Supporting Statement A

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FCC Application for Radio Service Authorization                                                        3060-0798 Wireless Telecommunications Bureau and Public Safety and Homeland Security    September 2026

SUPPORTING STATEMENT

The Federal Communications Commission (Commission) requests a revision from the Office of Management and Budget (OMB) for a currently approved information collection under OMB Control Number 3060-0798.
    A.  Justification 
    1. Circumstances that make this collection necessary.  FCC Form 601 is a consolidated, multi-part application form that is used for market-based and site-based licensing for wireless telecommunications services, including public safety, which are filed through the Commission’s Universal Licensing System (ULS) or any other electronic filing interface the Commission develops.  FCC Form 601 is composed of a main form that contains administrative information and a series of schedules used for filing technical and other information.  This form is used to apply for a new license, to amend or withdraw a pending application, to modify or renew an existing license, cancel a license, submit required notifications, request an extension of time to satisfy construction requirements, request an administrative update to an existing license (such as mailing address change), or request a Special Temporary Authority License. Respondents are required to submit FCC Form 601 electronically including when applying for an authorization for which the applicant was the winning bidder in a spectrum auction.

The data collected on FCC Form 601 includes the FCC Registration Number (FRN), which serves as a “common link” for all filings an entity has with the FCC.  The Debt Collection Improvement Act of 1996 requires entities filing with the Commission to use an FRN. 

Records such as Form 601 may include information about individuals or households, e.g., personally identifiable information or PII, and the use(s) and disclosure of this information are governed by the requirements of a system of records notice or “SORN”, FCC/WTB-1, “Wireless Services Licensing Records.”  There are no additional impacts under the Privacy Act.

The Commission now seeks OMB approval to renew the existing information collection allowances and approval for information collections on FCC Form 601, with revisions to reflect regulatory and information collection changes adopted in the following items: the 900 MHz Report and Order, Space Launch Services, License Reaggregation, changes regarding use of the 5.850–5.925 GHz Band, and Educational Broadband Service Reform.

900 MHz Report and Order.  On February 18, 2026, the Commission adopted a Report and Order, FCC 26-9, in WT Docket 24-99, modified by an erratum released  March 25, 2026, that established rules for the entire ten megahertz of the 896–901/935–940 MHz (900 MHz) band to be used for paired five megahertz broadband service.   The Report and Order modified the requirements in sections 27.1503(b) and (c) and 27.1505(b) through (d) to reflect the option for paired five megahertz broadband service, in addition to the existing paired three megahertz option.   

§ 27.1503 Broadband license eligibility and application requirements. Section 27.1503(b)(1) requires an applicant to file an application for a 900 MHz broadband license in accordance with part 1, subpart F of the Commission’s rules.  The 900 MHz broadband service is a service governed under part 27 of the Commission’s rules.  The Commission requests OMB approval to revise FCC Form 601 to add a new radio service code, and requests continued approval for two attachment types for the Eligibility Certification and Transition Plan now updated to allow for both 3/3 and 5/5 900 MHz broadband applications. Schedule N is a supplementary schedule for 900 MHz broadband service applicants to apply for the required license authorization in conjunction with the FCC 601 Main Form.  In Schedule N, 900 MHz broadband service applicants identify the market(s) to which the filing pertains and certifies that the applicant has attached an Eligibility Certification and Transition Plan, that the applicant will return licensed 900 MHz spectrum to the Commission, and that it will remit an anti-windfall payment if applicable. Additionally, the Commission also requests approval to add a new question to FCC Form 601 that will require 900 MHz broadband applicants to address any spectrum shortfall related to the anti-windfall payment requirement. 
Section 27.1503(b)(2) requires an applicant to file an Eligibility Certification as part of its application for either a 3/3 or 5/5 900 MHz broadband license. A 5/5 900 MHz broadband applicant must show that the applicant holds the required amount of licenses for the relevant county and that it will protect incumbent operators.  Section 27.1503(b)(3) requires an applicant to file a Transition Plan as part of its application for either a 3/3 or 5/5 900 MHz broadband license.  This Transition Plan must detail the agreements reached between the incoming licensee and incumbents or details of the process to relocate an incumbent to comparable facilities.
Section 27.1503(c)(1) requires a 5/5 broadband applicant to show that a 900 MHz Specialized Mobile Radio or Business/Industrial/Land Transportation licensee has returned the required amount of spectrum back to the Commission in exchange for 900 MHz broadband spectrum within a certain timeframe.  Section 27.1503(c)(2) requires applicants that relinquish less than the designated amount of spectrum to remit an anti-windfall payment prior to the grant of the 900 MHz broadband license.  
§ 27.1505 Performance requirements for 900 MHz broadband licenses.  Section 27.1505 establishes performance requirements for 3/3 and 5/5 900 MHz broadband licensees.  Section 27.1505(a) requires an applicant to file a construction notification in accordance with section 1.946(d) of the Commission’s rules.  An applicant files FCC Form 601 to file the construction notification, and this information collection is adjusted by adding a new radio service code for the 5/5 900 MHz broadband service.  Pursuant to section 27.1505(b), licensees can satisfy performance requirements through population or geographic coverage. 

