Dirs 3060-1003 Ss (062018)

Communications Disaster Information Reporting System (DIRS) 3060-1003

June 2018

SUPPORTING STATEMENT

1. Justification:

1. Explain in detail the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Provide a copy of the appropriate section of each statue and regulation mandating or authorizing the information collection.

The Disaster Information Reporting System (DIRS) is an electronic, voluntary, information collection program that is designed to inform the Federal Communications Commission (Commission) of the status of communications infrastructure, provide situational awareness, and facilitate requests for resource restoration support during times of crisis. The Commission works with the Department of Homeland Security’s (DHS) Federal Emergency Management Agency (FEMA) to identify a designated area to activate the DIRS information collection, and the information collected is often shared with key government stakeholders. Entities that report the status of communications infrastructure through DIRS include: wireless, wireline, broadcast, cable, satellite, interconnected Voice over Internet Protocol, and broadband communications providers.

The creation and implementation of DIRS builds on the Commission’s longstanding commitment to promoting the safety of life and property through the use of wire and radio communication, as required by the Communications Act of 1934, as amended.¹ DIRS also complements the efforts of the DHS’s National Communications System (NCS) in support of NCS’s role as the primary agency for Emergency Support Function-2 (ESF-2) of the National Response Plan (NRP).² Finally, DIRS addresses many of the recommendations submitted by the Independent Panel Reviewing the Impact of Hurricane Katrina on Communications Networks, regarding the collection of disaster-related outage and other situational awareness information.³

DIRS

The DIRS collection supports the Commission’s goal to capture status information of crucial infrastructure and network elements in designated major disaster areas during and after natural disasters, and situational awareness information that would otherwise be unavailable quickly to the Commission.

The DIRS collection is separate from the mandatory reporting requirements that apply to certain communications providers under Part 4 of the Commission’s rules, 47 C.F.R Part 4. Since June 2009, the Federal Communications Commission’s Public Safety and Homeland Security Bureau has provided a waiver of the Part 4 mandatory network outage reporting obligations of the Commission’s rules on a limited basis during DIRS activation periods.⁴

DIRS-Lite

During smaller-scale disasters, the Commission activates DIRS-Lite, a limited version of the DIRS collection mentioned above to reduce the burden on respondents but also maintain visibility in critical communications assets.⁵ The Commission designates the DIRS-Lite disaster areas at the request for information from a federal agency, including the Chairman of the Commission.⁶ For DIRS-Lite, only DIRS wireline and wireless carrier respondents are asked to provide a set of information to the Commission, and this submission may be done by email or through phone calls.⁷ Unlike the full DIRS activation, the DIRS-Lite activation does not supersede the Part 4 mandatory network outage reporting obligations of the Commission’s rules.

Statutory authority for this collection of information is contained in 47 U.S.C. 154(i), 218, 303(r) and 47 CFR Section 0.181(h).

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

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 Commission, as a supporting agency for the NRP ESF-2, coordinates with the DHS in the data collection design and needs as part of the DHS’s role as the primary agency for ESF-2. Specifically, the emergency contact, communications infrastructure, and network damage information data gathered through voluntary submissions in the DIRS collection is, and will continue to be, utilized during major disasters or crises that result in communication disruptions. Collection respondents  wireless, wireline, broadcast, cable, interconnected VoIP, broadband, and satellite communications providers  enter appropriate emergency contact information and infrastructure damage status information into the electronic DIRS database. In the event of an emergency, the Commission may also contact the respondents.

The DIRS collection supports the Commission’s goal to capture status information of crucial infrastructure and network elements in designated disaster areas during and after natural disasters to fulfill its longstanding commitment to promoting the safety of life and property through the use of wire and radio communication, as required by the Communications Act of 1934, as amended.⁸ The DIRS collection helps the Commission obtain consistent data from companies in each segment of the communications sector in the designated area during and after a disaster. Through the DIRS collection, the Commission also tracks disaster recovery efforts and their effectiveness over time and provides situational awareness to the federal agencies associated with or working on disaster restoration. The collection helps the Commission and DHS, as appropriate, identify the most affected areas during a disaster and aid in restoration effort coordination.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical or other technological techniques or other forms of information technology, e.g., permitting electronic submissions of responses, and the basis for the decision for adopting this means of collection.

Describe any consideration given to the use of improved information technology to reduce the burden on the public.

To balance the needs of the Commission to obtain this information with the burdens to the associated public, respondents may submit responses electronically through the DIRS online database or through an e-mail or phone call submission for DIRS-Lite. The DIRS database accepts submissions through web-based forms and requires an associated account with access credentials for each respondent. Respondents may access their submissions but cannot view the rest of the database nor edit other respondent data submissions. The DIRS database also accepts batch submissions to reduce the burden on the public.

