DIRS Emergency Letter

Federal Communications Commission
Washington, D.C. 20554
July 27, 2023
Mr. Alexander Hunt
Chief, Information Policy Branch
Office of Information and Regulatory Affairs
Office of Management and Budget
Washington, D.C. 20503
Dear Mr. Hunt:
The Federal Communications Commission (Commission) requests OMB approval to submit the
information collection described herein under the “emergency processing” provision of the Paperwork
Reduction Act (PRA) of 1995 (5 C.F.R. § 1320.13). The Commission is requesting clearance for a
revision to an existing information collection under OMB Control Number 3060-1003. We respectfully
request OMB approval for this collection no later than 32 days after it is received by OMB to effectuate
the public safety purposes of the collection.
Promotion of public safety in an integral part of the Commission’s public interest responsibility and one
of the core purposes for which Congress created the Commission. The Commission's current information
collection facilitates the collection of network outage information and restoration status during disasters
as voluntarily submitted by communications service providers through its Disaster Information Reporting
System (DIRS). The Commission utilizes this information to facilitate disaster response, direct resources,
and engage with providers to ensure the prompt access for consumers to critical communications services,
including 911 and emergency information, during a variety of disasters, including hurricanes, tropical
storms, and wildfires.
In 2021, the Commission issued a Second Report and Order 1 in which it adopted rules to facilitate readonly access by Federal, state, territorial and Tribal partners to outage reports filed in both its Network
Outage Reporting System (NORS) 2 and in DIRS. Direct access to DIRS information by these partners
serves the public interest by ensuring public safety officials can effectively and appropriately leverage the
same reliable and timely network outage and infrastructure status information that the Commission has
access to when responding to emergencies and disasters. Timely access is critical to ensure the ability of
disaster response agencies to act on this information to preserve the safety of life and property.
Requiring the Commission to seek routine OMB approval for this revised collection under the regular
PRA processing procedures would significantly delay the Commission’s efforts to address the serious and
immediate risk to public safety posed by disasters. As such, we believe these circumstances meet the
criteria for emergency PRA approval as set forth in 5 C.F.R. Sec. 1320.13(a), 3 in that: 1) a public harm
Amendments to Part 4 of the Commission’s Rules Concerning Disruptions to Communications, PS Docket No. 1580, Second Report and Order, 36 FCC Rcd 6136 (2021) (Second Report and Order).
1

Modifications to the NORS information collection arising from the Second Report and Order have already been
reviewed and approved by OMB. See OMB Control No. 3060-0484,
https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202206-3060-012 (approved 08/15/2022).

2

“Any such request shall be accompanied by a written determination that: (1) The collection of information: (i) Is
needed prior to the expiration of time periods established under this Part; and (ii) Is essential to the mission of the
agency; and (2) The agency cannot reasonably comply with the normal clearance procedures under this part because:

3

will result if normal clearance procedures are followed; and 2) the use of normal clearance procedures is
reasonably likely to prevent or disrupt the collection of information.
First, absent prompt approval the public risks harm during disasters and emergencies as Federal, state,
territorial and Tribal public safety agencies will be unable to access critical DIRS information necessary
to support public disaster response. Prompt access in this respect is particularly critical as we are
currently in the midst of the 2023 hurricane and wildfire seasons, and DIRS may be activated at any time.
The sooner that OMB approval can be achieved, the sooner eligible public safety agencies will have
access to critical information concerning outages, network reliability, and infrastructure status.
Second, utilizing normal clearance procedures is reasonably likely to result in the collection of critical
information being prevented or disrupted. The revisions at issue provide for modifications to facilitate the
confidentiality safeguards that are necessary preconditions to allowing access by public safety personnel
tasked with disaster response. Enhanced situational awareness and being able to access data necessary to
allocate resources and direct emergency relief efforts on a timely basis is critical. Under a normal
clearance procedures, many agencies will be unable to access this information until months after a
disaster, at which point its value will be minimal.
The Commission will conduct all the necessary regular submission requirements under the PRA after
approval of this emergency request. The Commission’s staff is ready and eager to work with your PRA
Desk Officer to immediately provide any additional information needed to assure OMB’s approval of this
emergency request no later than 30 days after it is received by OMB. Please have your Desk Officer
contact Nicole Ongele, (202) 418-2991, or at [email protected] if there are any questions or if you
need additional information.
Sincerely,

MARK
STEPHENS

Digitally signed by MARK
STEPHENS
Date: 2023.07.27 09:39:27
-04'00'

Mark Stephens
Office of Managing Director
Federal Communications Commission

(i) Public harm is reasonably likely to result if normal clearance procedures are followed; (ii) An unanticipated event
has occurred; or (iii) The use of normal clearance procedures is reasonably likely to prevent or disrupt the collection
of information or is reasonably likely to cause a statutory or court ordered deadline to be missed.”