Section 27.1505(b)(2) establishes interim and final performance deadlines for 3/3 and 5/5 licenses.  Section 27.1505(b)(3) establishes both interim and final performance deadlines for 5/5 900 MHz broadband licenses issued in exchange for a 3/3 900 MHz broadband license that has met its interim performance requirements but prior to its applicable final performance deadline for a 3/3 900 MHz license and exempts such licensee from an interim performance requirement for the 5/5 900 MHz broadband license. Section 27.1505(b)(4) establishes performance requirements for a 5/5 900 MHz broadband license issued in exchange for a 3/3 900 MHz broadband license after the 3/3 900 MHz broadband licensee has met its applicable final performance requirement.  Such a licensee will not be subject to an interim performance requirement for the 5/5 900 MHz broadband license.  The 900 MHz broadband licensees will demonstrate its compliance with section 27.1505(b) by filing an attachment to their FCC Form 601 construction notification filings.  FCC Form 601 will also be updated to include a question for 5/5 900 MHz broadband applicants that requires listing any current 3/3 900 MHz broadband licenses they hold for the relevant county. 

The Commission anticipates there will be a minimal impact on the burden for this collection. We estimate that one respondent could file an application for a 5/5 900 MHz broadband license.

Space Launch Services.  The Launch Communications Act, Public Law 118-85, 138 Stat. 1546, enacted September 26, 2024, required the Commission to adopt regulations allocating the 2025-2110 MHz, 2200-2290 MHz, and 2360-2395 MHz frequency bands on a secondary basis for commercial space launch and reentry operations, and adopt service rules including technical specifications, eligibility requirements, and coordination procedures to preserve the defense capabilities of the United States.  The Commission has met these requirements through the adoption of a new rule part, part 26.
Under the part 26 framework established by the Commission, eligible space launch operators seeking authorization to use frequencies available for Space Launch Services must first apply for and obtain a non-exclusive 10-year nationwide spectrum license.  After they obtain this license, operators must, for each launch (1) register in ULS the launch site and each corresponding station (fixed, base, itinerant, or mobile) that will be used in the space launch operation; (2) complete a frequency coordination process using a third-party frequency coordinator; and (3) following successful coordination, register in ULS the final approved technical and operating parameters associated with the coordinated launch prior to commencing the launch operation.  These requirements are codified in sections 26.106, 26.108, 26.202, and 26.301 of the rules, and the rule requirements are further elaborated in Public Notice, ET Docket No. 13-115, DA 25-270 (Space Launch Public Notice).
Space launch operators will rely on FCC Form 601 for several of these steps.  To apply for the nationwide non-exclusive license, operators will file an FCC Form 601 application.  When entering the Radio Service Code for which the applicant is applying, they will select a new radio service code designating Space Launch Services.  In addition, operators will submit both initial site and station registration and final launch registration through a new FCC Form 601 schedule, Schedule P.  
License Reaggregation.  On July 18, 2022, the Commission released a Report and Order and Second Further Notice of Proposed Rulemaking, FCC 22-53, in WT Docket No. 19-38, in which, among other measures, the Commission modified two rules, sections 1.929 and 1.950, 47 CFR §§ 1.929, 1.950, to permit the reaggregation of geographic-area-based wireless licenses (authorizations to engage in wireless transmission in specified frequencies and over a defined geographic area).  Reaggregation is the consolidation into a single license of two or more licenses that were the result of a previous spectrum disaggregation (dividing a license into two or more licenses that cover different frequencies) and/or geographic area partitioning (dividing a license into two or more licenses that cover different geographic areas).  The Commission amended 1.929 and 1.950 to authorize licensees to reaggregate covered geographic licenses, subject to certain eligibility prerequisites, and required that licensees seeking approval for a reaggregation must file an application for a license modification using FCC Form 601.  As amended, section 1.950 further provides that applicants for reaggregation must include the following five attachments with the application: 
    (1) A certification that the licenses meet the prerequisites for reaggregation specified in section 1.950; 
