Supporting Statement OMB 3060-1084 (2016)

3060-1084 April 2016

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.

2. 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.

6. 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. § 1320.5.

8. The Commission published a notice in the Federal Register pursuant to 5 CFR § 1320.8(d) on February 9, 2016 seeking comments from the public on the information collection requirements contained in this collection. See 81 FR 6859. 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.

2. 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.

11. 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 2,749 LECs operating in the United States.²

(b) Approximately 2,262 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 487 of the total 2,749 based on its understanding that:

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

2. Those LECs are not 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 2,262 LECs (respondents).

IXCs:

(a) Similarly, the Commission estimates that there are approximately 359 IXCs operating in the United States.³

(b) Approximately 317 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 42 of the total 359 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 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 359 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 317 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 359 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

2. 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 2,262 LECs, or approximately 1,357 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:

1,357 LECs (respondents) x 1.6 hours per year =2,171 hours

1,357 respondents x 48 notifications = 65,136 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: $23.72/hour) to process the notifications:

2,171 hours x $23.72 per hour = $51,496.12

The remaining 40% of the 2,262 LECS, or approximately 905 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:

905 LECs (respondents) x 6 hours per year = 5,430 hours

905 respondents x 24 notifications = 21,720 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: $23.72/hour) to process the notifications:

5,430 hours x $23.72 per hour = $128,799.60

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 2,262 LECs, or approximately 1,357 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:

1,357 LECs (respondents) x 1.13 hours per year = 1,533.41 (1,533 hours)

1,357 respondents x 68 notifications = 92,276 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: $23.72/hour) to process the notifications:

1,533 hours x $23.72 per hour = $36,362.76

The remaining 40% of the 2,262 LECs or 905 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:

905 LECs (respondents) x 4.27 hours per year = 3,864.35 (3,864 hours)

905 respondents x 32 notifications = 28,960 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) to process the notifications. The Commission estimates respondents’ cost to be about $23.72 per hour.

3,864 hours x $23.72 per hour = $91,654.08

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 2,262 LECs, or approximately 1,357 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:

1,357 LECs (respondents) x 1.3 hours per year = 1,764.1 (1,764 hours)

1,357 respondents x 8 reject notifications = 10,856 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) to process the reject notifications. The Commission estimates respondents’ cost to be about $23.72 per hour.

1,764 hours x $23.72 per hour = $41,842.08

The remaining 40% of the 2,262 LECs, or 905 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:

905 LECs (respondents) x 1.3 hours per year = 1,176.5 (1,177 hours)

905 respondents x 4 reject notifications = 3,620 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) to process the notifications. The Commission estimates respondents’ cost to be about $23.72 per hour.

1,177 hours x $23.72 per hour = $27,918.44

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 2,262 LECs, or approximately 1,357 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:

1,357 LECs (respondents) x 2.75 hours per year = 3,731.75 (3,732 hours)

1357 respondents x 55 notifications = 74,635 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: $23.72/hour) to process the notifications:

3,732 hours x $23.72 per hour = $88,523.04

The remaining 40% of the 2,262 LECs, or 905 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:

905 LECs (respondents) x 6.6 hours per year = 5,973 hours

905 respondents x 33 notifications = 29,865 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: $23.72/hour) to process the notifications:

5,973 hours x $23.72 per hour = $141,679.56

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 2,262 LECs, or approximately 1,357 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:

1,357 LECs (respondents) x 2.9 hours per year = 3,935.3 (3,935 hours)

1,357 respondents x 80 notifications = 108,560 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) to process the notifications. The Commission estimates respondents’ cost to be about $23.72 per hour.

3,935 hours x $23.72 per hour = $93,338.20

The remaining 40% of the 2,262 LECs, or approximately 905 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:

905 LECs (respondents) x 7.3 hours per year = 6,606.5 (6,607 hours)

905 respondents x 40 notifications = 36,200 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/Step 5: $23.72/hour) to process the notifications:

6,607 hours x $23.72 per hour = $156,718.04

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 2,262 LECs, or approximately 1,357 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:

1,357 LECs (respondents) x 1 hour per year = 1,357 hours

1,357 respondents x 20 notifications = 27,140 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: $23.72/hour) to process the notifications:

1,357 hours x $23.72 per hour = $32,188.04

The remaining 40% of the 2,262 LECs, or approximately 905 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:

905 LECs (respondents) x 2.5 hours per year = 2,262.5 (2,263 hours)

905 respondents x 10 notifications = 9,050 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: $23.72/hour) to process the notifications:

