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Report to the Honorable Edward J. Markey, House of Representatives: 

United States Government Accountability Office: 
GAO: 

January 2010: 

Telecommunications: 

Information Collection and Management at the Federal Communications 
Commission: 

GAO-10-249: 

GAO Highlights: 

Highlights of GAO-10-249, a report to the Honorable Edward J. Markey, 
House of Representatives. 

Why GAO Did This Study: 

The Federal Communications Commission (FCC) regulates industries that 
affect the lives of virtually all Americans. FCC-regulated industries 
provide Americans with daily access to communications services, 
including wireline and wireless telephone, radio, and television. To 
ensure FCC is carrying out its mission, the commission requires a 
significant amount of information, such as ownership and operating 
information from radio and television stations. In prior reports, GAO 
has found weaknesses with FCC’s information collection, management, 
and reporting processes. While FCC has taken action, the commission 
has not implemented all the recommendations associated with 
information collection, management, and reporting. 

As requested, this report provides information on (1) the information 
FCC collects; (2) how FCC collects and manages information; (3) the 
strengths and weaknesses, if any, in FCC’s information collection and 
management practices; and (4) the status of FCC’s internal review of 
its information collection and management practices. To complete this 
work, GAO gathered information on FCC’s information collection 
efforts, reviewed information collection and management practices for 
30 collection instruments, interviewed agency officials and industry 
stakeholders, and reviewed relevant laws and guidance. FCC provided 
comments which discuss its efforts to improve data management. 

What GAO Found: 

FCC gathers a wide variety of information though information 
collection instruments. FCC gathers information through 413 collection 
instruments approved by the Office of Management and Budget (OMB). 
Through these OMB-approved collection instruments, FCC gathers 
information pertaining to (1) required company filings, such as the 
ownership of television stations; (2) applications for FCC licenses; 
(3) consumer complaints; (4) company financial and accounting 
performance; and (5) a variety of other issues, such as an annual 
survey of cable operators. FCC estimates that it receives nearly 385 
million responses with an estimated 57 million burden hours associated 
with the 413 collection instruments. 

FCC’s bureaus and offices collect and manage most commission 
information following commissionwide programs, policies, and 
procedures. FCC articulates its commissionwide programs, policies, and 
procedures in several directives, including its records management 
program. These directives help ensure FCC’s compliance with 
governmentwide laws and regulations. Since FCC’s bureaus and offices 
are the primary users of information, implementing decisions generally 
occur at that level. According to GAO’s review of 30 information 
collections, FCC’s bureaus and offices collect and manage information 
in a variety of ways. For example, FCC collects and manages 14 of the 
30 information collections electronically, while it collects and 
manages some information in paper format. FCC disseminates information 
from 11 of the 30 information collections on its Web site, while it 
disseminates some information upon request, but in a redacted format. 

According to GAO’s review of 30 information collections, FCC’s bureaus 
and offices appear to follow commission- and governmentwide guidance, 
such as quality control procedures and safeguards for sensitive 
information. However, prior GAO reports and some stakeholders 
identified certain weaknesses with FCC’s information collection and 
management practices. These weaknesses concern FCC’s information 
collection processes and the accuracy of the estimated burden hours 
associated with FCC’s information collections. For example, GAO 
recently reported that FCC rarely includes the text of a proposed rule 
in its Notice of Proposed Rulemaking, and stakeholders similarly noted 
that FCC does not initially specify the information that it wants to 
gather in the notice; the lack of specificity makes it harder for 
stakeholders and the public to provide meaningful input on the 
proposed information collection instrument. 

Recognizing the need to improve the commission’s information 
practices, in July 2009, FCC’s Chairman initiated a review of the 
commission’s systems and processes. The Chairman sought to address 
whether (1) new information should be collected, (2) existing 
information reporting requirements could be streamlined or eliminated, 
and (3) existing technology and management processes could be 
modernized in order to make the commission’s use of information more 
efficient and effective. FCC staff have taken several steps to 
implement the review and the effort continues. 

View GAO-10-249 or key components. For more information, contact David 
Wise at (202) 512-2834 or wised@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

FCC Uses OMB-Approved Collection Instruments to Gather a Wide Variety 
of Information on the Industries That It Regulates: 

FCC Bureaus and Offices Collect and Manage Most of the Commission's 
Information Following Commissionwide Programs, Policies, and 
Procedures: 

FCC's Bureaus and Offices Follow Commission-and Governmentwide 
Guidance, but Prior GAO Reports and Some Stakeholders Identified 
Certain Weaknesses in FCC's Information Collection and Management 
Practices: 

FCC Is Currently Reviewing Its Information Management Processes: 

Agency Comments: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Comments from the Federal Communications Commission: 

Appendix III: Contact and Acknowledgments: 

Tables: 

Table 1: GAO Reports Identifying Weaknesses with Certain Information 
Collection, Management, and Reporting Efforts at FCC: 

Table 2: Description of FCC Bureau Responsibilities: 