    (2) An electronic map and table that together identify all licenses and spectrum to be aggregated and identify the composite license requested;
    (3) A certification that all licenses in the reaggregation request are active under the same FCC Registration Number at the time of filing;
    (4) A per-license list of all special conditions and a statement acknowledging that the listed special conditions will continue to apply only to that portion of the reaggregated license with respect to the spectrum and/or geography at issue, as if the license had not been reaggregated; and
    (5) A per-license list of all waivers granted and a statement of understanding that the listed waiver(s) do not automatically convey to any other portion of the reaggregated license. If applicable, the applicant shall include a statement indicating that it is seeking waiver relief through a separately filed waiver request seeking to expand the scope of previously granted relief.
The Commission found that codifying a formal process for reaggregation would ease the administrative burden on both licensees and Commission staff from more ad hoc approaches and create more certainty that a license holder could reaggregate partitioned or disaggregated licenses in the future, which would eliminate a potential reason not to partition or disaggregate in the first instance.  Thus, this measure will help to incentive secondary market transactions.
Use of the 5.850–5.925 GHz Band. In the First Report and Order released on November 20, 2020 (ET Docket No. 19‑138, FCC 20‑164), the Commission determined that the most efficient use of the 75 megahertz in the 5.9 GHz band is to expand unlicensed operations in the lower 45 megahertz (5.850–5.895 GHz) and to reserve the upper 30 megahertz (5.895–5.925 GHz) for the Intelligent Transportation Service (ITS) using cellular vehicle‑to‑everything (C‑V2X) technology. Dedicated Short Range Communications (DSRC) stations must discontinue operations in the 5895–5925 MHz portion of the band by December 14, 2026. No new DSRC station license applications were accepted after February 11, 2025.
FCC Form 601 Schedule M currently collects technical information for the DSRC Service under Part 90 Subpart M. In line with the Commission’s actions in the 5.9 GHz Report and Order, the Commission proposes removing DSRC references and incorporating the new C‑V2X service into FCC Form 601, along with corresponding updates to the Universal Licensing System (ULS) database.
We anticipate that these modifications—removing DSRC information and adding C‑V2X data requirements—will not increase the burden or cost associated with completing FCC Form 601 and implementing updates to the ULS database.
Educational Broadband Service Reform.  In a Report and Order released July 11, 2019, WT Docket No. 18-120, FCC 19-62, the Commission adopted certain measures to reform the regulatory framework governing the 2495-2690 MHz band (2.5 GHz band).  This band includes 112.5 megahertz designated for Educational Broadband Service (EBS).  Under section 27.1203 of the Commission’s rules, EBS licensees were required to use their spectrum specifically to further their educational missions.  Among other steps taken in the Report and Order, the Commission eliminated this requirement, removing section 27.1203 from the rules.
FCC Form 601 currently includes Question 54, which serves to implement section 27.1203, asking “(For EBS only) Does the Applicant comply with the programming requirements contained in 47 CFR § 27.1203?”  Consistent with the Commission’s action in the 2.5 GHz Report and Order, the Commission seeks to remove Question 54 from FCC Form 601, and to eliminate the associated reference to this question and section 27.1203 in the Instructions.
We do not anticipate that this revision, which requests no new information and simply eliminates one question, will result in any additional burden or cost to complete FCC Form 601. 
Conclusion. The Commission seeks approval for a revision to its currently approved information collection on FCC Form 601 to incorporate the changes discussed above.
Statutory authority for this information collection is contained in 47 U.S.C. §§ 151, 152, 154, 154(i), 155(c), 157, 161, 201, 202, 208, 214, 301, 302a, 303, 307, 308, 309, 310, 311, 314, 316, 319, 324, 331, 332, 333, 336, 534, 535, and 554, and section 2 of the Launch Communications Act, Pub. L. No. 118-85, 138 Stat. 1546 § 2.
    2. Use of Information.  The Commission, in accordance with its statutory responsibilities under the Communications Act of 1934, as amended, uses the information provided by applicants on FCC Form 601 to update its licensing database and to determine if the applicant is legally, technically, and financially qualified to provide licensed services and make proper use of the frequency spectrum.  

