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SUPPORTING STATEMENT

A.   Justification:

The Federal Communications Commission (Commission) is requesting that the Office of Management and Budget (OMB) to approve an extension of the delegated authority information collection  titled, “International Signaling Point Code (ISPC)” under OMB Control No. 3060-1028.  

1. Explain the circumstances that make the collection of information necessary.

An ISPC is a unique, seven-digit code used to identify the signaling network of each international carrier.  The ISPC has a unique format that is used at the international level for signaling message routing and identification of signaling points in Signaling System 7 networks.  ISPC applications are filed through the International Communications Filing System (ICFS).  After receipt and review of an ISPC application, the Commission assigns an ISPC code(s) to each international carrier applicant free of charge on a first-come, first-served basis.  The collection of this information is required to assign a unique identification code to each international carrier and to facilitate communication among international carriers through their use of the ISPC code on the shared signaling network.  The Commission informs the International Telecommunication Union (ITU) of its assignment of ISPCs to international carriers on an ongoing basis.

In 1987, the Commission assumed the responsibility as the Administrator for the United States for issuing ISPCs to international carriers based on an exchange of letters between AT&T, the Commission, and the ITU Telecommunications Standardization Bureau  (ITU-T).  The ITU allocates a specific amount of ISPCs to member countries for assignment to carriers.  ITU-T Recommendation Q.708 includes a list of criteria for assignment of signaling point codes.

The ITU, headquartered in Geneva, Switzerland, is the United Nations’s specialized agency for information and communication technologies.  The ITU-T, which is one of three sectors of the ITU, has a continuing role in preparing the technical specifications for telecommunications systems, networks and services, including their operation, performance, and maintenance.  In addition, the ITU-T oversees the tariff principles and accounting methods used to provide international services. 

Pursuant to the ITU guidance contained in ITU-T Recommendation Q.708, the Commission must obtain certain information from an applicant requesting a new ISPC assignment.1  This information is used by the Commission to assess whether the applicant’s use of the ISPC will be in comply with ITU guidelines.  The minimum information required in a request are the name of the applicant and the name of the signaling point (typically the city where the ISPC will be located).   ITU-T Recommendation Q.708 states that administrators can request additional information from applicants, which may include applicant contact information; location(s) where the ISPC(s) will be implemented; description of the nature of the use of the ISPC(s) in the network; a statement regarding the signaling point manufacturer/type; and identification of at least one planned Message Transfer Part (MTP) signaling relation.  Applicants must also make several certifications/acknowledgments regarding their obligations and rights associated with an ISPC assignment.  Operators that have been assigned an ISPC must also notify the Commission when any parameters of their code assignment(s) have changed (i.e., modifications), such as a change in the location where the ISPC has been implemented.  If an assigned ISPC has undergone a transfer of control as a result of a merger, acquisition, divestiture, or formation of a joint venture, the ISPC operator must notify the Commission of the transfer and the identity of the new holder of the ISPC (along with relevant contact information).
ICFS Modernization of ISPC Electronic Forms.  The Commission has obtained OMB approval of revisions to its ISPC application form and the addition of new forms that are be electronically filed  through the Commission’s online, web-based electronic filing system – the International Communications filing system (ICFS).2   

2.   Indicate how, by whom, and for what purpose the information is to be used.

The Commission obtains relevant information from signaling point operators through the filing of applications for ISPCs in ICFS.  The information collection requirements contained in this collection facilitate the Commission's assignment of unique ISPCs to international carriers for identification purposes.  In addition, they enhance the ability of the international carriers to communicate with each other internationally through the shared signaling network.  Since ISPCs are a limited resource, the information collection also assists the Commission in reclaiming ISPCs that are not being used.

This information collection does not affect individuals or households; thus, there are no impacts under the Privacy Act.
The statutory authority for this collection is contained in Sections 1, 4(i)-(j), 201-205, 211, 214, 219-220, 303(r), 309 and 403 of the Communications Act of 1934, as amended, 47 U.S.C §§ 151, 154(i)-(j), 201-205, 211, 214, 219-220, 303(r), and 403.

3.  Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology.
Currently 100% of ISPC applications (SPC-NEW, SPC-MOD, SPC-WAV, SPC-TC, SPC-AMD) are filed electronically through ICFS.  ICFS allows filers to work more efficiently, which reduces the time and effort spent on the filing of ISPC  applications

4.   Describe efforts to identify duplication.

The information collected in these applications is not duplicated elsewhere.  Similar information is not available.

5.   If the collection of information involves small businesses or other small entities, describe the methods used to minimize burden.  

This collection of information does not significantly impact small businesses or other small entities.

6.   Describe the consequences to the Federal program or policy activities if the collection is not conducted or is conducted less frequently.

The Commission would not have unique identification codes, such as ISPCs, to identify each international carrier if these collections of information were not conducted.  Furthermore, the lack of ISPCs would hinder the ability of international carriers to identify other carriers and would likely result in delays in communication or miscommunication among international carriers on the shared signaling network.

7.  Describe if there are special circumstances associated with this request.

There are no special circumstances associated with this collection of information. 

8.  Provide a copy of the PRA Federal Register notice that solicited public comments on the information collection prior to this submission.  Summarize the public comments received in response to that notice and describe the actions taken by the Agency in response to those comments.

On April 2, 2026, the Commission published a 60-day notice in the Federal Register (91 FR 16698) to request comments from the public.  No comments were received from the public in response to the notice.
 
9.   Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.

Respondents will not receive any payments or gifts.

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

Any applicants may request that any information supplied be withheld from public inspection, pursuant to 47 CFR § 0.459 of the FCC’s rules.  This request must be justified pursuant to 47 CFR § 0.457.

