Supporting Statement OMB 3060-0800 (603) - 9-24-2019 (FCC 18-149

Supporting Statement OMB 3060-0800 (603) - 9-24-2019 (FCC 18-149.docx

FCC Application for Assignment of Authorization or Transfer of Control: WTB and PSHS Bureaus

OMB: 3060-0800

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FCC Application for Assignment of Authorization 3060-0800

or Transfer of Control: Wireless Telecommunications February 2020

Bureau and Public Safety and Homeland Security Bureau


SUPPORTING STATEMENT


A. Justification:


  1. FCC Form 603 is a multi-purpose form that is used by radio services in Wireless Services within the Universal Licensing System (ULS). FCC 603 is composed of a main form that contains the administrative information and a series of schedules used for filing technical information. These schedules are required when applying for Auctioned Services, Partitioning and Disaggregation, Undefined Geographical Area Partitioning, and Notification of Consummation or Request for Extension of Time for Consummation. Applicants/licensees in the Public Mobile Services, Personal Communications Services, Private Land Mobile Radio Services, Broadband Radio Service, Educational Broadband Service, Maritime Services (excluding Ship), and Aviation Services (excluding Aircraft) use FCC Form 603 to apply for an assignment or transfer, to establish their parties’ basic eligibility and qualifications, to classify the filing, and/or to determine the nature of the proposed service. This form is also used to notify the FCC of consummated assignments and transfers of wireless licenses to which the Commission has previously consented or for which notification but not prior consent is required. Respondents are encouraged to submit FCC 603 electronically.


The data collected on FCC 603 include the FCC Registration Number (FRN), which serves as a “common link” for all filings an entity has with the FCC. The Debt Collection Improvement Act of 1996 required that those filing with the Commission to use the FRN, effective December 3, 2001.


Records may include information about individuals or households, e.g., personally identifiable information or PII, and the use(s) and disclosure of this information are governed by the requirements of a system of records notice or ‘SORN’, FCC/WTB-1, “Wireless Services Licensing Records.” There are no additional impacts under the Privacy Act.



On October 24, 2018, the Commission released a Report and Order, FCC 18-149, in GN Docket No. 17-158, adopting limited changes to the rules governing Priority Access Licenses (PALs) in the 3550-3700 MHz (3.5 GHz) band, including larger license areas, longer license terms, renewability, and performance requirements. The Commission anticipated that the targeted changes made in its 2018 Report and Order will spur additional investment and broader deployment in the band, promote robust and efficient spectrum use, and help ensure the rapid deployment of advanced wireless technologies—including 5G—in the United States.


The Commission seeks approval for revisions to its currently approved collection of information under OMB Control Number 3060-0800 to permit the collection of the additional information in connection with partial assignments of authorizations for geographic partitioning, spectrum disaggregation, or a combination of both, pursuant to the rules and information collection requirements adopted by the Commission 2018 Report and Order. Specifically, in the 2018 Report and Order, the Commission revised its rules to allow Priority Access Licensees to partition their licenses or disaggregate their spectrum, and partially assign or transfer their licenses, pursuant to §1.950 of the Commission’s rules. Because of the additional Priority Access Licensees, additional respondents may be filing FCC Form 603 for assignments or transfers of control of licenses.


In this information collection request, the Commission has increased the number of estimated respondents by 100, and accordingly adjusted the estimated total burden in hours and cost.


Statutory authority for this collection of information is contained in 47 U.S.C. sections 154, 155, 158, 161, 301, 303(r), 308, 309, 310 and 332.


2. The FCC uses the information in FCC Form 603 to determine whether the applicant is legally,

technically, and financially qualified to obtain the requested authorization. Without such information, the Commission can not determine whether to issue the licenses to the applicants that provide telecommunication services to the public, and therefore, to fulfill its statutory responsibilities in accordance with the Communications Act of 1934, as amended. Information provided on this form will also be used to update the database and to provide for proper use of the frequency spectrum.


Information about individuals or households, and the use(s) and disclosure of this information is governed by the requirements of system of records, FCC/WTB-1. All information within PLMRS is publicly available except TIN Numbers and material that is afforded confidential treatment pursuant to a request made under 47 C.F.R. § 0.459 of the Commission’s rules will not be made available for public inspection.


  1. The Commission encourages the use of electronic filing. With the advent of the Universal Licensing System (ULS), 98% of all applications and notifications submitted to the FCC are now being filed electronically. Electronic filing is mandatory for certain categories of respondents specified in 47 C.F.R. § 1.913 of the Commission’s rules and others have the choice of filing manually or electronically.


4. This agency does not impose a similar information collection on the respondents. There are no similar data available.


  1. In conformance with the Paperwork Reduction Act of 1995, the Commission is making an effort to minimize the burden on all respondents, regardless of size. The Commission has limited the information collection requirements to those absolutely necessary for evaluating and processing each application and to deter against possible abuses of the processes.