The 900 MHz requirements will be used by Commission personnel in evaluating the applicant’s need for such frequencies and to minimize the interference potential to other stations operating on the proposed frequencies. 

The new licensing requirements for space launch operations will be used by the Commission to provide space launch operators access to the protected spectrum they need for commercial launch operations. Registration of space launch site and station data will help to facilitate post-licensing frequency coordination by the frequency coordinator and other stakeholders.  The Commission will use the data in post-coordination launch registrations to authorize space launch operations under operational and technical parameters that have cleared the frequency coordination process and to verify compliance with the Space Launch Service technical rules.  

Regarding reaggregation, the additional attachments requested specifically for reaggregation applications will be used by the Commission to determine if applicants meet the requirements for license reaggregation as well as to implement any approved reaggregation.  

    3. Technological collection techniques.   Electronic filing is mandatory for all respondents as specified in 47 CFR §1.913.  Prior to finalizing rulemakings, the Commission conducts an analysis to ensure that improved information technology cannot be used to reduce the burden on the public.  This analysis considers the possibility of obtaining and/or computer-generating the required data from existing data bases in the Commission or other federal agencies

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

    5. Impact on small entities.  In conformance with the Paperwork Reduction Act of 1995, the Commission makes an effort to minimize the burden of information collection on all its applicants regardless of size.  In addition, pursuant to the Small Business Paperwork Relief Act of 2002, Public Law 107-198, see 44 U.S.C. § 3506(c)(4), the Commission previously sought specific comment in the record proceeding on how it might further reduce the information collection burden for small business concerns with fewer than 25 employees.  

    6. Consequences if information is not collected. This information collection is critical for the Commission to be able to license wireless spectrum. The frequency of filing FCC Form 601 is determined by the applicant and/or licensee and the frequency of response can be on occasion or periodic.

    7. Special circumstances. This information collection as currently approved does not have any of the characteristics that would require separate justification under 5 C.F.R. § 1320.5(d)(2).

    8. Federal Register notice; efforts to consult with persons outside the Commission.  The Commission published a notice in the Federal Register pursuant to 5 CFR § 1320.8(d) on July 27, 2026 (91 FR 46917), seeking comments from the public on the information collection requirements contained in this supporting statement.  No comments were received following publication of this notice.

    9. Payments or gifts to respondents.  Respondents will not receive any payments or gifts.  

    10. Assurance of confidentiality.  The information collected under this collection will be made publicly available, however, to the extent information submitted pursuant to this information collection is determined to be confidential, it will be protected by the Commission.  If a respondent seeks to have information collected pursuant to this information collection withheld from public inspection, the respondent may request confidential treatment pursuant to section 0.459 of the Commission’s rules for such information.  See 47 C.F.R. § 0.459.  

    11. Questions of a sensitive nature.  The information collection requirements do not ask questions of a sensitive nature and the PII is covered by the system of records notice or ‘SORN’, FCC/WTB-1, “Wireless Services Licensing Records.”