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

This collection of information does not contain questions of a sensitive nature.

12.  Provide estimates of the hour burden of the collection of information.  The statement should: indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.  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 chart shows the total number of responses and the combined burden hours for in-house staff and outside counsel to provide responses.  We estimate that 50% of the burden hours are incurred in-house and 50% by outside counsel.    
















Information Collection
Number
of Responses
Average Hours Per
Response
Total Annual Hour Burden
Applications for assignment of ISPC3  
6
3
18
Modifications of ISPC4
3
0.5
1.5
Notification applications for transfers of ISPCs5

2

1.5

3
Amendment of Pending ISPC Application
3
1
3
Waiver of ISPC Assignment Requirements6 
07
1.5
0
Notification of Signaling Point Code Implementation (Notification by letter filed in the ISPC file)
6
0.5
3
Totals:
20
0.5-3
28.5

Cumulative Total Number of Respondents  =  11 respondents
Cumulative Total Annual Responses = 20 responses
Cumulative Total Annual Burden Hours:  = 28.5 hours

Therefore, the respondent’s burden hours are:  15 (rounded)

In-House Costs

We estimate that 50% of the burden hours are incurred by in-house staff.   We estimate that in-house staff is paid at an estimated rate of $40 per hour.  

Total In-House Cost to Respondent – 28.5 hours X 50% X
$40 per hour = $570

13.  Provide an estimate of the total annual cost burden to the respondents or record-keepers resulting from the collection (excluding the value of the burden hours in Question 12 above).    

Annual Burden Cost:  

(a) Capital and Start-up Costs: None.
	
(b)  Operation and Maintenance Costs:  

Outside Legal/Engineering Assistance.  We estimate that the respondents will require outside legal and engineering assistance for 50% of the burden hours.  The cost of outside legal and engineering assistance is estimated at $300 per hour.8  The figure is based on a small survey of local firms in the Washington D.C. area and is considered a conservative estimate.  

28.5 hrs. x 50% x $300 per hr. = $4,275 Total Outside Legal/Engineering Costs

Application Fees.  The Commission adopted a new schedule of application fees in 2020 and updated it in 2022.9  The current fees are shown in the table below.10

ISPC Application 
Filing Fees
Number
of Applicants Per Year
Application
Fees
Cost

New ISPC Filing
6
$920
$5,520
ISPC Transfer of Control/Assignment
2
$755
$1,510
Modification of ISPC 
3
$755
$2,265
Waiver of ISPC Application Requirements
0
$375
0
Totals


$ 9,295

  (c)   	 Total Annual Cost Burden = $4,275 + $9,295 = $13,570. 

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

We make the following estimates for the total annual cost to the Federal Government to review 	 
and process the ISPC applications that applicants file annually, in accordance with OMB guidance.11  While we are utilizing the best available cost information, there are certain limitations to our data.  For example, we only have aggregated total costs for ICFS that are not broken down by incremental costs due to the difficulty in identifying with any more precision what those incremental costs are.  We utilized the lowest cost collection and analysis methodology consistent with the ultimate purpose and goals of mandatory electronic filing, which are to simplify and reduce filing burdens for applicants and review burdens for the Federal Government.  
	
As the Commission stated in the 2020 Application Fees Notice and adopted in the 2020 Application Fees Report and Order, the review of all ISPC applications includes industry analyst processing and review, staff attorney review, and supervisory attorney review.12  The Commission’s application fees are based on government costs for processing applications up through first line supervisor review.13  The Commission’s costs for review of applications up through the point of grant could, and in most instances will, exceed the costs through first line review.  For example, these costs might include staff time for follow-up inquiries with applicants for additional information, higher-level supervisory review, and ICFS administrative work related to granting and tracking applications.  The estimated Commission costs described below reflect these additional costs for complete processing and grant of ISPC applications. The review and processing of the applications will be performed by one employee at the GS-14/Step 5 grade level (attorney), up to two employees at the GS-15/Step 5 grade level (supervisor attorneys), and one employee at the GS-11/Step 5 grade level (Industry Analyst).  

Federal Government
Staff
Number of Staff
Salary Per Hour
Hourly
Cost
Annual Burden Hours
Annual Costs
GS-15/Step 5 Attorney
2
$91.93 
$183.86
15
$2,757.90
GS-14/Step 5 Attorney
1
$78.15 
$78.15
45
$3,516.75
GS-11/Step 5 Industry 
Analyst
1
$46.40 
$46.40
25
$1,160.00

4



$7,434.65

The combined cost to the Federal Government is $7,434.65.

15.  Explain the reasons for any program changes or adjustments. 

There are no program changes to this collection.  Section 8(b)(1) of the Communications Act of 1934, as amended (Communications Act or Act), requires the Commission, in every even-numbered year, to adjust the schedule of fees for processing applications to reflect increases or decreases in the Consumer Price Index (CPI), rounded to the nearest $5 increment.14  The cost burdens for this collection have been recalculated to account for the Commission’s revised application fees since OMB’s approval of this collection in 2023.15  For this reason, the estimated cost burden has increased from $13,300 to $13,570 (an increase (adjustment ) of $270).    

16.	For collections whose results will be published, outline the plans for tabulation and publication.

The Commission does not plan to publish the information for statistical use. 

17.	If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons why display would be inappropriate.
	
No waiver is necessary.  

18.	Exceptions to “Certification for Paperwork Reduction Submissions.”

There are no exceptions to the Certification Statement.

B.  Collections of Information Employing Statistical Methods.

This collection of information does not anticipate the use of statistical methods.