degrading other services and the degradation remains unresolved by the deploying carrier(s) after a reasonable opportunity to correct the problem, the carrier whose services are being degraded must establish before the relevant state commission that a particular technology deployment is causing the significant degradation. Any claims of network harm presented to the deploying carrier(s) or, if subsequently necessary, the relevant state commission, must be supported with specific and verifiable information. See 47 CFR Sections 51.233 (b) and (c).

i. List of Equipment, Affidavit - Whenever an incumbent LEC objects to collocation of equipment by a requesting telecommunications carrier for the purposes within the scope of section 251(c)(6) of the Act, the incumbent LEC shall prove to the state commission that the equipment is not eligible for collocation. An incumbent LEC that denies collocation of a competitor's equipment, citing safety standards, must provide to the competitive LEC within five business days a list of all equipment that the incumbent LEC locates within the premises in question, together with an affidavit attesting that all of that equipment meets or exceeds the safety standard that the incumbent LEC contends the competitor's equipment fails to meet. In the Order on Reconsideration, the Commission required that this affidavit set forth in detail: the exact safety requirement that the requesting carrier’s equipment does not satisfy; the incumbent LEC’s basis for concluding that the requesting carrier’s equipment does not meet this safety requirement; and the incumbent LEC’s basis for concluding why collocation of equipment not meeting this safety requirement would compromise network safety. See 47 CFR Section 51.323(b).

j. Space Limitation Documentation - An incumbent LEC shall submit to the state commission, subject to any protective order that the state commission deems necessary, detailed floor plans or diagrams of any premises where the incumbent LEC claims that physical collocation is not practical because of space limitations. An incumbent LEC that contends space for physical collocation is not available in an incumbent LEC premises must also allow the requesting carrier to tour the entire premises in question, not just the room in which space was denied, without charge, within ten days of the receipt of the incumbent LEC's denial of space. The Commission amended the rule in the First Report and Order to require that incumbent LECs allow competitive LECs to tour their facility. However, no new or modified paperwork requirements were made. In the Order on Reconsideration, the Commission required that each incumbent LEC provide the state commission with all information necessary for the state commission to evaluate the reasonableness of the incumbent LEC’s and its affiliates’ reservations of space for future growth. This information shall include any information the state commission may require to implement its specific space reservation policies, including which space, if any, the incumbent or any of its affiliates have reserved for future use. The incumbent shall also provide the state commission with a detailed description of the specific future uses for which the space has been reserved. An incumbent LEC shall permit any requesting telecommunications carrier to inspect any floor plans or diagrams that the incumbent LEC provides a state commission, subject to any nondisclosure protections the state commission deems appropriate. See 47 CFR Section 51.321(f). See also paragraph 57 in the Order on Reconsideration.

k. Report of Available Collocation Space - Upon request, an incumbent LEC must submit to the requesting carrier within ten days of the submission of the request a report indicating the incumbent LEC's available collocation space in a particular LEC premises. This report must specify the amount of collocation space available at each requested premises, the number of collocators, and any modifications in the use of the space since the last report. The incumbent LEC must maintain a publicly available document, posted for viewing on the Internet, indicating all premises that are full, and must update such a document within ten days of the date at which a premises runs out of physical collocation space. See 47 CFR Section 51.321(h). In the Order on Reconsideration, the Commission made clear that the incumbent LEC must provide this report within ten calendar days, as opposed to ten business days. See Order on Reconsideration, paragraph 64, page 32. In the Fourth Report and Order, the Commission required that this report describe in detail the space that is available for collocation in the particular premises. This description requirement should enable a carrier requesting collocation to request the space that best fits its operational needs. See 47 CFR Section 51.321(h).

l. Information on Security Training - An incumbent LEC must provide information to competitive LECs on the specific type of security training a competitive LEC's employees must complete in order for the incumbent LEC to maintain reasonable security measures for its equipment and networks. See 47 CFR Section 51.323(i)(3).