Table 3: FCC's OMB-Approved Information Collection Instruments by 
Bureau and Office, as of April 2009: 

Table 4: FCC's OMB-Approved Information Collection Instruments by Type 
and Category, as of April 2009: 

Abbreviations: 

APA: Administrative Procedure Act: 

CD: compact disc: 

CIO: chief information officer: 

FCC: Federal Communications Commission: 

FISMA: Federal Information Security Management Act of 2002: 

FNPRM: Further Notice of Proposed Rulemaking: 

NARA: National Archives and Records Administration: 

NPRM: Notice of Proposed Rulemaking: 

NOI: Notice of Inquiry: 

OMB: Office of Management and Budget: 

OSPPA: Office of Strategic Planning and Policy Analysis: 

PERM: Performance Evaluation and Records Management: 

PRA: Paperwork Reduction Act: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

January 29, 2010: 

The Honorable Edward J. Markey: 
House of Representatives: 

Dear Mr. Markey: 

The Federal Communications Commission (FCC) regulates industries that 
affect the lives of virtually all Americans. FCC-regulated industries 
provide Americans with daily access to a variety of communications 
services, including wireline and wireless telephone, Internet access, 
radio, and television. FCC's mission is to ensure that the American 
people have available at reasonable cost and without discrimination, 
rapid, efficient, nationwide, and worldwide communication services 
whether by radio, television, wire, wireless, satellite, or cable. To 
carry out its mission, FCC has to collect and manage a significant 
amount of information. For example, FCC obtains information on (1) 
broadband Internet access connections to households and businesses, 
(2) license applications for radio and television stations, (3) 
wireline telephone companies' finances and operations, and (4) 
consumer complaints. 

We have previously reported that to be successful in measuring 
performance, agencies generally need to collect sufficiently complete, 
accurate, and consistent information.[Footnote 1] Yet, in reports 
examining FCC's programs and operations, we have found weaknesses in 
certain information collection, management, and reporting processes. 
For example, in a recent report, we found that limitations in FCC's 
current approach for collecting and analyzing enforcement data create 
challenges for the commission in carrying out its enforcement 
responsibilities.[Footnote 2] Another report found that FCC's 
information for assessing competition for dedicated access service 
(telecommunications service with guaranteed capacity, high service 
levels, and security purchased by government agencies and businesses) 
was significantly limited in describing the presence, extent, or 
change in competition in any given area.[Footnote 3] Table 1 provides 
information on our previous reports and the status of our 
recommendations to FCC. Recognizing the need to improve the 
commission's information practices, on July 22, 2009, FCC's Chairman 
initiated a top-to-bottom review of the commission's systems and 
processes. 

Table 1: GAO Reports Identifying Weaknesses with Certain Information 
Collection, Management, and Reporting Efforts at FCC: 

Report: GAO-06-425; 
Topic: FCC's enforcement of junk fax laws; 
Findings: 
* Guidance to consumers does not provide all of the information 
necessary to support enforcement efforts; 
* Majority of consumer complaints not considered in making decisions 
about investigations and enforcement; 
* Inefficient data management resulting in time-consuming manual entry 
and errors; 
Recommendations to FCC: 
* Revise its complaint form and guidance to consumers; 
* Develop data management strategies to make the consumer complaint 
database more usable; 
Status of recommendations: 
* Recommendations implemented; 
* FCC revised its complaint form and guidance to consumers; 
* FCC requests information only for the specific complaint type, and 
when possible, the complainant selects prespecified answers to 
questions, which eliminates the need for staff to interpret 
information, thereby improving data management. 

Report: GAO-07-80; 
Topic: Competition for dedicated access service; 
Findings: 
* Data measure potential competition at one point in time and are not 
revisited or updated; 
* Data collected from external parties through rulemaking proceedings, 
but those parties have no obligation to provide data, and FCC has 
limited mechanisms to verify the reliability of the data; 
Recommendations to FCC: 
* Consider collecting additional data and developing additional 
measures to monitor competition on an ongoing basis; 
Status of recommendations: 
* Recommendation not implemented; 
* FCC initially disagreed that it needed to better define competition 
and collect additional data; 
* FCC released a Public Notice inviting comment on an appropriate 
analytical framework for examining dedicated access. 

Report: GAO-08-125; 
Topic: FCC's program to enforce relevant laws and rules; 
Findings: 
* Enforcement Bureau uses five separate databases and manually 
searches paper case files to track and monitor enforcement actions; 
* Lack of systematic data on why enforcement actions are closed; 
Recommendations to FCC: 
* Improve how it collects and analyzes data on complaints received; 
Status of recommendations: 
* Recommendation not implemented; 
* FCC initially said it implemented measures that addressed the 
recommendation; however, we disagreed; 
* FCC recently began developing and implementing upgrades to its 
Consumer Complaint Management and Enforcement Bureau Activity Tracking 
System. 

