3060-XXXX
February 2021
Secure Telephone Identity Governance Authority Token Revocation Review Process
SUPPORTING STATEMENT
This new information collection is being submitted to obtain approval from the Office of Management and Budget (OMB) for new proposed information collection requirements due to a recent Federal Communications Commission (Commission or FCC) Notice of Proposed Rulemaking, as explained below.
Justification
Circumstances that make the collection necessary. On December 30, 2019, Congress enacted the Pallone-Thune Telephone Robocall Abuse Criminal Enforcement and Deterrence (TRACED) Act. The TRACED Act directs the Commission to require, no later than 18 months from enactment, all voice service providers to implement STIR/SHAKEN caller ID authentication framework in the Internet protocol (IP) portions of their networks and implement an effective caller ID authentication framework in the non-IP portions of their networks. To implement the TRACED Act’s provisions related to caller ID authentication, the Commission adopted a Report and Order and Further Notice of Proposed Rulemaking on March 30, 2020, which required voice service providers to implement the STIR/SHAKEN caller ID authentication technology in the IP portions of their phone networks by June 30, 2021. See Call Authentication Trust Anchor, Implementation of TRACED Act Section 6(a)—Knowledge of Customers by Entities with Access to Numbering Resources, WC Docket Nos. 17-97 and 20-67, Report and Order and Further Notice of Proposed Rulemaking, 35 FCC Rcd 3241 (Mar. 31, 2020). The Commission then adopted a Second Report and Order on September 29, 2020 to further implement the remaining portions of the TRACED Act related to caller ID authentication and STIR/SHAKEN. See Call Authentication Trust Anchor, WC Docket No. 17-97, Second Report and Order, FCC 20-136 (adopted Sept. 29, 2020).
On January 13, 2021, the Commission adopted a Second Further Notice of Proposed Rulemaking, which proposes a limited role for the Commission to oversee certificate revocation decisions by the private STIR/SHAKEN governance system that would have the effect of placing providers in noncompliance with the Commission’s rules. Within the STIR/SHAKEN framework, voice service providers share a digital certificate along with each call as a means of maintaining trust and accountability. The STIR/SHAKEN governance system can revoke a voice service provider’s access to these digital certificates due to that voice service provider’s violation of a specified list of rules and policies. Because this revocation would place an affected voice service provider in noncompliance with the Commission’s rules, the Second Further Notice proposes to establish an oversight role for the Commission over the governance system’s token revocation decisions similar to the one the Commission holds in the context of decisions by the Universal Service Administrative Company. The proposed rules would allow review by the Wireline Competition Bureau, except for requests for review that raise novel questions of fact, law or policy, which would be considered by the full Commission.
New Proposed Information Collection Requirements:
Under the proposed rules of the Second Further Notice, a request for Commission review from a voice service provider, at a minimum, must contain: (1) a statement setting forth the voice service provider’s asserted basis for appealing the governance system’s revocation decision; (2) a full statement of relevant, material facts with supporting affidavits and documentation, including any background information the voice service provider deems useful to the Commission’s review; and (3) the question presented for review, with reference, where appropriate, to any underlying Commission rule or STIR/SHAKEN governance system policy.
The Commission proposed finding statutory authority for this information collection under 47 U.S.C. §§ 227b, 251(e), or 227(e) of the Communications Act of 1934.
This information collection does not affect individuals or households; thus; there is no impact under the Privacy Act.
Use of information. The Commission will use the information to provide targeted oversight to the private STIR/SHAKEN governance system.
Technology collection techniques. All submissions will me made electronically in the Commission’s Electronic Comment Filing System (ECFS).
Efforts to identify duplication. The information to be collected is unique to each revocation decision, and there are no similar collection requirements.
Impact on small entities. The Commission worked to minimize the amount of information each certification will require, requesting only the information necessary for the Commission to effectively review a revocation decision.