m. Access to Spectrum Management Procedures and Policies - An incumbent LEC must provide competitive LECs with nondiscriminatory access to the incumbent LEC's spectrum management procedures and policies. See 47 CFR Section 51.231(a).

n. Rejection and Loop Information - An incumbent LEC must disclose to requesting carriers information with respect to the rejection of the requesting carrier's provision of advanced services, together with the specific reason for the rejection. An incumbent LEC must also disclose to requesting carriers information with respect to the number of loops using advanced services technology within the binder and type of technology deployed on those loops. See 47 CFR Section 51.231(a).

o. Notification of Performance Degradation - If a carrier claims a service is significantly degrading the performance of other advanced services or traditional voice band services, then that carrier must notify the causing carrier and allow that carrier a reasonable opportunity to correct the problem. Any claims of network harm must be supported with specific and verifiable supporting information. See 47 CFR Section 51.233.

p. Certification of Interstate Traffic - In the Fourth Report and Order, the Commission required that an incumbent LEC provision cross-connects between collocated carriers upon reasonable request. A collocated carrier may request such provisioning pursuant to either section 201 or 251 of the Communications Act. An incumbent LEC, however, is not required to provide a connection between the equipment in the collocated spaces of two or more telecommunications carriers if the connection is requested pursuant to section 201 of the Act, unless the requesting carrier submits to the incumbent LEC a certification that more than 10 percent of the amount of traffic to be transmitted through the connection will be interstate. The certification requirement recognizes that the Commission’s jurisdiction under section 201 is subject to certain limits. Because the Commission’s jurisdiction under section 251 is not similarly limited, no such certification is required for a request for a cross-connect under section 251 of the Act. See 47 CFR Section 51.323(h).

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

The statutory authority for this collection is contained in: Sections 1-4, 201-03, 251-54, 256, and 303(r) of the Communications Act of 1934, as amended, 47 U.S.C. §§ 151-54, 201-03, 251-54, 256, and 303(r).

2. All of the collections will be used by the Commission and by competitive carriers to facilitate the deployment of advanced services and to implement section 251 of the Communications Act of 1934, as amended.

3. The means of compliance is primarily at the discretion of the carrier. The Commission does not prohibit the use of improved technology where appropriate. The Commission requires that incumbent LECs list on the Internet all premises that are full. See 47 CFR Section 51.321(h).

4. There will be no duplication of information. The information sought is unique to each carrier.

5. The collection of information burdens all incumbent LECs, many of which may be small entities. The Commission is committed to reducing the regulatory burdens on all respondents whenever possible, consistent with the Commission’s other public interest responsibilities.

6. If the information sought is not collected or is collected less frequently, it will delay implementation of section 251 of the Communications Act and may impede competition in the market for advanced services and other telecommunications services. This would violate the language and intent of the Telecommunications Act of 1996, which calls for deployment of advanced services “on a reasonable and timely basis,” and section 251, which requires incumbent LECs to provide physical collocation “on rates, terms, and conditions that are just, reasonable, and nondiscriminatory.”

7. Respondents may have to prepare a written response to a request of competitive carriers within 30 days of receipt. This is necessary to provide competitive carriers access to information in a nondiscriminatory and timely manner.

8. The Commission published a 60 Day Notice in the Federal Register on October 24, 2014 (79 FR 63624) as required by 5 CFR 1320.8(d). No comments were received as a result of this Notice.

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

10. The Commission is not requesting respondents to submit confidential information. Any respondent who submits information to the Commission that the respondent believes is confidential may request confidential treatment of such information under section 0.459 of the Commission's rules. See 47 C.F.R. §0.459.

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

12. The following represents the Commission's estimate of the annual hour burden of the collections of information. Additionally, each item is broken down in the Appendix at the end of this Supporting Statement:

(a) Processing of Collocation Applications:

(1) Number of respondents: 750

(2) Frequency of response: On occasion reporting requirement.

(3) Annual hour burden per respondent: 20 hours per respondent. Total annual burden = 15,000 hours.