Report: GAO-08-383; 
Topic: Number and ownership of media outlets, such as radio and 
television stations; 
Findings: 
* Exemptions from filing information on gender, race, and ethnicity 
for certain types of broadcast stations; 
* Inadequate data quality procedures; for example, lacking 
verification; 
* Problems with data storage and retrieval that hinder electronic 
queries; 
Recommendations to FCC: 
* Identify processes and procedures to improve the reliability of its 
data on gender, race, and ethnicity; 
Status of recommendations: 
* Recommendation implemented; 
* FCC revised its rules and procedures to limit exemptions, enhance 
data quality, and improve data retrieval. 

Source: GAO. 

Note: This table includes recommendations pertaining to information 
collection, management, and reporting. In some instances, the reports 
included other recommendations not identified in this table. 

[End of table] 

In response to your request, we examined FCC's information collection 
and management practices across the agency. Specifically, we addressed 
(1) the information FCC collects; (2) how FCC collects and manages 
information; (3) the strengths and weaknesses, if any, in FCC's 
information collection and management practices; and (4) the status of 
FCC's internal review of its information collection and management 
practices. We examined the extent to which FCC has commissionwide 
information collection and management procedures and the commission's 
bureaus, and offices, adherence to those procedures. As such, we did 
not assess whether individual information collection and management 
efforts were adequate to meet FCC's policy or rulemaking mission. 
Further, we did not review FCC's collection of information through its 
rulemaking process. 

To describe the information that FCC collects, we obtained information 
as of April 2009 on the 413 collection instruments that the Office of 
Management and Budget (OMB) approved through the Paperwork Reduction 
Act (PRA).[Footnote 4] We interviewed FCC officials about the various 
types of information the commission collects. To describe how FCC 
collects and manages its information, we prepared two questionnaires 
for FCC officials; these questionnaires sought information on 
information collection, management, dissemination, and retention and 
disposal for 30 OMB-approved information collection instruments. To 
select the 30 information collection instruments, we initially asked 
FCC for the repository (e.g., the database where the information 
resides) associated with each of its OMB-approved information 
collection instruments; FCC officials said the commission could not 
readily provide that information because it does not maintain its 
records in such a manner. In response, we adopted an alternative, 
multistep approach. Specifically, we (1) asked FCC to categorize its 
OMB-approved collection instruments by activity or use (e.g., licenses 
and surveys), (2) determined the average burden hours associated the 
various categories, (3) established three strata based on the average 
burden hours (greater than 46,803 hours, 46,803 hours to 17,904 hours, 
and less than 17,904 hours) and selected one category from each of the 
first two strata and two categories from the third stratum,[Footnote 
5] and (4) judgmentally selected collection instruments from the four 
categories. We received responses for all 30 OMB-approved information 
collection instruments. Of the 30 responses, 9 pertained to collection 
instruments where the reporting entity or a third-party entity 
maintains the information; we used two questionnaires, one for 
information collection instruments where FCC maintains the information 
and one for information collection instruments where the reporting 
entity or a third-party entity maintains the information. We reviewed 
FCC policies and procedures to determine the guidance the commission 
has established for managing information, and we interviewed FCC 
officials to determine how the commission carries out its procedures. 
We also reviewed relevant laws and regulations on procedures for 
collecting and managing information. To identify the strengths and 
weaknesses in FCC's information collection and management practices, 
we compared the 30 responses from the questionnaires with the 
commission's internal policies and procedures and federal guidance on 
information collection and management practices. We also interviewed 
19 stakeholders, including representatives from communication 
companies, industry trade associations, consumer and public interest 
groups, state regulators, and academic and industry experts. We 
selected these stakeholders to include a cross section of industries 
regulated by FCC, including radio and television broadcasters, cable 
television operators, satellite operators, and wireline and wireless 
telephone companies, as well as parties representing consumers and 
regulators that are affected by the commission's policies and 
rulemaking. We also reviewed prior GAO reports and other relevant 
literature for best practices for the collection and management of 
information. 

We performed this performance audit from December 2008 to January 2010 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our review objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. A detailed 
discussion of our scope and methodology appears in appendix I. 

Background: 

Under the Communications Act, as amended, FCC regulates interstate and 
international communications by radio, television, wire, satellite, 
and cable.[Footnote 6] FCC regulates these industries by carrying out 
various activities, including issuing licenses for radio and 
television broadcast stations; overseeing the licensing, enforcement, 
and regulatory functions of cellular telephones and other personal 
communication services; regulating the use of the radio spectrum and 
conducting auctions of licenses for use of the spectrum; investigating 
consumer complaints and taking enforcement actions for violations of 
communications laws and commission rules; addressing public safety, 
homeland security, emergency management, and preparedness; educating 
and informing consumers about telecommunications goods and services; 
and reviewing mergers of companies holding FCC-issued licenses. FCC 
carries out these responsibilities using its 7 bureaus and 10 offices. 
Table 2 provides descriptions of each bureau's responsibilities. 

