Draft/jstify

Status: Original and derived artifacts are available for this document.

Download: docx | pdf | html


SUPPORTING STATEMENT

A.  Justification:

The Federal Communications Commission (“Commission”) is requesting that the Office of Management and Budget (OMB) approve an extension of the delegated authority information collection titled “Data Network Identification Code (DNIC)” under OMB Control No. 3060-1029.  

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

A Data Network Identification Code (DNIC) is a unique, four-digit number designed to provide discrete identification of individual public data networks.  The DNIC is intended to identify and permit automated switching of data traffic to particular networks.  The DNIC is the central device of the international data numbering plan developed by the International Telecommunication Union (ITU) and set forth in Recommendation X.121.1  Prior to the availability of electronic web-based application forms in 1999, the Commission used an informal process for assigning DNICs.  Under the informal system, a company desiring a code would notify the Commission that it wishes one assigned and demonstrate that it has the ability to originate and terminate international traffic (e.g,, by showing an interconnection arrangement with a U.S. international carrier).  Then, the Commission would assign a DNIC to the requesting company.2  In 1986, the Commission established procedures for the DNIC assignments for interested data network operators.3  Today, the operators of public data networks file an application for a DNIC in ICFS.  The DNIC is obtained on a one-time only basis unless there is a change in company ownership or the owner chooses to relinquish the code to the Commission. 

ICFS Modernization of DNIC Electronic Forms.  The Commission has obtained OMB approval of revisions to its DNIC application form and the addition of new forms that are electronically filed through the Commission’s online, web-based electronic filing system – the International Communications filing system (ICFS).4    

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

The Commission obtains relevant information from operators of public data networks through their DNIC application requests filed through  ICFS.  This information is collected by the Commission to assign DNICs to the operators of public data networks, who then identify and permit automated switching of data traffic to particular networks.  
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), 309 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.

All applicants must file the DNIC application on the Commission’s ICFS.  The electronic collection of information expedites the Commission’s review and approval of DNIC applications for operators of public data networks.  A total of 100 percent of DNIC applications (DNC-NEW, DNC-WAV, and DNC-AMD) are filed with the Commission electronically in the ICFS.  ICFS allows filers to work more efficiently, which reduces the time and effort spent on the filing of DNIC applications.


4.   Describe efforts to identify duplication.

The Commission does not impose similar information collections on the respondents.  There are no similar data 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.

If the Commission does not conduct this collection to then assign DNICs to operators of public data networks, this would result in technical problems preventing the identification and automated switching of data traffic to particular networks.  

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

There are no special circumstances associated with this collection of information. 
The collection of information will not be conducted in any manner inconsistent with the guidelines 5 CFR 1320.

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, a 60-day notice was published in the Federal Register (91 FR 16698) to request comments from the public.  No comments were received from the public.

9.    Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.

The Commission will not provide any payment or gift to respondents.

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

There is no need for confidentiality of information contained in the applications filed with the Commission.  

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
Assignment Procedures for Data Network Identification Code5

1
4
4
Amendment of Pending DNIC Application 
1
2
2
Notification of Data Network Identification Code Implementation (Notification by letter  filed in the ISPC file)
1
0.5
0.5
Waiver of DNIC Application Requirements 
06
3
0
Totals:
3
0.5-4
6.5






 






Cumulative Total Number of Respondents  =  1 respondent
Cumulative Total Annual Responses = 3 responses
Cumulative Total Annual Burden Hours:  = 6.5 hours

Therefore, the respondent’s burden hours are:  4 (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 – 6.5 hours X 50% X $40 per hour = $130

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.7  The figure is based on a small survey of local firms in the D.C. area and is considered a conservative estimate.  

6.5 hrs. x 50% x $300 per hr. = $975 Total Outside Legal/Engineering Costs

Application Fees. The Commission adopted a new schedule of application fees in 2020 and updated it in 2022.8  The current fees are shown in the table below.9

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

New DNIC Filing
1
$920
$920
Waiver of DNIC Application Requirements
0
$375
0
Totals


$ 875
  
 (c)   	 Total Annual Cost Burden = $975 + $920 = $1,895

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 DNIC applications that applicants file annually, in accordance with OMB guidance.10  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 DNIC applications includes industry analyst processing and review, staff attorney review, and supervisory attorney review.11  The Commission’s application fees are based on government costs for processing applications up through first line supervisor review.12  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 DNIC 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

Total Hourly
Cost
Annual Burden Hours
Annual Costs
GS-15/Step 5 Attorney
2
$91.93 

$183.86
             3
$551.58
GS-14/Step 5 Attorney
1
$78.15 

$78.15
15
$1,172.25
GS-11/Step 5 Industry 
Analyst
1
$46.40 

$46.40
10
$464.00

4




$2,817.83
The combined cost to the Government is $2,187.83.
 
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.13  The cost burdens for this collection have been recalculated to account for revised application fees since OMB’s approval of this collection in 2023.14  For this reason, the estimated cost burden has increased from $1,850 to $1,895, an increase (adjustment) of $45.    

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

The results of this collection of information are not going to be published 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.

We do not seek approval to not display the expiration date for OMB approval of the information collection. 
  
18.  Exceptions to “Certification for Paperwork Reduction Submissions.”
There are no exceptions to the Certification Statement.
  	
B.  Collections of Information Employing Statistical Methods:

This information collection does not employ statistical methods.