Overview
Title
Information Collection Being Reviewed by the Federal Communications Commission Under Delegated Authority
Agencies
ELI5 AI
The FCC is asking people and other government groups to tell them what they think about the forms and information they collect to help track phone and internet rules. They want to make sure the forms are useful and clear, while also making it easier for little companies to fill them out.
Summary AI
The Federal Communications Commission (FCC) is inviting comments from the public and other federal agencies on its efforts to reduce paperwork, as part of the Paperwork Reduction Act of 1995. They are evaluating the necessity and utility of the information collected under the Communications Assistance for Law Enforcement Act (CALEA). The notice seeks feedback on various aspects, including the accuracy of the burden estimate, ways to improve information quality and clarity, and strategies to lessen the collection burden, especially on small businesses. The FCC emphasizes that this information collection cannot proceed without a valid control number from the Office of Management and Budget.
Abstract
As part of its continuing effort to reduce paperwork burdens, and as required by the Paperwork Reduction Act (PRA) of 1995, the Federal Communications Commission (FCC or the Commission) invites the general public and other Federal agencies to take this opportunity to comment on the following information collection. Comments are requested concerning: whether the proposed collection of information is necessary for the proper performance of the functions of the Commission, including whether the information shall have practical utility; the accuracy of the Commission's burden estimate; ways to enhance the quality, utility, and clarity of the information collected; ways to minimize the burden of the collection of information on the respondents, including the use of automated collection techniques or other forms of information technology; and ways to further reduce the information collection burden on small business concerns with fewer than 25 employees. The FCC may not conduct or sponsor a collection of information unless it displays a currently valid control number. No person shall be subject to any penalty for failing to comply with a collection of information subject to the PRA that does not display a valid Office of Management and Budget (OMB) control number.
Keywords AI
Sources
AnalysisAI
The document under discussion involves a notice from the Federal Communications Commission (FCC) inviting public and federal agency comments regarding an information collection initiative aligned with the requirements of the Paperwork Reduction Act (PRA) of 1995. The focus is on the Communications Assistance for Law Enforcement Act (CALEA), which aims to enhance electronic surveillance and law enforcement efficiency in the fast-evolving telecommunications landscape. Public feedback is sought to assess the necessity, utility, and burden of this information collection effort.
General Summary
The FCC is currently reviewing its procedures to collect information as required by CALEA. As part of this process, they are asking for input on several key areas. These include the necessity and utility of the information collected, the accuracy of the FCC's burden estimates, and potential improvements in information quality, clarity, and the methodology of collection. Importantly, there is an emphasis on minimizing the burden on small businesses with fewer than 25 employees. The commission underscores that the information collection process cannot proceed unless it is properly endorsed by a valid Office of Management and Budget (OMB) control number.
Significant Issues and Concerns
The document presents several issues that merit attention:
Complexity and Accessibility: The document contains numerous technical references and legislative language that might be difficult for the layperson or non-expert to fully understand. This suggests a need for more accessible language or additional definitions to ensure clarity for all stakeholders.
Cost Clarification: While the document states that there is "No Cost" associated with the information collection, further clarification is warranted to ensure that indirect or hidden costs do not pose an unforeseen burden.
Ambiguity in Mandates: The classification of obligations as both "Mandatory and Voluntary" is somewhat confusing. It is not clear how the requirements qualify under both categories, thus necessitating additional explanation.
Impact on Small Businesses: The FCC acknowledges the potential burden on small businesses but does not provide specific strategies for burden mitigation beyond a call for general suggestions. More concrete measures could be beneficial for these stakeholders.
Time Estimates: The wide range provided for estimated response time (5-80 hours) is notable. Further clarification could provide stakeholders with a better understanding of what to expect based on their specific circumstances or role in the process.
Broad Public Impact
The information collection initiative by the FCC aims to streamline the processes in telecommunications surveillance and compliance, which indirectly impacts the public by potentially enhancing law enforcement capabilities in identifying and intercepting criminal activities. However, the complexity and perceived burden of this initiative might discourage broader engagement and compliance.
Impact on Specific Stakeholders
For businesses, especially small enterprises, the burden of compliance with FCC regulations poses a significant consideration. The ambiguity surrounding the time and resources required might discourage participation or compliance. On a positive note, engaging small businesses in this feedback process could lead to more tailored solutions that reduce their burden and lead to more equitable regulatory processes. On the other hand, telecom carriers and providers are directly impacted as they need to continually update their systems and comply with mandatory reporting requirements.
In conclusion, while the initiative has worthy goals of improving legal frameworks and surveillance capabilities, addressing the outlined concerns through more accessible language, explicit cost and time clarifications, and enhanced stakeholder engagement could enhance its likely efficacy and implementation.
Issues
• The document uses technical terms and references to laws (e.g., CALEA, FCC rules) that may not be easily understood by those unfamiliar with telecommunications legislation, suggesting a need for simplified language or definitions.
• The document specifies no cost for the total annual cost of this information collection, which might need further clarification to ensure there are no hidden or indirect costs not accounted for.
• The use of mandates in 'Mandatory and Voluntary' could be confusing, as it is not clearly elaborated how both are applicable or how they are distinguished in context.
• The potential burden on small businesses (those with fewer than 25 employees) is referenced, but there is no specific mitigation strategy outlined beyond a generic statement of seeking ways to reduce the burden.
• The estimated time per response has a wide range (5-80 hours), which could be clarified to provide a more specific average or typical expected time to complete each response based on the type of entity or specific requirement.