Table 2: Description of FCC Bureau Responsibilities: 

Bureau: Consumer and Governmental Affairs Bureau; 
Responsibility: The Consumer and Governmental Affairs Bureau develops 
and implements the commission's consumer policies, including 
disability access. The bureau conducts consumer outreach and education 
and maintains a Consumer Center that responds to consumer inquiries 
and complaints. The bureau also maintains collaborative partnerships 
with state, local, and tribal governments in areas such as emergency 
preparedness and implementation of new technologies. 

Bureau: Enforcement Bureau; 
Responsibility: The Enforcement Bureau is responsible for enforcing 
provisions of the Communications Act, FCC's rules and orders, and the 
terms and conditions of station authorizations. Major areas of 
enforcement that are handled by the Enforcement Bureau are (1) 
consumer protection enforcement, (2) local competition enforcement, 
and (3) public safety/homeland security enforcement. 

Bureau: International Bureau; 
Responsibility: The International Bureau represents the commission in 
satellite and international matters. This includes advising the 
Chairman and commissioners on matters of international 
telecommunications policy and the status of the commission's actions 
to promote the vital interests of the American public in international 
commerce, national defense, and foreign policy areas. The bureau also 
develops, recommends, and administers policies, rules, and procedures 
for the authorization and regulation of international 
telecommunications facilities and service and domestic and 
international satellite systems. 

Bureau: Media Bureau; 
Responsibility: The Media Bureau develops, recommends, and administers 
the policy and licensing programs relating to electronic media, 
including cable television, broadcast television, and radio in the 
United States and its territories. The Media Bureau also handles 
postlicensing matters regarding Direct Broadcast Satellite service. 

Bureau: Public Safety and Homeland Security Bureau; 
Responsibility: The Public Safety and Homeland Security Bureau is 
responsible for developing, recommending, and administering the 
agency's policies pertaining to public safety communications issues. 
These policies include 911 and enhanced 911 service, operability and 
interoperability of public safety communications, communications 
infrastructure protection and disaster response, and network security 
and reliability. The bureau also serves as a clearinghouse for public 
safety communications information and takes the lead on emergency 
response issues. 

Bureau: Wireless Telecommunications Bureau; 
Responsibility: The Wireless Telecommunications Bureau handles all FCC 
domestic wireless telecommunications programs and policies, except 
those involving public safety, satellite communications, or 
broadcasting, including licensing, enforcement, and regulatory 
functions. Wireless communications services include cellular 
telephone, paging, personal communications services, and other 
commercial and private radio services. The bureau also regulates the 
use of radio spectrum to fulfill the communications needs of business, 
aircraft and ship operators, and individuals. Finally, the bureau is 
responsible for implementing the competitive bidding authority for 
spectrum auctions. 

Bureau: Wireline Competition Bureau; 
Responsibility: The Wireline Competition Bureau develops and 
recommends policy goals, objectives, programs, and plans for the 
commission on matters concerning wireline telecommunications. The 
Wireline Competition Bureau's overall objectives include ensuring 
choice, opportunity, and fairness in the development of wireline 
telecommunications services and markets; developing deregulatory 
initiatives; promoting economically efficient investment in wireline 
telecommunications infrastructure; promoting the development and 
widespread availability of wireline telecommunications services; 
and fostering economic growth. 

Source: FCC. 

[End of table] 

To fulfill its responsibilities, FCC requires regulated entities, such 
as companies and licensees, in the communications industry that it 
regulates to maintain records, submit information, or disclose 
information to others. For example, television stations are required 
to provide FCC with information relating to construction permits, 
license renewals, and ownership. When collecting and managing 
information, FCC must adhere to various laws and regulations and 
coordinate with various entities. 

* Paperwork Reduction Act. The PRA requires agencies, such as FCC, to 
obtain approval for each information collection instrument that meets 
the requirements of the PRA from OMB.[Footnote 7] Before approving a 
collection instrument, OMB is required to determine that the agency's 
collection of information is necessary for the proper performance of 
the functions of the agency, including whether the information will 
have practical utility.[Footnote 8] Consistent with the PRA's 
requirements, OMB has established a process to review all proposals by 
agencies to collect information from 10 or more persons, whether the 
collections are voluntary or mandatory. OMB's approval of each 
information collection instrument usually expires within 3 years, and 
agencies must periodically ask for an extension until the collection 
is no longer needed. 

* Records management by federal agencies. As required by statute, the 
head of each federal agency must establish and maintain an active, 
continuing program for the economical and efficient management of the 
agency's records.[Footnote 9] The agency must provide for effective 
controls over the creation, maintenance, and use of records in the 
conduct of current business. Further, the agency must cooperate with 
the Administrator of General Services and the Archivist in applying 
standards, procedures, and techniques designed to improve the 
management of records; promote the maintenance and security of records 
deemed appropriate for preservation; and facilitate the segregation 
and disposal of records of temporary value.[Footnote 10] 

* Federal Information Security Management Act of 2002 (FISMA). FISMA 
requires the head of each agency to provide information security 
protections commensurate with the risk and magnitude of harm resulting 
from unauthorized access, use, disclosure, disruption, modification, 
or destruction of information collected or maintained by or on behalf 
of the agency.[Footnote 11] 