2,263 hours x $23.72 per hour = $53,678.36

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 2,262 LECs, or approximately 1,357 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:

1,357 LECs (respondents) x 0.825 hours per year = 1,119.525 (1,120 hours)

1,357 respondents x 15 notifications = 20,355 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: $23.72/hour) to process the notifications:

1,120 hours x $23.72 per hour = $26,566.40

The remaining 40% of the 2,262 LECS, or approximately 905 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:

905 LECs (respondents) x 1.375 hours per year = 1,244.375 (1,244 hours)

905 respondents x 5 notifications = 4,525 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) to process the notifications. The Commission estimates respondents’ cost to be about $23.72 per hour.

1,244 hours x $23.72 per hour = $29,507.68

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 2,262 LECs or approximately 1,357 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:

1,357 LECs (respondents) x 0.75 hours per year = 1,017.75 (1,018 hours)

1,357 respondents x 15 notifications = 20,355 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: $23.72/ hour) to process the notifications:

1,018 hours x $23.72 per hour = $24,146.96

The remaining 40% or 905 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:

905 LECs (respondents) x 1.25 hours per year = 1,131.25 (1,131 hours)

905 respondents x 5 notifications = 4,525 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: $23.72/hour) to process the notifications:

1,131 hours x $23.72 per hour = $26,827.32

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 317 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:

317 IXCs (respondents) x 4.98 hours per year = 1,578.66 (1,579 hours)

317 respondents x 30 notifications = 9,510 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: $23.72/hour) to process the notifications:

1,579 hours x $23.72 per hour = $37,453.88

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 359 IXCs currently operating in the United States.

The Commission estimates 359 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:

359 IXCs (respondents) x 5 hours per year = 1,795 hours

359 respondents x 20 notifications = 7,180 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) to process the notifications. The Commission estimates respondents’ cost to be about $23.72 per hour.

1,795 hours x $23.72 per hour = $42,577.40

Rule Sections	Providers	Hours per Response	Total Hours per Year	Notifications	Notifications per Year	TotalTotal Total “In House” Costs
Information Collection Requirements
47 CFR § 64.4002(a)	1,357 LECs	1.6	2,171	48	65,136	$51,496.12
	905 LECs	6	5,430	24	21,720	$128,799.60
47 CFR § 64.4002(b)	1,357 LECs	1.13	1,533	68	92,276	$36,362.76
	905 LECs	4.27	3,864	32	28,960	$91,654.08
47 CFR § 64.4002(c)	1,357 LECs	1.3	1,764	8	10,856	$41,842.08
	905 LECs	1.3	1,177	4	3,620	$27,918.44
47 CFR § 64.4002(d)	1,357 LECs	2.75	3,732	55	74,635	$88,523.04
	905 LECs	6.6	5,973	33	29,865	$141,679.56
47 CFR § 64.4002(e)	1,357 LECs	2.9	3,935	80	108,560	$93,338.20
	905 LECs	7.3	6,607	40	36,200	$156,718.04
47 CFR § 64.4002(f)	1,357 LECs	1	1,357	20	27,140	$32,188.04
	905 LECs	2.5	2,263	10	9,050	$53,678.36
47 CFR § 64.4002(g)	1,357 LECs	0.825	1,120	15	20,355	$26,566.40
	905 LECs	1.375	1,244	5	4,525	$29,507.68
47 CFR § 64.4002(h)	1,357 LECs	0.75	1,018	15	20,355	$24,146.96
	905 LECs	1.25	1,131	5	4,525	$26,827.32
Totals			44,319		557,778	$1,051,246.68

47 CFR § 64.4003(a)	317 IXCs	4.98	1,579	30	9,510	$37,453.88
47 CFR § 64.4003(b)	359 IXCs	5	1,795	20	7,180	$42,577.40
Totals			3,374		16,690	$80,031.28
Total Report and Order Information Collection Requirements			47,693		574,468	$1,131,277.96

Cumulative Totals for the Information Collection Requirements

Cumulative Total Number of Respondents: 2,262 LECs + 359 IXCs = 2,621 respondents

Cumulative Total Number of Responses: 574,468 responses

Cumulative Total Annual Burden Hours: 47,693 hours

Cumulative Total In-House Cost: $1,131,277.96

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:

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

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

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

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.

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 5.3, Pages 5-5 (September 2010).

3 Id..

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