    12. Estimates of the hour burden of the collection to respondents. 
The current applicant burden in the OMB Inventory for the Form 601 is: 255,552 Responses,  225,808 Burden Hours.   The Commission estimated that 255,552 respondents (applicants/licensees) file FCC Form 601 applications annually and that the average burden per response is 1.25 hours. 
The Commission estimated that 50% of the 255,552 respondents (127,776) complete the application themselves with no additional assistance and the remaining 50% (127,726) will contract out the completion of the form to a law firm or application preparation service.  
The Commission estimated the average burden per response to be approximately 1.25 hours for those respondents completing the forms themselves.  For those respondents hiring a consultant, we estimate a burden of approximately 30 minutes (0.5 hours) to coordinate with the consultant. 
The estimated annual burden is:
127,776 responses x 1.25 hours = 159,720 hours
127,776 responses x .50 hours   =   63,888 hours 
Annual burden:  159,720 hours + 63,888 hours = 223,608 hours.
The Commission also estimates that between zero and 400 entities will annually file FCC Form 601 applications regarding eligibility for designated entity benefits.  We therefore estimate that there will be 400 such entities.
The Commission estimates that 50% of these 400 respondents (200) will complete the application themselves with no additional assistance and the remaining 50% (200) will contract out the completion of the form to a law firm or application preparation service.  
The Commission estimates the average burden per response to be approximately 1.25 hours for those respondents completing the form themselves.  For those respondents hiring a consultant, we estimate a burden of approximately 45 minutes (0.75 hours) to coordinate with the consultant.  The estimated annual burden is:
200 responses x 1.25 hour     =  250 hours
200 responses x 0.75 hours    = 150 hours
Annual burden hours:  250 hours + 150 hours = 400 hours 
The Commission also estimates that thirty (30) 900 MHz entities will hire a consultant, such as a law or engineering firm, to produce documentation and exhibits to support their FCC Form 601 applications.  The Commission estimates that the 30 respondents will each annually file supporting documents for two applications for a total of 60 responses with an average burden of 30 hours to produce such documents.
 The estimated annual burden is:
		60 responses x 30 hours = 1,800 hours
	total annual burden hours in the omb inventory:  223,608 + 400 + 1,800 = 225,808
	Total Number of Respondents: 255,552
	Total Number of Responses: 255,552
Commission Rules require that certain applicants obtain frequency coordination prior to submitting their application to the FCC.  We estimate that approximately 40% of the total respondents (102,221) respondents are required to comply with frequency coordination requirements.  There is no additional time burden placed on the respondent for this third-party disclosure requirement, however, it adds an extra “step” to the application filing requirements. Applicants forward their applications via the non-profit private sector frequency coordinators designated by type of radio service to the FCC.  The frequency coordinator then forwards the application and application remittance to the FCC.  The frequency coordinator must file electronically.

The increase to the existing burden to reflect the regulatory changes adopted in the 900 MHz Report and Order, Space Launch Services, and License Reaggregation are:
The Commission estimates that one 900 MHz entity will hire a consultant, such as a law or engineering firm, to produce documentation and exhibits to support their FCC Form 601 applications.1 We estimate this entity will file 66 applications per year. 
Since the applicant will contract the preparation of the 900 MHz 5/5 applications, the estimated annual burden is:
900 MHz Applications Total Annual Burden = 66 responses x .5 hours = 33 hours
Space Launch	
Average additional respondents filing Form 601 annually to meet Space Launch requirements: 24.  Of this 24 we estimate that annually, 8 will file for an initial license or a renewal license.  
The Commission estimated that 50% of the 8 respondents (4) complete the application themselves with no additional assistance and the remaining 50% (4) will contract out the completion of the form to a law firm or application preparation service.  
The Commission estimated the average burden per response to be approximately 1.25 hours for those respondents completing the forms themselves.  For those respondents hiring a consultant, we estimate a burden of approximately 30 minutes (0.5 hours) to coordinate with the consultant.
	4 responses x 1.25 hours = 5 hours
	4 responses x 0.5 hours = 2 hours
	Initial/Renewal Application: 5 hours + 2 hours = 7 hours
Additionally, it is estimated 24 Space Launch Respondents will file 200 site/station registrations and 200 final launch registrations. The Commission estimated that 50% of the 400 responses (200) complete the application themselves with no additional assistance and the remaining 50% (200) will contract out the completion of the form to a law firm or application preparation service.  
The Commission estimated the average burden per response to be approximately 1.25 hours for those respondents completing the forms themselves.  For those respondents hiring a consultant, we estimate a burden of approximately 30 minutes (0.5 hours) to coordinate with the consultant.
	200 responses x 1.25 hours = 250 hours
	200 responses x 0.5 hours = 100 hours
	Site/Station registration and final launch  250 hours + 100 hours = 350 hours 
Additionally, the Commission estimates that 40 of the applications filing space launch site/station registrations will include requests for use of greater than 5 megahertz.  The Commission estimated that 50% of the 40 responses (20) complete the application themselves with no additional assistance and the remaining 50% (20) will contract out the completion of the form to a law firm or application preparation service.  
The Commission estimated the average burden per response to be approximately one hour for those respondents completing the forms themselves.  For those respondents hiring a consultant, we estimate a burden of approximately 15 minutes (0.25 hours) to coordinate with the consultant.
	The estimated annual burden is:
	20 responses x 1 hour = 20 hours
 	20 responses x 0.25 hour = 5 hours
Space Launch Applications Total Burden Hours = 7 + 350 + 25 = 382