* Additional requirements. In addition to the requirements established 
by the various laws, federal agencies must follow regulations 
promulgated by agencies such as OMB and the National Archives and 
Records Administration (NARA). For example, OMB established policy for 
managing information through its A-130 Circular.[Footnote 12] NARA 
provides federal agencies with guidance on the management of records 
and other types of documentary materials and assists agencies in 
creating and maintaining accurate and complete records of an agency's 
functions and activities and in ensuring the authorized, timely, and 
appropriate disposition of documentary materials.[Footnote 13] 

To develop new rules or modify existing rules, including rules 
pertaining to information collection instruments, FCC initiates a 
rulemaking process.[Footnote 14] When implementing a rulemaking 
process, FCC must follow the procedures set forth in the 
Administrative Procedure Act (APA).[Footnote 15] The APA generally 
requires a "notice and comment" or "notice and comment rulemaking" 
process to ensure that stakeholders and the public have adequate 
opportunity to participate in agencies' rulemaking processes. In 
particular, the APA requires agencies, in most cases, to publish a 
notice of proposed rulemaking in the Federal Register and give 
interested parties an opportunity to comment on the proposed rule or 
rule change by providing "written data, views, or arguments."[Footnote 
16] FCC generally collects information through the following methods. 

* Notice of Inquiry (NOI). FCC releases a NOI to gather information 
about a broad subject or as a means of generating ideas on a specific 
issue. 

* Notice of Proposed Rulemaking (NPRM). FCC issues a NPRM to propose 
new rules or changes to its existing rules. The NPRM must include 
either the terms or substance of the proposed rule or a description of 
the subjects and issues involved and seek public comment on the 
proposal.[Footnote 17] 

* Further Notice of Proposed Rulemaking (FNPRM). After reviewing 
comments in the NPRM, FCC can issue a FNPRM regarding specific issues 
raised in the process. The FNPRM provides an opportunity for the 
public to comment further on a related or specific proposal. 

FCC Uses OMB-Approved Collection Instruments to Gather a Wide Variety 
of Information on the Industries That It Regulates: 

As of April 2009, FCC used 413 OMB-approved information collection 
instruments to gather information, maintain records, or disclose 
information; however, the amount of information collected and managed 
varied by bureau or office.[Footnote 18] Responsibility for these 
collections is spread across 10 FCC bureaus and offices (see table 3). 
The Media, Wireline Competition, and Wireless Telecommunications 
bureaus are responsible for almost three-quarters of the collections, 
with 139, 85, and 74 collections, respectively. The estimated number 
of responses also varies significantly by bureau or office. For 
example, both the Wireline Competition and Consumer and Governmental 
Affairs bureaus anticipate over 140 million individual responses 
annually to their collection instruments, whereas the Enforcement 
Bureau anticipates fewer than 10,000.[Footnote 19] The burden 
associated with submitting the information also varies by bureau or 
office; according to the PRA, the term "burden" means the time, 
effort, or financial resources expended by persons to generate, 
maintain, or provide information to a federal agency.[Footnote 20] The 
Consumer and Governmental Affairs Bureau estimates over 39 million 
hours for its collection instruments, more than the other bureaus and 
offices combined; other bureaus with over 1 million estimated annual 
burden hours include the Media, Wireline Competition, and Wireless 
Telecommunications bureaus. 

Table 3: FCC's OMB-Approved Information Collection Instruments by 
Bureau and Office, as of April 2009: 

Bureau or office: Media Bureau; 
Number of collection instruments: 139; 
Estimated number of responses: 26,060,594; 
Estimated annual burden hours: 7,204,822. 

Bureau or office: Wireline Competition Bureau; 
Number of collection instruments: 85; 
Estimated number of responses: 146,943,153; 
Estimated annual burden hours: 6,485,604. 

Bureau or office: Wireless Telecommunications Bureau; 
Number of collection instruments: 74; 
Estimated number of responses: 2,160,965; 
Estimated annual burden hours: 2,661,209. 

Bureau or office: International Bureau; 
Number of collection instruments: 30; 
Estimated number of responses: 21,238; 
Estimated annual burden hours: 163,968. 

Bureau or office: Consumer and Governmental Affairs Bureau; 
Number of collection instruments: 27; 
Estimated number of responses: 188,981,121; 
Estimated annual burden hours: 39,194,033. 

Bureau or office: Office of Engineering and Technology; 
Number of collection instruments: 21; 
Estimated number of responses: 2,099,423; 
Estimated annual burden hours: 653,411. 

Bureau or office: Public Safety and Homeland Security Bureau; 
Number of collection instruments: 19; 
Estimated number of responses: 18,092,277; 
Estimated annual burden hours: 856,821. 

Bureau or office: Office of Managing Director; 
Number of collection instruments: 8; 
Estimated number of responses: 319,066; 
Estimated annual burden hours: 68,812. 

Bureau or office: Enforcement Bureau; 
Number of collection instruments: 7; 
Estimated number of responses: 9,906; 
Estimated annual burden hours: 10,944. 