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.

This information collected in the DIRS collection is not available elsewhere, and the collection helps the Commission obtain consistent data from companies in each segment of the communications sector in the designated area, during and after a disaster. The DIRS collection was created specifically to meet the requirements in 47 CFR section 0.181(h), which outlines the responsibilities of the designated Defense Commissioner.⁹ This is a unique collection with no duplication.

5. If the collection of information will have significant economic impacts on small businesses, organizations or other small entities, describe any methods used to minimize the burden on these entities.

In compliance with the Paperwork Reduction Act of 1995, the Commission minimizes the respondent burden, regardless of size, by limiting the collection to voluntary submissions of emergency contact information, communications infrastructure, and network damage information. Providing this information will have minimal impact on a small business because the information can be submitted over a web-based interface at the respondent’s convenience, or by email or a phone call for DIRS-Lite.

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

If the information will be collected only once, it is appropriate to state that the collection is a “one-time collection.”

Failure to collect this information will adversely impact the Commission’s ability to carry out its Congressionally-mandated objective of aiding the national defense and promoting the safety of life and property by regulating wire and radio communications.

7. Explain any special circumstances that would cause an information collected in a manner inconsistent with OMB’s guidelines which are stated in 5 C.F.R. § 1320.5(d)(2).

These special circumstances include any of the following situations: (a) requiring respondents to report information to the agency more often than quarterly; (b) requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it; (c) requiring respondents to submit more than an original and two copies of any document if paper copies are required; (d) requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years; (e) in connection with a statistical survey, that is not designed to product valid and reliable results that can be generalized to the universe of study; (f) requiring the use of statistical data classification that has not been reviewed and approved by OMB; (g) that includes a pledge of confidentially that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; (h) requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law.

Information will be collected on occasion and during major disasters or other crises.

8. Identify the date and page number of publication in the Federal Register of the agency’s Paperwork Reduction Act (PRA) 60-day notice, required by 5 C.F.R. § 1320.8(d), soliciting comments on the information collection requirement(s) prior to submission to OMB.

Summarize public comments received in response to that notice and describe actions taken by the agency in response to those comments. 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, and on the data elements to be recorded, disclosed, or reported. If no comments were received from the public, indicate “ no PRA comments were received from the public.”

The Commission published a 60-day notice as required by 5 C.F.R. § 1320.8(d) on March 28, 2018 soliciting comments on the information collection requirements prior to submission to OMB.¹⁰

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

Justify why any payment or gift to respondents is necessary. If respondents will not receive any payment or gift, state that “no payment or gift will be given to respondents.”

No payment or gift will be given to respondents.

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

Cite the authority for promising confidentiality if there are plans to collect identifiable information. Explain what methods will be used to maintain the privacy and confidentiality of the respondents. If the Privacy Act applies to a collection, it can be used as the statutory authority for maintaining the privacy of respondents who are individuals. The Privacy Act generally applies if records in the collection will be primarily retrieved by personal identifiable information such as name, Social Security Number, or date of birth.

The Commission will continue to treat DIRS and DIRS-Lite filings as presumptively confidential upon filing as previously announced.¹¹

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

The justification should include the reasons why the questions are necessary, the specific uses for the information, the explanation to be given to the respondents, and any steps taken to obtain their consent.

The reporting requirement does not address private matters of a sensitive nature.

11. Provide estimates of the burden hours for the collection of information.

The statement should: indicate the number of respondents annually, the frequency of responses, total number of responses annually (annual respondents x frequency of responses for the year), average response time per response, the annual burden hours (annual number of responses x average response time), and an explanation of how the burden was estimated.

Response time includes not only the time necessary to complete the response, but also the time to gather information and have it reviewed.

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. The burden should be calculated under this item for each information collection requirement and a cumulative total should be calculated for the collection.

Also, provide estimates of annualized “ in-ho u se” cost to respondents for the burden hours for the information collections, identifying and using appropriate wage rate categories.

The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 13.

Respondent wireless, wireline, broadcast, cable, interconnected VoIP, broadband, and satellite communications providers companies will enter emergency contact information, and when necessary, critical information (i.e. related to infrastructure damage) into the DIRS database. Respondent wireless and wireline companies will submit critical information for DIRS-Lite by email or by phone. The Commission anticipates that this data entry will take 0.10 hours for initial entry of contact information; 0.50 hours for initial input of critical information, and 0.10 hours for updates of critical information. This estimate is based on FCC staff's knowledge and familiarity with the availability of the data required.

Total Burden Hours to collect this information is as follows:

5,000 respondents x 0.10 hours (6 minutes) = 500 hours for initial entry of contact information;

5,900 responses x 0.50 hours (30 minutes) = 2,950 hours for initial input of critical information;

35,000 responses x 0.10 hours (6 minutes) = 3,500 hours for updates of critical information;

Total number of respondents: 5,000 respondents.