Reaggregation
The Commission estimates we will receive 24 applications for license reaggregation. The Commission estimated that 50% of the 24 responses (12) complete the application themselves with no additional assistance and the remaining 50% (12) will contract out the completion of the form to a law firm or application preparation service.  
The Commission estimated the average burden per response to be approximately 1.25 hours for those respondents completing the forms themselves.  For those respondents hiring a consultant, we estimate a burden of approximately 30 minutes (0.5 hours) to coordinate with the consultant.

12 responses x 1.25 hours = 15 hours
12 responses x 0.5 hours = 6
All 24 reaggregation applications are required to provide an additional attachment describing the reaggregation details. We estimated the applicant will prepare this information in-house and it will require an additional 3 hours per application 
24 responses x 3 hours = 72 hours
Reaggregation Applications Total Burden  Hours =  21 + 72 = 93

The total increases in burden and the number of respondents for the revisions to the collection are:
Burden Hours:  (900 MHz) 33 hours + (Space Launch) 382 hours + (Reaggregation) 93 hours = 508 Hours
Responses: (900 MHz) 66 + (Space Launch) 408 + (Reaggregation) 24 = 498 Responses  
Respondents: (900 MHz) 1 + (Space Launch) 24 + (Reaggregation) 24 = 49



Total Burden Hours Requested: (Current OMB Inventory) 225,808 +  (Increase) 508 = 226,316
Total Number of Responses:  (Current OMB Inventory) 255,552 + (Increase) 498 = 256,0502
Total Number of Respondents: (Current OMB Inventory) 255,552 + (Increase ) 49 = 255,601

“In-House Cost”: The “In-House” Cost (for the burden currently in the inventory)
Assuming that 50% of the respondents use personnel comparable in pay to a mid-to-senior level federal employee (GS-13, Step 5) to prepare the collection, we estimate the cost to be about $66.14 per hour @ 1.25 hours per filing.  The cost per filing: $66.14x 1.25 = $82.68.
	127,776 x $82.68 per filing = $10,564,520
The Commission estimates that 50% will contract out the completion of the form to a law firm or application preparation service and will spend approximately 30 minutes (0.5 hours) coordinating this information. Assuming they use personnel comparable in pay to a mid-to-senior level federal employee (GS-13, Step 5) to coordinate this submission we estimate the cost to be approximately $66.14 per hour @ 0.5 hours per filing.  The cost per filing = $33.07
	127,776 x $33.07 = 4,225,552 
Assuming that 50% of the respondents filing the 601 annually for designated entity benefits use personnel comparable in pay to a mid-to-senior level federal employee (GS-13, Step 5) to prepare the collection, we estimate the cost to be about $66.14 per hour @ 1.25 hours per filing. The cost per filing is $82.68.
	200 responses x $82.68 per response = $16,536
The Commission estimates that 50% filing will contract out the completion of the form to a law firm or application preparation service and will spend approximately 30 minutes (0.5 hours) coordinating this information.  Assuming they use personnel comparable in pay to a mid-to-senior level federal employee (GS-13, Step 5 to coordinate the submission we estimate the cost to be approximately $66.14 per hour @.5 hours per filing. The cost per filing = $66.14 x 0.5 = $33.07
	200 responses x $33.07 per response = $6,614 
	TOTAL IN-HOUSE COSTS (currently in the inventory): 
	$10,564,520 + $4,225,552 + $16,536 + $6,614 = $14,813,222 