Consequences if information is not collected. If this information is not collected, the Commission will be unable to provide a full and complete review of a decision by a private entity that would have the effect of placing a voice service provider in noncompliance with the Commission’s caller ID authentication rules.
Special circumstances. We do not foresee any special circumstances with this information collection.
Federal Register notice; efforts to consult with persons outside the Commission. The Commission published a Federal Register Notice in the Federal Register as required by 5 CFR 1320.8(d) on February 17, 2021 (86 FR 9894). To date, no PRA comments were received.
Payments or gifts to respondents. The Commission does not anticipate providing any payment or gifts to respondents.
Assurances of confidentiality. The Commission will consider the potential confidentiality of any information submitted, particularly where public release of such information could raise security concerns (e.g., granular location information). Respondents may request materials or information submitted to the Commission or to the Administrator be withheld from public inspection under 47 C.F.R. § 0.459 of the Commission’s rules.
Questions of a sensitive nature. There are no questions of a sensitive nature with respect to the information collection described herein.
Estimates of the hour burden of the collection to respondents. The following represents the hour burden on the collection of information:
Number of Respondents: Approximately 50 voice service providers.
Frequency of Response: Upon request by the voice service provider.
Total number of responses per respondent: 1.
Estimated time per response: 24 hours.
Total hour burden: 1,200 hours.
24 hours per response per respondent for 50 voice service providers. Total annual hour burden is calculated as follows:
50 respondents x 1 response per respondent = 50 responses x 24 hours = 1,200 total hours.
Explanation of calculation: We estimate that each voice service provider will take, on average, 24 hours per response. We estimate that respondents use mid- to senior-level personnel to comply with the requirements comparable in pay to the Federal Government, approximately $56.31 per hour (equivalent to a GS-13, step 5 federal employee).
50 (number of responses) x 24 (hours to prepare response) x 1 (responses per respondent) x $56.31/hr. = $67,572.
Total Number of Respondents: 50 unique respondents
Total Number of Responses: 50 responses
Total Hourly Burden: 1,200 burden hours
Total
In-House Costs to Respondents: $67,572
Estimates for the cost burden of the collection to respondents. The Commission believes that voice service providers have sufficient “in-house” staff to address all the information collection requirements using their “in-house” personnel rather than having to contract out this requirement. Thus:
(a) Total annualized capital/startup costs: $0.00
(b) Total annualized costs (O&M): $0.00
(c) Total annualized cost requested: $0.00
Estimates of the cost burden to the Commission.
Costs to the Commission to set up the collection process will potentially be $56.31/hr. (GS-13, step 5 federal employee) x 1 hour (to set up the designated Electronic Comment Filing System inbox to receive request for review) = $56.31. Additionally, costs to the Commission to review each submission will potentially be $56.31/hr. (GS-13, step 5 federal employee) x 50 (number of respondents with one response each) x 3 hours (for staff to review each submission) = $8,446.50.
Total Cost to the Federal Government: $56.31 + $8,446.50 = $8,502.81
Program changes or adjustments. If the Commission adopts the new information collection requirements as proposed in a final rulemaking, the following burdens/increases to the total number of respondents of +50, total annual responses of +50 and total annual burden hours of +1,200 will be added to OMB’s Inventory.
Collections of information whose results will be published. The filings voice service providers submit with their request for review will be publicly available in the Commission’s Electronic Comment Filing System.
Display of expiration date for OMB approval of information collection. There is no paper form associated with this information collection; it will be collected electronically through the Commission’s Electronic Comment Filing System. The Commission publishes a list of all OMB-approved information collections including their titles, OMB Control Numbers and OMB expiration dates in 47 CFR 0.408 of the Commission’s rules.
Exceptions to certification for Paperwork Reduction Act submissions. There are no exceptions to the Certification Statement.
Collections of Information Employing Statistical Methods:
No statistical methods are employed.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Jordan Marie Reth |
| File Modified | 0000-00-00 |
| File Created | 2021-09-01 |