Total annual responses: 5,900 + 35,000 = 40,900 responses.

Total annual burden = 500 + 2,950 + 3,500 = 6,950 hours.

13. Provide an estimate of the total annual cost burden to respondents or

record keepers resulting from the collection of information. Do not include the cost of any burden hours shown in items 12 and 14.

The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. Hiring contracting personnel to fulfill requirements on behalf of respondents is captured under this component.

The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate

major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include among other items, preparations for collecting information such as purchasing computers and software, other equipment, and record storage facilities.

If cost estimates are expected to vary widely, present ranges of cost burdens and explain the reasons for the variance. Generally, estimates should not include purchases of equipment or services made (1) to achieve regulatory compliance with requirements not associated with the information collection, (2) for reasons other than to provide information or keep records for the government, or (3) as part of customary and usual business or private practices.

There is no cost to the respondents’ normal operating costs beyond the staff time needed to voluntarily complete an online entry in the DIRS database or for DIRS-Lite for wireless or wireline respondents, to voluntarily email or call the Commission.

14. Provide estimates of annualized costs to the Federal government.

Provide a description of the method used to estimate cost, which should include quantification of hours, staff GS-pay rate per hour, 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.

There are no costs to the Commission beyond what we consider to be part of the Commission’s normal operating costs.

14. Explain the reasons for any program changes or adjustments reported.

Program changes result from new collection requirements or revisions to existing information collection requirements which are usually associated with rulemakings or revisions to forms or other instruments.

Adjustments are re-estimates of the burdens for existing information collection requirements or instruments. Please consider whether previous assumptions concerning burden hours or costs have been borne out by actual experience with the information collection.

There are adjustments to the Commission’s respondents/responses and burden estimates since the last submission to OMB. The change accounts for the additional requests by the Commission for DIRS and DIRS-Lite respondents, as appropriate, to voluntarily update the information submitted more than once during activated periods.

There are no program changes to this collection.

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

Provide a time schedule for the publication of the results associated with the collection. If no results will be published, state that the Commission will not publish any results from the information collected.

The Commission treats DIRS and DIRS-Lite submissions as presumptively confidential and will not publish the individual submissions but may publish this information on an aggregated basis pursuant to the Wireless Framework. ¹²

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

Justify why displaying the OMB expiration date of approval is not necessary or inappropriate for the collection or instrument.

The Commission seeks approval to display an edition date in lieu of an OMB expiration date for the information collection. The information is retained in an electronic format, and the format will be updated regularly. Also, all information collection requirements are published in 47 CFR 0.408.

14. Explain any exceptions to the statement certifying compliance with 5 C.F.R. §

1320.9 and the related provisions of 5 C.F.R. § 1320.8(b)(3).

There are no exceptions to the certification statement

2. Collections of Information Employing Statist ical Methods:

This information collection does not employ statistical methods.

1 47 U.S.C. §§ 151 et seq.

2 The FCC’s Public Safety and Homeland Security Bureau Launches Disaster Information Reporting System (DIRS), Public Notice, DA 07-3871, 22 FCC Rcd 16757 (PSHSB 2007).

3 Recommendations of the Independent Panel Reviewing the Impact of Hurricane Katrina on Communications Networks, Order, EB Docket No. 06-119, WC Docket No. 06-63, 22 FCC Rcd 10541 (2007).

4 Public Safety and Homeland Security Bureau Announces Limited Waiver of Sections 4.9 and 4.11 of the Commission’s Rules During Activations of the Disaster Information Reporting System, Public Notice, DA 09-1319 (PSHSB 2009).

5 Federal Communications Commission, Standard Operating Procedures DIRS-Lite, https://transition.fcc.gov/pshs/docs/Standard_Operating%20_Procedures_DIRS-Lite.pdf (last visited Feb. 20, 2018) (DIRS-Lite Manual).

6 DIRS-Lite Manual at 1.

7 DIRS-Lite Manual at 1.

8 47 U.S.C. §§ 151 et seq.

9 The Defense Commissioner is designated by the Commission and directs the homeland security, national security and emergency preparedness, and defense activities of the Commission. 47 CFR § 0.181.

10 [83 FR 13277]

11 The FCC’s Public Safety and Homeland Security Bureau Launches Disaster Information Reporting System (DIRS), Public Notice, DA 07-3871, 22 FCC Rcd 16757 (PSHSB 2007); DIRS-Lite Manual at 2.

12 Improving the Resiliency of Mobile Wireless Communications Networks; Reliability and Continuity of

Communications Networks, Including Broadband Technologies, Order, 31 FCC Rcd 13745 (2016) (Order).

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