(4) Method of estimation of burden: We estimate that it would take respondents approximately 2 hours to process each collocation application and to advise the requesting carrier of any deficiencies in the required level of detail. If each respondent processed 10 collocation applications annually, the annual burden would be 20 hours per respondent.

(5) Estimate of annualized cost to respondents for the hour burden for collection of information. $917,910. We assume the respondents use personnel comparable in pay to a GS-14/5 Federal employee including 5% for overhead to comply with the recordkeeping requirement. Thus cost is as follows: 20 hours per respondent x $58.28 per hour x 750 respondents = $917,910.

(b) Amendment of Collocation Agreements, Collocation Tariffs, and Collocation-Related Provisions in Statements of Generally Available Terms:

(1) Number of respondents: 750

(2) Frequency of response: On occasion reporting requirement and third party disclosure requirement.

(3) Annual hour burden per respondent: 8 hours per respondent. Total annual burden = 6,000 hours.

(4) Method of estimation of burden: We estimate that it would take respondents approximately 4 hours to renegotiate an interconnection agreement to comply with the Commission’s application processing and provisioning interval requirements and approximately 4 hours to prepare and file with the state commission any proposed amendments to a tariff or statement of generally available terms and conditions that does not comply with those requirements. Respondents, however, should have already implemented these requirements. If each respondent has one additional interconnection agreement, tariff, or statement of generally available terms that does not comply with the national standard, the annual burden would be 8 hours per respondent.

(5) Estimate of annualized cost to respondents for the hour burden for collection of information. $367,164. We assume the respondents use personnel comparable in pay to a GS-14/5 Federal employee including 5% for overhead to comply with the recordkeeping requirement. Thus cost is as follows: 8 hours per respondent x $58.28 per hour x 750 respondents = $367,164.

(c) State Commission Approval:

(1) Number of respondents: 750

(2) Frequency of response: On occasion reporting requirement.

(3) Annual hour burden per respondent: 2 hours. Total annual burden = 1,500 hours.

(4) Method of estimation of burden: It is difficult to estimate the annual burden on respondents. However, we estimate that respondents will take approximately 2 hours to comply with the requirements.

(5) Estimate of annualized cost to respondents for the hour burden for collection of information: $91,791. Assuming carriers use personnel comparable in pay to a GS-14/5 to comply with the requirement, the cost estimate, including 5% for overhead, is as follows: 750 respondents x 2 hours per respondent x $58.28 per hour = $91,791.

(d) Showing Regarding Loop Condition:

(1) Number of respondents: 750

(2) Frequency of response: On occasion reporting requirement.

(3) Annual hour burden per respondent: 2 hours. Total annual burden = 1,500 hours.

(4) Method of estimation of burden: It is difficult to estimate the annual burden on respondents. However, we estimate that respondents will take approximately 2 hours to comply with the requirements.

(5) Estimate of annualized cost to respondents for the hour burden for collection of information: $91,791. Assuming carriers use personnel comparable in pay to a GS-14/5 to collect, list and disburse this information, the cost estimate, including 5% for overhead, is as follows: 750 respondents x 2 hours per respondent x $58.28 per hour = $91,791.

(e) Showing of Significant Degradation:

(1) Number of respondents: 750

(2) Frequency of response: On occasion reporting requirement.

(3) Annual hour burden per respondent: 2 hours. Total annual burden = 1,500 hours.

(4) Method of estimation of burden: It is difficult to estimate the annual burden on respondents. However, we estimate that it will take respondents approximately 2 hours to comply with the requirements.

(5) Estimate of annualized cost to respondents for the hour burden for collection of information: $91,791. Assuming carriers use personnel comparable in pay to a GS-14/5 to comply with the requirement, the cost estimate, including 5% for overhead, is as follows:

750 respondents x 2 hours per respondent x $58.28 per hour = $91,791.

(f) Information on Type of Technology

(1) Number of respondents: 750

(2) Frequency of response: On occasion reporting requirement.

