Supporting statement OMB 3060-0188 (2021)

OMB Control Number: 3060‑0188 August 2021

Title: Call Sign Reservation and Authorization System, FCC Form 380

SUPPORTING STATEMENT

A. Justification:

History:

1. On December 16, 1998 the Commission released a Report and Order (R&O), Call Sign Assignments for Broadcast Stations, MM Docket No. 98-98; FCC 98-324, which the Commission modified its practices and procedures regarding the assignment of call signs to radio and television broadcast stations. The R&O replaced the Commission’s existing manual procedures with an on-line system for the electronic preparation and submission of requests for the reservation and authorization of new and modified call signs. The implementation of the on-line call sign system would enhance the speed and certitude of radio and television broadcast station call sign assignments, thereby providing better service to all broadcast licensees and permittees, and will also conserve Commission resources.¹

Information Collection Requirements:

47 CFR 73.3550 provides that all requests for new or modified call signs be made via the on-line call sign reservation and authorization. The Commission uses an on-line system, FCC Form 380, for the electronic preparation and submission of requests for the reservation and authorization of new and modified call signs. Access to the call sign reservation and authorization system is made by broadcast licensees and permittees, or by persons acting on their behalf, via the Internet's World Wide Web. This on-line, electronic call sign system enables users to determine the availability and licensing status of call signs; to request an initial, or change an existing, call sign; and to determine and submit more easily the appropriate fee, if any. Because all elements necessary to make a valid call sign reservation are encompassed within the on-line system, this system prevents users from filing defective or incomplete call sign requests. The electronic system also provides greater certitude, as a selected call sign is effectively reserved as soon as the user has submitted its call sign request. This electronic call sign reservation and authorization system has significantly improved service to all radio and television broadcast station licensees and permittees.

The Commission is requesting an extension of this information collection in order to receive the full three-year OMB approval/clearance.

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

Statutory authority for this collection of information is contained in Sections 154(i) and 303 of the Communications Act of 1934, as amended.

2. The call sign reservation and authorization system is used by permittees, licensees or persons acting on their behalf to determine the availability of a call sign and to request an initial call sign or change an existing call sign.

3. The Commission requires applicants to use the on-line system for the electronic preparation and submission of requests for the reservation and authorization of new and modified call signs. Paper-filed copies of the form will be accepted only if accompanied by an appropriate request for waiver of the electronic requirement. Waivers will not be routinely granted, and filers should plead with particularity the facts and circumstances warranting grant of the waiver.

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

5. In conformance with the Paperwork Reduction Act of 1995, the Commission is making an effort to minimize the burden on all respondents. Therefore, this information collection will not have a significant economic impact on a substantial number of small entities/businesses.

6. The frequency for this collection of information is determined by respondents, as necessary.

7. This collection of information is consistent with the guidelines in 5 CFR Section 1320.5(d)(2).

8. The Commission published a Notice (86 FR 30318) in the Federal Register on June 7, 2021 seeking comments on the information collection requirements contained in this supporting statement. The Commission received one comment pertaining to the unavailability of an online filing option for FCC Form 380. The Commission modified its practices and procedures regarding the assignment of call signs to radio and television broadcast stations in December of 1998. At that time, the Commission replaced the manual procedures with an online system for electronic preparation and submission. The Call Sign Reservation and Authorization System (CSRS) is where all broadcast radio and television entities can obtain or modify a call sign.

9. No payment or gifts were provided to respondents.

10. There is no need for confidentiality with this collection of information.

11. This collection of information does not address any private matters of a sensitive nature.

12. We estimate that 1,600 requests for new or modified call signs will be filed annually. We estimate that 50% of the respondents will complete the request without outside assistance. The respondents’ average burden is 0.166 hours per request. We also estimate that the remaining 50% of the respondents will contract with an outside attorney to complete requests and the respondents will have an average burden of 0.25 hours to consult/provide necessary information to the outside attorney to enable the attorney to complete the requests on behalf of the respondents. These estimates are based on FCC staff's knowledge and familiarity with the availability of the data required.

Total Annual Number of Respondents: 1,600 respondents

Total Annual Number of Responses: 1,600 FCC Form 380 filings/requests

Total Annual Burden Hours:

1,600 requests x 50% x 0.166 hours to complete each request by the respondent	=	133 hrs.
1,600 requests x 50% x 0.25 hours to consult with outside attorney	=	200 hrs.
		333 hrs.

Annual “In-House Cost”: We estimate that these respondents would have an average salary of $100,000/year ($48.08/hour).

Total In-House Costs:	1,600 requests x 50% x 0.166 hours x $48.08/hour	=	$ 6,385.02
	1,600 requests x 50% x 0.25 hours x $48.08	=	$ 9,616.00
			$16,001.02

13. Annual cost burden: We estimate that 50% of the respondents would contract with an attorney to complete a call sign request. We estimate for the attorney an average salary of $300/hour and that this work will take 0.25 hours. In addition, a respondent must submit a fee for certain types of call sign requests at $85/request.² We estimate that 75% of all call sign requests will be accompanied by a fee.

A fee is not imposed on the following: (a) respondents seeking to modify an existing call sign only to the extent of adding or deleting an “-FM" or "-TV" suffix; (b) a low power television (LPTV) respondent changing its five-character alpha-numeric call sign to a four letter call sign;³ (c) a noncommercial educational respondent; and (d) a request for an initial call sign from a permittee.

Total Annual Cost Burden:	1,600 requests x 50% x 0.25 hours x $300/hour	=	$ 60,000
	1,600 requests x 75% x $85/request	=	$102,000
			$162,000

14. Cost to the Federal Government: The Commission will use a clerical person at the GS-9, step 5 level ($68,146/annually), to monitor the system and perform all necessary duties associated with the call sign system. Monitoring the system and performing all the necessary duties associated with the call sign system are the primary duties of the incumbent.

Total cost to the Federal Government: $68,146

15. There are no program changes or adjustments to this collection.

16. The data will not be published.

17. OMB approval of the expiration date of the information collection will be displayed at 47 CFR 0.408. We request that OMB waive the requirement to display the expiration date on FCC Form 380.

18. There are no exceptions to the Certification Statement.

B. Collections of Information Employing Statistical Methods

No statistical methods are employed.

1 63 FR 71601.

2 See Order, In the Matter of Amendment of the Schedule of Application Fees Set Forth In Section 1.1102 through 1.1107 of the Commission’s Rules, GEN Docket No. 86-285, FCC 04-150 @ 35.

3 LPTV permittees/licensees that have four letter call sign are subject to a fee if they subsequently changes to another four letter call sign.

3