Bureau or office: Office of General Counsel; 
Number of collection instruments: 3; 
Estimated number of responses: 12,515; 
Estimated annual burden hours: 9,230. 

Bureau or office: Total; 
Number of collection instruments: 413; 
Estimated number of responses: 384,700,258; 
Estimated annual burden hours: 57,308,854. 

Source: FCC. 

[End of table] 

FCC collects a wide variety of information through its 413 OMB-
approved information collection instruments. In response to our 
request, FCC placed each of its 413 collection instruments in a 
category based on the industry and/or purpose. FCC identified 21 
categories, and we further organized these 21 categories into five 
groups (see table 4). As shown in the table, there is significant 
variation in the number of collection instruments and estimated number 
of responses and annual burden hours across the 21 categories. We 
provide a description of the types of information collection 
instruments below. 

Table 4: FCC's OMB-Approved Information Collection Instruments by Type 
and Category, as of April 2009: 

Type: Requirements; 
Category industry/purpose: Wireless licensee requirements; 
Number of collection instruments: 59; 
Estimated number of responses: 1,221,133; 
Estimated annual burden hours: 1,352,762. 

Type: Requirements; 
Category industry/purpose: Wireline carrier requirements; 
Number of collection instruments: 58; 
Estimated number of responses: 161,134,039; 
Estimated annual burden hours: 2,991,155. 

Type: Requirements; 
Category industry/purpose: Broadcast licensee requirements; 
Number of collection instruments: 51; 
Estimated number of responses: 2,652,838; 
Estimated annual burden hours: 4,279,656. 

Type: Requirements; 
Category industry/purpose: Cable system requirements; 
Number of collection instruments: 42; 
Estimated number of responses: 22,752,312; 
Estimated annual burden hours: 1,703,044. 

Type: Requirements; 
Category industry/purpose: Public safety licensee requirements; 
Number of collection instruments: 19; 
Estimated number of responses: 18,092,277; 
Estimated annual burden hours: 856,821. 

Type: Requirements; 
Category industry/purpose: Equipment authorizations and experimental 
radio requirements; 
Number of collection instruments: 15; 
Estimated number of responses: 408,850; 
Estimated annual burden hours: 372,594. 

Type: Requirements; 
Category industry/purpose: Satellite and earth station license 
requirements; 
Number of collection instruments: 16; 
Estimated number of responses: 805; 
Estimated annual burden hours: 26,381. 

Type: Requirements; 
Category industry/purpose: Digital television requirements; 
Number of collection instruments: 13; 
Estimated number of responses: 534,687; 
Estimated annual burden hours: 438,178. 

Type: Requirements; 
Category industry/purpose: Broadcast and cable equal employment 
opportunity reporting requirements; 
Number of collection instruments: 6; 
Estimated number of responses: 40,836; 
Estimated annual burden hours: 623,432. 

Type: Applications; 
Category industry/purpose: Satellite and earth station license 
applications; 
Number of collection instruments: 14; 
Estimated number of responses: 20,433; 
Estimated annual burden hours: 137,587. 

Type: Applications; 
Category industry/purpose: Broadcast and cable license applications; 
Number of collection instruments: 24; 
Estimated number of responses: 71,083; 
Estimated annual burden hours: 143,204. 

Type: Applications; 
Category industry/purpose: Public safety and wireless license 
applications; 
Number of collection instruments: 10; 
Estimated number of responses: 916,259; 
Estimated annual burden hours: 916,032. 

Type: Applications; 
Category industry/purpose: Equipment authorizations and experimental 
radio license applications; 
Number of collection instruments: 6; 
Estimated number of responses: 1,690,573; 
Estimated annual burden hours: 280,817. 

Type: Complaints; 
Category industry/purpose: Consumer complaints and enforcement; 
Number of collection instruments: 28; 
Estimated number of responses: 164,805,662; 
Estimated annual burden hours: 39,072,069. 

Type: Financial and accounting; 
Category industry/purpose: Universal service fund; 
Number of collection instruments: 12; 
Estimated number of responses: 8,286,676; 
Estimated annual burden hours: 2,147,053. 

Type: Financial and accounting; 
Category industry/purpose: FCC financial operations; 
Number of collection instruments: 8; 
Estimated number of responses: 319,066; 
Estimated annual burden hours: 68,812. 

Type: Financial and accounting; 
Category industry/purpose: Wireline carrier accounting; 
Number of collection instruments: 15; 
Estimated number of responses: 19,218; 
Estimated annual burden hours: 268,538. 

Type: Other; 
Category industry/purpose: Spectrum auctions[A]; 
Number of collection instruments: 6; 
Estimated number of responses: 30,628; 
Estimated annual burden hours: 401,893. 

Type: Other; 
Category industry/purpose: Telecommunications relay service[B]; 
Number of collection instruments: 5; 
Estimated number of responses: 1,685,365; 
Estimated annual burden hours: 126,626. 