In-House Costs for the 900 MHz Revision
Assuming one applicant will file 66 responses using contract personnel comparable in pay to a mid-to-senior level federal employee (GS-13, step 5)  to prepare the collection, we estimate the cost to be about $66.14 per hours @ 0.5 hours per filing to coordinate with this contractor.  The cost per filing is: $66.14 x 0.5 = $33.07
In-house Cost for 900 MHz = 66 responses X $33.07 = $2,183

Space Launch “In-House” Costs 
The Commission estimated that 50% of the 8 respondents (4 responses) will complete the initial or renewal filing themselves use personnel comparable in pay to a mid-to-senior level federal employee (GS-13, Step 5) to prepare the collection, we estimate the cost to be about $66.14 per hour @ 1.25 hours per filing. The cost per filing is $82.68. 
	4 responses x $82.68 = $331
The remaining 50% of the 8 respondents (4 responses) will contract out the completion of the form to a law firm or application preparation service using contract personnel comparable in pay to a mid-to-senior level federal employee (GS-13, step 5)  to prepare the initial or renewal application, we estimate the cost to be about $66.14 per hours @ 0.5 hours per filing to coordinate with this contractor.  The cost per filing is: $66.14 x 0.5 = $33.07
	4 responses x $33.07 = $132
Additionally, it is estimated 24 Space Launch Respondents will file 200 site/station registrations and 200 final launch registrations. The Commission estimated that 50% of the 400 responses (200) will use personnel comparable in pay to a mid-to-senior level federal employee (GS-13, Step 5) to prepare the collection, we estimate the cost to be about $66.14 per hour @ 1.25 hours per filing. The cost per filing is $82.68.
	200 responses x $82.68 = $16,536
The remaining 50% (200 responses) will contract out the completion of the form to a law firm or application preparation service using contract personnel comparable in pay to a mid-to-senior level federal employee (GS-13, step 5)  to prepare the initial or renewal application, we estimate the cost to be about $66.14 per hours @ 0.5 hours per filing to coordinate with this contractor.  The cost per filing is: $66.14 x 0.5 = $33.07.
 	200 responses x $33.07 = $6,614
For the 40 space launch/site registrations including requests for use of greater than 5 megahertz  We estimate 50% will prepare the application in house We estimate preparing this attachment in-house will increase the burden for these applications by one hour .  Assuming they use personnel comparable to a mid-to-senior level federal employee (GS-13, Step 5) to prepare the application we estimate  the cost to be approximately $66.14 per hour@ 1 hour per filing. The cost per filing  = $66.14.
	20 responses X $66.14 = $1,323
The applications prepared by counsel or a third party service will require 15 minutes for the applicants to coordinate their services . Assuming they use personnel comparable to a mid-to-senior level federal employee (GS-13, Step 5) to coordinate the application preparation services we estimate  the cost to be approximately $66.14 per hour@ 15 minutes (.25 hours) per filing. The cost per filing  = $16.54.
	20 responses X $16.54 = $331
“In-House” Costs for Space Launch = $331 + $132 + $16,536 + $6,614 + $1,323 + $331 = $25,267