(3) Annual hour burden per respondent: 1.5 hours. Total annual burden = 1,125 hours.

(4) Method of estimation of burden: It is difficult to estimate the annual burden on respondents. However, we estimate that the respondents will take approximately 1.5 hours to comply with the requirement.

(5) Estimate of annualized cost to respondents for the hour burden for collection of information: $68,843. Assuming carriers use personnel comparable in pay to a GS-14/5 to comply with the requirement, the cost estimate, including 5% for overhead, is as follows: 750 respondents x 1.5 hours per respondent x $58.28 per hour = $68,843.

(g) Petition:

(1) Number of respondents: 25

(2) Frequency of response: On occasion reporting requirement.

(3) Annual hour burden per respondent: 1 hour. Total annual burden = 25 hours.

(4) Method of estimation of burden: It is difficult to estimate the annual burden on respondents. However, we estimate that it will take respondents 1 hour to comply with the requirements.

(5) Estimate of annualized cost to respondents for the hour burden for collection of information: $1,530. Assuming carriers use personnel comparable in pay to a GS-14/5 to comply with the requirement, the cost estimate, including 5% for overhead, is as follows: 25 respondents x 1 hour per respondent x $58.28 per hour = $1,530.

(h) Showing of Network Harm:

(1) Number of respondents: 50

(2) Frequency of response: On occasion reporting requirement.

(3) Annual hour burden per respondent: 2 hours. Total annual burden = 100 hours.

(4) Method of estimation of burden: It is difficult to estimate the annual burden on respondents. However, we estimate that it will take respondents 2 hours to comply with the requirements.

(5) Estimate of annualized cost to respondents for the hour burden for collection of information: $6,119. Assuming carriers use personnel comparable in pay to a GS-14/5 to comply with the requirement, the cost estimate, including 5% for overhead, is as follows:

50 respondents x 2 hours per respondent x $58.28 per hour = $6,119.

(i) List of Equipment:

(1) Number of respondents: 750

(2) Frequency of response: On occasion reporting requirement. Incumbent LECs should make information regarding changes in

equipment approved or used in providing collocation as such circumstances arise.

(3) Annual hour burden per respondent: 2 hours. Total annual burden = 1,500 hours.

(4) Method of estimation of burden: It is difficult to estimate the annual burden on respondents because it is unknown at this time whether incumbent LECs will make modifications to their collocation practices which would require additional information to be compiled. The annual burden will increase by one hour per carrier should carriers make such modifications.

(5) Estimate of annualized cost to respondents for the hour burden for collection of information: $91,791. Assuming carriers use personnel comparable in pay to a GS-14/5 to collect, list and disburse this information, the cost estimate, including 5% for overhead, is as follows: 750 respondents x 2 hours per respondent x $58.28 per hour = $91,791.

(j) Space Limitation Documentation:

(1) Number of Respondents: Approximately 20.

(2) Frequency of Response: On occasion reporting requirement.

(3) Annual hour burden per respondent: 26 hours. Total annual burden = 520 hours.

(4) Method of estimation of burden: This obligation arises when parties are unable to negotiate an agreement, and an incumbent LEC alleges that it is unable to satisfy a request for physical collocation because it is not practical for technical reasons or because of space limitations. It will also occur when an incumbent LEC objects to collocation of specific equipment because it alleges the equipment is not used for the purpose of obtaining interconnection or access to unbundled elements. We believe that a reasonable estimate is that, on average, incumbent LECs will have to make such a showing only once each year, as many potential disputes over these issues already have been resolved. We also believe it reasonable to estimate that, on average, incumbent LECs will take approximately 26 hours to resolve each dispute.

(5) Estimate of annualized cost to respondents for the hour burden for collection of information. $31,821. We assume the respondents use personnel comparable in pay to a GS-14/5, Federal employee including 5% for overhead to comply with the requirements. Thus cost is as follows: 20 respondents x 26 hours per respondent x $58.28 per hour = $31,821.