Type: Other; 
Category industry/purpose: Surveys; 
Number of collection instruments: 3; 
Estimated number of responses: 4,978; 
Estimated annual burden hours: 1,092,970. 

Type: Other; 
Category industry/purpose: Legal procedures; 
Number of collection instruments: 3; 
Estimated number of responses: 12,515; 
Estimated annual burden hours: 9,230. 

Total: 
Number of collection instruments: 413; 
Estimated number of responses: 384,700,258; 
Estimated annual burden hours: 57,308,854. 

Source: FCC. 

[A] In many instances, to use the electromagnetic spectrum, an entity 
(such as a wireless telephone company) must receive a license from 
FCC. To award some licenses, FCC conducts auctions where the highest 
bidder pays for and receives the license. 

[B] Telecommunications relay service allows persons with hearing or 
speech disabilities to place and receive telephone calls. 

[End of table] 

* Requirements. FCC-defined information collection instruments for 
requirements span a wide variety of industries, including wireless and 
wireline telephone, broadcasting, cable, equipment, and public safety. 
FCC regulations require companies to provide a variety of information. 
For example, the Wireline Competition Bureau has 58 collection 
instruments of this type, including employment reports and local 
number portability for wireline telephone companies. The Wireless 
Telecommunications Bureau has 59 collection instruments of this type, 
such as reports on interference. 

* Applications. Regulated entities, such as companies and individuals, 
seeking to provide certain services must apply for and receive a 
license from FCC. For example, the Media Bureau gathers license 
application information from companies seeking to provide radio and 
television broadcast service. The Office of Engineering and Technology 
gathers license application and equipment authorization information 
from companies seeking to market new wireless equipment, such as 
wireless telephones. 

* Complaints. FCC collects consumer complaints on a variety of 
problems through OMB-approved information collection instruments. 
These complaints include a wide variety of problems such as deceptive 
or unlawful advertising or marketing; obscene, profane, and/or 
indecent material on broadcast radio or television; slamming, the 
illegal practice of changing a consumer's telephone service without 
permission; and accessibility of communications services to persons 
with disabilities. 

* Financial and accounting. The Wireline Competition Bureau collects 
information pertaining to both wireline carrier accounting and the 
universal service fund. The wireline carrier accounting collections 
include a variety of company submissions, such as information on 
rates, costs, investment, and customer satisfaction. The universal 
service fund collections include submissions necessary to pay into or 
receive payment from the universal service fund.[Footnote 21] We also 
include collection instruments for FCC's financial operations in this 
group; these collections include, for example, documents for FCC's 
regulatory fees.[Footnote 22] 

* Other. These information collection instruments pertain to a variety 
of topics. For example, the Media, Wireline Competition, and Wireless 
Telecommunications bureaus conduct surveys of cable television 
operators, companies providing broadband service, and participants in 
FCC's spectrum auctions, respectively. The Consumer and Governmental 
Affairs Bureau collects information pertaining to telecommunications 
relay service, which allows persons with hearing or speech 
disabilities to place and receive telephone calls. The Wireless 
Telecommunications Bureau uses collection instruments to receive 
applications for participants in spectrum auctions and auction 
participants seeking bidding credits.[Footnote 23] 

FCC Bureaus and Offices Collect and Manage Most of the Commission's 
Information Following Commissionwide Programs, Policies, and 
Procedures: 

FCC has established commissionwide programs, policies, and procedures 
for the collection and management of information; FCC articulates 
these policies and procedures in its records management program, forms 
management program, security policies and procedures, and information 
system protection. However, since bureaus and offices are the primary 
users of information, implementing decisions generally occur at the 
bureau or office level. On the basis of responses to our 
questionnaires about 30 OMB-approved information collection 
instruments, FCC's bureaus and offices collect and manage information 
in a variety of different ways. 

FCC Has Commissionwide Programs, Policies, And Procedures For Managing 
And Maintaining Information: 

FCC has four primary directives that establish procedures for 
commission staff to follow for collecting and managing information. 
These directives help ensure FCC's compliance with governmentwide laws 
and regulations pertaining to information collection and management, 
such as the PRA and FISMA. 

Records management program. By statute, the head of each federal 
agency must establish and maintain an active, continuing program for 
the economical and efficient management of all records of the agency. 
[Footnote 24] To meet this requirement, FCC established a records 
management program that sets out the policies, procedures, and 
activities needed to manage the commission's recorded information. 
[Footnote 25] The objectives of FCC's records management procedures 
are to: 

* accurately and completely document the policies and transactions of 
the commission; 

* control the quantity and quality of records produced by the 
commission; 

* establish and maintain mechanisms of control to promote effective 
and economical operations of the commission; 

* simplify the activities, systems, and processes of creating, 
maintaining, and using records; and: 

* judiciously preserve and dispose of records. 

Within the Office of Managing Director, FCC's Performance Evaluation 
and Records Management (PERM) staff carry out procedures to establish 
and oversee the records management program. The procedures require 
PERM staff to review and evaluate the program by conducting (1) on-
site inspections, (2) annual reviews of all bureau and office records 
control schedules, and (3) reviews of bureau and office submissions of 
record holdings. 