  1. Generally, the frequency of filing FCC Form 603 is determined by the applicant and the licensee. FCC Form 603 is required when an authorization is assigned or transferred.


7. This collection of information is consistent with the guidelines in 5 C.F.R. § 1320.



  1. The Commission published a 60-day notice which appeared in the Federal Register on October 4, 2019 (84 FR 53145) seeking comment from the public on the information collection requirements contained in this collection. No comments were received as a result of this notice.


9. Respondents will not receive any payments.


  1. Respondents may request materials or information submitted to the Commission be withheld from public inspection under 47 CFR §0.459 of FCC rules.


Information on the FCC Form 603 is maintained in the Commission’s system of records, FCC/WTB-1, “Wireless Services Licensing Records.” These licensee records are publicly available and routinely used in accordance with subsection b. of the Privacy Act, 5 U.S.C. 552a(b), as amended. TIN Numbers and material that is afforded confidential treatment pursuant to a request made under 47 CFR §0.459 of the Commission’s rules will not be available for public inspection.


The Commission has in place the following policy and procedures for records retention and disposal: Records will be actively maintained as long as the individual remains a licensee. Paper records will be archived after being keyed or scanned into the system. Electronic records will be backed up on tape. Electronic and paper records will be maintained for at least twelve years and three months.


  1. This collection does not address private matters of a sensitive nature, and the PII is covered by the system of records notice or ‘SORN’, FCC/WTB-1, “Wireless Services Licensing Records.”


  1. The Commission estimates that 2,547 respondents (applicants/licensees) will file 2,547 FCC Form 603 applications annually and that the average burden per respondent will be 1.75 hours. Of the estimated 2,547 respondents, we estimate approximately 10 are Cellular Service respondents that will be required to submit the maps (in GIS format and PDF) when applying for Partitioning and Disaggregation, and that the average burden associated with creating and filing the maps is 30 minutes (0.5 hours).


We estimate that 50% of the respondents (1,274) will complete the application themselves with no additional assistance. The remaining 50% (1,273) will contract out completing the form to a law firm or application preparation service. We estimate that it will take 1.75 hours per respondent to complete FCC Form 603 for the respondents completing the forms and keeping records of the forms without hiring a consultant. For those respondents hiring a consultant, we estimate a burden of approximately 30 minutes (0.5 hours) to coordinate with the consultant.


The total annual burden is:


1,274 @ 1.75 hours + 10 @ 0.5= 2,235 hours

1,273 @ 0.5 hours = 637 hours


Total Burden Hours: 2,235 + 637 = 2,872 hours


In-House Cost: Respondents use personnel comparable in pay to a mid-to-senior level federal employee (GS-13, Step 5) to prepare this collection of information, we estimate the cost to be about $55.75 per hour.


Total in-house cost to the respondents: 2,872 hours x $55.75/hour = $160,114.



  1. Cost to the Respondent:


  1. There are no capital and start-up costs to prepare FCC Form 603.


  1. The annual costs (O&M) consist of the following:


There is no cost to file the application electronically with the FCC other than the cost of a long distance phone call and/or Internet access. We assume that respondents that file manually will incur postage costs, which are considered “in house costs.”


  1. The FCC filing fees for this application vary based on radio service. For purpose

of this submission, we estimate an average filing fee of $75 per application:

2,547 applications @ $75/response = $191,025.


(2) We also estimate that 50% of the respondents will contract out the completion of Form 603 and will use an attorney/engineer or application preparation service at a cost of $300/hour to prepare the FCC Form 603. It will take the attorney/preparation service .5 hours to complete the FCC Form 603 application for respondents:


1,273 applications x .5 hours @ $300/hour = $190,950


Total Estimated Annual Costs: $191,025 + $190,950 = $381,975.






14. Cost to the Federal Government:

FCC Form 603 applications estimated to be filed: 2,547.


2,547 applications x 30 min. (0.5 hrs.)

@ $39.12 per hour (GS-11, Step 5) for an = $49,819.32

Industry Analyst

Total $49,819.32


15. The Commission has program changes to this collection as a result of the information collection requirements adopted in FCC 18-149 because a new radio service will use Form 603 and add the new radio service to the Form 603. Therefore, the following increases occurred to this collection: 100 to the number of respondents, 100 to the annual number of responses, 113 to the annual burden hours and $15,000 to the annual cost.


There are no adjustments to this collection.


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


  1. The Commission is requesting a continued waiver from displaying the OMB expiration date on the FCC Form 603. Granting this waiver will prevent the Commission from destroying stock upon re-approval of the form or updating the electronic screens in ULS. The Commission published all OMB-approved information collections along with their OMB Control Numbers, titles, and OMB expiration dates in 47 CFR § 0.408.


18. There is no exception to the “Certification Statement.”


B. Collections of Information Employing Statistical Methods:

This information collection does not use any statistical methods.


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