Reaggregation “In-House” Costs
The Commission estimated that 50% of the 24 respondents (12 responses) will complete the initial or renewal filing themselves use personnel comparable in pay to a mid-to-senior level federal employee (GS-13, Step 5) to prepare the collection, we estimate the cost to be about $66.14 per hour @ 1.25 hours per filing. The cost per filing is $82.68. 
	12 responses x $82.68 = $992
The remaining 50% of the 24 respondents (12 responses) will contract out the completion of the form to a law firm or application preparation service using contract personnel comparable in pay to a mid-to-senior level federal employee (GS-13, step 5)  to prepare the initial or renewal application, we estimate the cost to be about $66.14 per hours @ 0.5 hours per filing to coordinate with this contractor.  The cost per filing is: $66.14 x 0.5 = $33.07
	12 responses x $33.07 = $397
For the 24 reaggregation applications requiring an additional attachment, we estimate that all attachments will be prepared in-house.  We estimate preparing an attachment in-house will increase the burden by 3 hours.  Assuming they use personnel comparable to a mid-to-senior level federal employee (GS-13, Step 5) to prepare the attachment, we estimate  the cost to be approximately $66.14 per hour@ 3 hours per filing. The cost per filing  = $198.42.
	24 responses x $198.42 = $4,762

“In-House” Costs for the Revisions: 
$2,183 + $331 + $132 + $16,536 + $6,614 + $1,323 + $331 +  $992 + $397 + $4,762 = $34,262
TOTAL IN-HOUSE COST3:  
	Current Inventory $14,813,222 + Revisions  $34,262 = $14,847,484

    13. Cost to the Respondent: 
    a. Total annualized capital/start-up costs: $0.00
    b. Total annualized cost requested to prepare FCC 601 are:

	There is no cost to file the application electronically with the FCC. 
FCC application filing fees:
We estimate that approximately 75% of 256,050 various applications filed require an application fee of $65-$430 each. (The balance of the respondents would be exempt from filing fees due to type of entity, i.e. public safety, governmental entities, non-commercial educational broadcasters, or because the purpose for which they are filing does not require a fee.)  
For purposes of this submission, we estimate the total application fees using an average of $125 per filing:
256,050 total responses x 75% (feeable) = 192,038 feeable filings

192,038 filings x $125 average fee = $24,004,750

We estimate that 50% of the respondents will contract out the completion of the form and would use an attorney or application preparation service at a cost of $300/hour to prepare the FCC 601 and take the consultant 1.25 hours to complete each form.

128,025 applications x 1.25 hours x $300/hour = $48,009,375
Regarding 900 MHz respondents submitting documentation and exhibits in support of their applications:
We estimate that the respondents will use an attorney or engineering firm at a cost of $300 per hour to prepare the documentation and exhibits supporting 66 applications.  Preparation of the supporting documents is estimated to take 30 hours per application.
66 applications x 30 hours x $300 = $594,000
For 20 Space Launch filings we anticipate requests for usage greater than 5 MHz:
We estimate that the respondent will use an attorney or engineering firm at the cost of $300 per hour to prepare the documentation. Preparation of this supporting documentation is estimated to take one hour per application.
20 application  x 1 hour x $300 = $6,000
TOTAL ESTIMATED RESPONDENT COST: $24,004,750 + $48,009,375 + $594,000 + $6,000 = 72,614,125 
  14.  Cost to the Federal Government:

	FCC Form 601 Applications estimated to be filed:  256,050

	128,025 applications x 30 mins. (0.50 hrs)
	@ $31.35 per hour (GS-7 Step 5) for an			=	$2,006,792	(Processing)
	Industry Analyst

	128,050 applications x 10 mins. (0.166 hrs) 		=	$666,385	(Processing)
	@ $31.35 per hour (GS-7 Step 5) for an
	Industry Analyst

			  		   Total		=	$2,673,177

15. There are program changes/increases of 49 to the number of respondents, 498 to the annual number of responses, 508 to the annual burden hours and $140,125 to the annual cost for this collection.  These program changes/increases are due to the information collections adopted in the various rulemaking and public notice mentioned under question #1 in this supporting statement.

16.  The data will not be published for statistical use.

17.  The Commission is requesting a continued waiver from displaying the OMB expiration date on FCC Form 601.  Granting this waiver will prevent the Commission from destroying excess forms, having to update computer versions and thus reduce waste. All OMB-approved information collections are displayed on OMB’s website which includes the . OMB control number, title of the collection and the OMB expiration date.

18.  There are no exceptions to the “Certification Statement.”  


Collections of Information Employing Statistical Methods: 

This information collection does not use any statistical methods.