(k) Report of Available Collocation Space

(1) Number of respondents: 750

(2) Frequency of response: On occasion reporting requirement and third party disclosure requirement.

(3) Annual hour burden per respondent: 2 hours. Total annual burden = 1,500 hours.

(4) Method of estimation of burden: It is difficult to estimate the annual burden on respondents because it is unknown at this time how many competitive carriers will request this information, and for how many premises the competitive carriers will request information. It is assumed, however, that once a compilation of information is made, it can be released to all requesting carriers without any additional collection of information, placing a minimal burden on the incumbent. The actual hourly burden will rise or fall depending on the number of competitive carriers seeking information from a particular incumbent LEC and the breadth of their requests.

(5) Estimate of annualized cost to respondents for the hour burden for collection of information: $84,921 (rounded up). Assuming carriers use personnel comparable in pay to a GS-14/5 to design the notification statement and a GS-7/5 employee, including 5% for overhead, to transmit the notification, the cost estimate is as follows: (750 respondents x 1.75 hours per respondent x $58.28 per hour) + (750 respondents x 0.25 hours per respondent x $23.38 per hour) = $84,921.

(l) Information on Security Training:

(1) Number of respondents: 750

(2) Frequency of response: On occasion reporting requirement.

(3) Annual hour burden per respondent: 0.50 hours (30 minutes). Total annual burden = 375 hours.

(4) Method of estimation of burden: We estimate that it would take respondents approximately 30 minutes to comply with the security training information requirement.

(5) Estimate of annualized cost to respondents for the hour burden for collection of information. $22,948. We assume the respondents use personnel comparable in pay to a GS-14/5 Federal employee including 5% for overhead to comply with the requirement. Thus cost is as follows: 750 respondents x 0.50 hours per respondent x $58.28 per hour = $22,948.

(m) Access to Spectrum Management Procedures and Policies:

(1) Number of respondents: 750

(2) Frequency of response: On occasion reporting requirement.

(3) Annual hour burden per respondent: 0.50 hours (30 minutes). Total annual burden = 375 hours.

(4) Method of estimation of burden: We estimate that it would take respondents approximately 30 minutes to comply with the requirement.

(5) Estimate of annualized cost to respondents for the hour burden for collection of information. $22,948. We assume the respondents use personnel comparable in pay to a GS-14/5 Federal employee including 5% for overhead to comply with the requirement. Thus cost is as follows: 750 respondents x 0.50 hours per respondent x $58.28 per hour = $22,948.

(n) Rejection and Loop Information:

(1) Number of respondents: 750

(2) Frequency of response: On occasion reporting requirement.

(3) Annual hour burden per respondent: 1 hour per year per respondent. Total annual burden = 750 hours.

(4) Method of estimation of burden: We estimate that it would take respondents approximately 1 hour to comply with the requirements.

(5) Estimate of annualized cost to respondents for the hour burden for collection of information: $45,986. We assume the respondents use personnel comparable in pay to a GS-14/5 Federal employee including 5% for overhead to comply with the recordkeeping requirement. Thus cost is as follows: 750 respondents x 1 hour per respondent x $58.28 per hour= $45,986.

(o) Notification of Performance Degradation:

(1) Number of respondents: 750

(2) Frequency of response: On occasion reporting requirement.

(3) Annual hour burden per respondent: 0.50 hours (30 minutes). Total annual burden = 375 hours.

(4) Method of estimation of burden: We estimate that it would take respondents approximately 30 minutes to comply with the requirement.

(5) Estimate of annualized cost to respondents for the hour burden for collection of information: $21,855. Assuming carriers use personnel comparable in pay to a GS-14/5 Federal employee, the cost estimate is as follows: 750 respondents x 0.50 hours per respondent x $58.28 per hour = $21,855.

(p) Certification of Interstate Traffic:

(1) Number of respondents: 175.

(2) Frequency of response: On occasion reporting requirement.

(3) Annual hour burden per respondent: 4 hours. Total annual burden = 700 hours.

