Overview
Title
Information Collection Being Reviewed by the Federal Communications Commission
Agencies
ELI5 AI
The FCC wants people to tell them if collecting certain information is helpful or if it's too much work, especially for small businesses. They're also seeing if there are better ways to do this and want opinions by June 20, 2025.
Summary AI
The Federal Communications Commission (FCC) is inviting comments from the public and other Federal agencies on a proposed information collection effort as part of the Paperwork Reduction Act of 1995. This involves evaluating whether the information collected is necessary for the FCC’s functions, how to improve the quality and clarity of this information, and ways to reduce the burden on businesses, particularly small ones. The FCC is focusing on compliance with rules that address robocall mitigation and caller ID authentication under various Acts and Orders, requiring service providers to certify their efforts and document specific practices to enforce compliance with regulations. Comments should be submitted by June 20, 2025.
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.
Keywords AI
Sources
AnalysisAI
The document released by the Federal Communications Commission (FCC) relates to their ongoing efforts to manage and potentially reduce paperwork burdens as mandated by the Paperwork Reduction Act of 1995. The FCC is appealing to both the general public and other Federal agencies to share their comments on a proposed information collection. The core aim is to assess whether collecting this information is necessary for the FCC to effectively carry out its duties and how this process can be improved. By doing so, the FCC seeks to enhance the clarity and utility of the information while also considering ways to reduce the burden on businesses, especially smaller ones.
Summary of the Document
The document details the FCC’s intention to ensure compliance with regulations that address robocall mitigation and caller ID authentication. It is rooted in various legislative acts including the TRACED Act and outlines specific requirements for voice service providers. These include implementing caller ID authentication technologies and robust robocall mitigation programs. Furthermore, providers are expected to certify their compliance in the Robocall Mitigation Database and provide proof of participation in relevant industry groups.
Significant Issues and Concerns
A notable issue arises from the document’s estimation of a total annual burden of 39,450 hours, which is not broken down or justified. Without this, there is a lack of clarity on whether all efforts are necessary or if there are opportunities to streamline and reduce this burden. Additionally, the document claims "Total Annual Cost: No Cost," which may not account for indirect costs associated with compliance, such as employee time or opportunity costs.
Another concern is the requirement for entities to update information in the CORES database within 10 business days of any changes. This could place a significant burden on smaller organizations with limited administrative resources. Moreover, the guidelines for mandatory participation in working groups or consortia are vague, which might lead to inadequate or inconsistent documentation.
The introduction of mandatory written agreements for third-party involvement is another area of complexity. While intended to ensure proper compliance, this requirement could lead to additional legal costs and uncertainties for providers, particularly those lacking clear guidance on agreement contents.
Impact on the Public
Broad Impact
The public is impacted broadly by the FCC's efforts to mitigate robocalls and ensure caller ID authenticity, aiming to improve the integrity of communications networks. However, these regulatory measures could indirectly influence service costs, as providers may pass on compliance costs to consumers, despite the noted "no cost" assertion.
Impact on Specific Stakeholders
For businesses, particularly small entities, these regulations present both a challenge and an opportunity. Although compliance may involve navigating complex legal and technical requirements, ultimately resulting in increased administrative load and potential costs, the measures aim to create a safer communication environment. However, without ample guidance and resources tailored to address their needs, smaller enterprises might struggle disproportionately under the weight of these requirements.
In conclusion, while the FCC's efforts are well-intentioned and aim to bolster consumer protection against robocalls, the execution and communication of these regulations need further refinement to avoid undue burden on smaller businesses and ensure the sweeping benefits reach all intended recipients effectively.
Issues
• The document does not provide a breakdown or justification for the estimated total annual burden of 39,450 hours, which could potentially indicate inefficiencies or areas where burden reduction is possible.
• The document does not specify any associated costs, stating 'Total Annual Cost: No Cost,' which might overlook indirect costs or the opportunity costs of the required time investment by respondents.
• The requirement for all entities and individuals to update information submitted to CORES within 10 business days of any change might impose undue burden, especially on smaller organizations with limited administrative resources.
• The language regarding mandatory participation in working groups, industry standards groups, or consortia is vague and does not specify the criteria or standards for acceptable documentation of participation.
• The need for written agreements for third-party involvement in the caller ID authentication process adds complexity and potential legal costs without clear guidance on what should be included in such agreements.
• While the goals of the STIR/SHAKEN implementation and robocall mitigation are clear, the technical language and regulatory references might be difficult for smaller businesses without specialized legal or technical expertise to fully understand.