(4) Method of estimation of burden: It is difficult to estimate the annual burden on respondents because it is unknown at this time how often collocating carriers will request cross-connects pursuant to section 201. The time involved in providing any individual certification, however, is likely to be less than 15 minutes.

(5) Estimate of annualized cost to respondents for the hour burden for collection of information: $41,232. Assuming carriers use personnel comparable in pay to a GS-14/5 to design, including 5% for overhead, the customer approval solicitation device and a GS-7/5 employee, including 5% for overhead, to transmit the solicitation, the cost estimate is as follows: (175 respondents x 3.75 hours per respondent x $58.28 per hour) + (175 respondents x 0.25 hours per respondent x $23.38 per hour) = $41,232.

Summary:

Cumulative “In-House” Cost to the respondent (a-p):

$917,910+$367,164+$91,791+$91,791+$91,791+$68,843+$1,530+$6,119+$91,791+$31,821+

$84,921+$22,948+$22,948+$45,896+$21,855+$41,232= $2,000,351.

Total “In-House” Cost to the respondent (a-p): $2,000,351

Annual Burden: 15,000 hours + 6,000 hours + 1,500 hours + 1,500 hours + 1,500 hours + 1,125 hours + 25 hours + 100 hours + 1,500 hours + 520 hours + 1,500 hours + 375 hours + 375 hours + 750 hours + 375 hours + 700 hours = 32,845 hours.

Total Annual Burden for All Collections Under this Control Number = 32,845 hours.

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

(1) Total capital and start-up cost component (annualized over its useful life): $0. The requirements will not require the purchase of additional equipment.

(2) Total operation and maintenance and purchase of services component: $0. The requirements will not require the purchase of additional equipment.

Total Annual Cost = $0.

14. There will be few, if any, costs to the Commission because the collection requirements adopted in this order are essentially third party disclosure requirements and will not require review by the Commission in most instances.

15. The Commission is reporting an adjustment to the burden hours because the number of reporting entities has reduced. This burden falls on incumbent local exchange carriers (LECs). Over time, consolidation of incumbent LECs has reduced their number to from 1400 to approximately 750; therefore, the number of responses has been reduced to 750. The total number of annual responses has also been reduced from 17,340 to 9,720. The annual burden hours for this collection are now estimated to be down from 61,490 hours to 32,845 total annual burden hours.

With this submission, the Commission has made these adjustments to the number of respondents, responses and annual burden hours which are now reflected in the information collection requirements of this collection.

16. The Commission does not anticipate publishing any of the information collected pursuant to this order.

17. The Commission does not intend to seek approval not to display the expiration date of the information collections from the Office of Management and Budget (OMB).

18. 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.

Appendix to Item 12 of this Supporting Statement

	Brief Description of Requirements	Annual Respondents (#)	Annual Responses (#)	Time per Response (Hours)	Annual Burden (Hours)
a.	Processing of Collocation Applications	750	750	20	15,000
B.	Amendment of Collocation Agreements, Collocation Tariffs, and Collocation Provisions	750	750	8	6,000
C.	State Commission Approval	750	750	2	1,500
D.	Showing Regarding Loop Condition	750	750	2	1,500
E.	Showing of Significant Degradation	750	750	2	1,500
F.	Information on Type of Technology	750	750	1.5	1,125
G.	Petition	25	25	1	25
H.	Showing of Network Harm	50	50	2	100
I.	list of Equipment	750	750	2	1,500
J.	Space Limitation Documentation	20	20	26	520
K.	Report on Available Collocation space	750	750	2	1,500
L.	Information on Security Training	750	750	.50	375
M.	Access to Spectrum Mgmt. Procedures and Policies	750	750	.50	375
N.	Rejection and Loop Information	750	750	1	750
O.	Notification of Performance Degradation	750	750	.50	375
P.	Certification of Interstate Traffic	175	175	4	700
TOTAL		750	9,270	.50 – 26	32,845