Forms management program. FCC has a forms management program to comply 
with statutory, regulatory, and policy requirements for federal forms. 
[Footnote 26] The objectives of the forms management program are to 
ensure (1) forms are directly linked to accomplishing specific 
missions of the commission; (2) forms are properly designed with clear 
instructions to make it easy as possible for respondents to provide 
information requested in the least amount of time; and (3) forms make 
effective and efficient use of electronic technologies for creating, 
collecting, distributing, and using these forms to record, store, and 
disseminate information. The procedures state that each bureau and 
office chief is responsible for, among other things, ensuring that 
forms are created, maintained, and disposed of in conformance with the 
commission's records management program. 

Security policies and procedures. FCC has security policies and 
procedures for the management and safeguarding of all nonpublic 
information.[Footnote 27] FCC has two categories of nonpublic 
information: 

1. "Highly sensitive/restricted" information is defined as information 
that is highly market sensitive (i.e., disclosure of which is likely 
to substantially affect the value of securities traded publicly or a 
company's market valuation) or other commercial or financial 
information the commission considers confidential and highly 
sensitive. For example, according to FCC officials, information that 
is submitted to FCC's Disaster Information Reporting System may 
contain commercial information that could affect competition among 
wireless, wireline, broadcast, and cable providers and is treated as 
confidential by FCC. 

2. "Internal use only" information is defined as all other nonpublic 
information not routinely available for inspection. For example, FCC 
maintains information for internal use only that allows its crisis 
incident managers to coordinate activities in the telecommunications 
industry and FCC in the event of a crisis. This internal document has 
contact information for FCC employees, other federal government 
agencies, state and local governments, and the communications industry. 

According to these procedures, the bureau or office creating or using 
nonpublic information is responsible for determining in which category 
the information should be placed. FCC's procedures are designed to 
safeguard the nonpublic information in all formats including, but not 
limited to, paper, computer files, e-mails, diskettes, CDs, audio and 
video recordings, and oral communications. Among other things, the 
policies and procedures require that nonpublic information must be 
disposed of in a locked document disposal bin; such bins are located 
throughout FCC headquarters. 

Information systems protection. FCC has established policy to help 
ensure that adequate levels of protection exist for all FCC 
information systems,[Footnote 28] including the FCC network, 
applications and databases, and information created, stored, or 
processed.[Footnote 29] FCC's Chief Information Officer (CIO) has 
primary responsibility for managing the commission's policy. The 
policy states that the CIO's responsibilities include (1) evaluating 
and approving the resolution of issues relating to information 
security, (2) developing and maintaining an agencywide information 
security program, and (3) training and overseeing personnel with 
significant responsibilities for information security. FCC also has a 
Chief Information Security Officer responsible for (1) developing 
plans for providing adequate information security for networks, 
facilities, and systems or groups of information systems; (2) 
conducting periodic assessments of the risk and magnitude of the harm 
that could result from the unauthorized access, use, disclosure, 
disruption, modification, or destruction of information and 
information systems that support the operations and assets of the 
agency; and (3) developing plans and procedures to ensure continuity 
of operations for information systems that support the operations and 
assets of the agency. 

Bureaus And Offices Are Primarily Responsible For Collecting And 
Managing The Commission's Information: 

FCC's policies and procedures for managing information are primarily 
carried out at the bureau or office level. As the primary users of 
information, FCC's bureaus and offices manage most of the commission's 
information collected through OMB-approved collection instruments. The 
previously mentioned records management guidance, which was 
established by PERM, gives bureau and office chiefs authority to 
establish their own procedures for managing records and ensuring staff 
observe guidelines. According to FCC officials, bureaus and offices 
are allowed to establish their own procedures. However, officials also 
said that they are not aware of any bureaus and offices that have 
officially done so. Similarly, officials with the bureaus and offices 
with whom we spoke said that they use the commissionwide guidance to 
manage their information and have no additional internal information 
procedures. 

According to responses to our questionnaires about 30 OMB-approved 
information collection instruments, FCC's bureaus and offices collect 
and manage information in various ways based on the type of 
information. As mentioned previously, a reporting entity or third-
party entity maintains the information associated with some FCC 
collection instruments. In those instances, certain questions 
pertaining to information collection, management, dissemination, and 
retention and disposal are not applicable. Therefore, we used two 
questionnaires, one for collection instruments where FCC maintains the 
information and one for collection instruments where the reporting 
entity or a third-party entity maintains the information. Of the 30 
responses we received, FCC maintains the information for 21 collection 
instruments; for the remaining 9 collection instruments, the reporting 
entity or third party maintains the information. Most of the following 
analysis pertains to the 21 collection instruments where FCC maintains 
the information. 

Information collection. Respondents to our questionnaire reported that 
they collect information in different formats, including electronic, 
paper, and compact disc (CD). For the 21 collection instruments where 
FCC maintains the information, 14 respondents reported that the 
reporting entity submits information to the bureau or office in an 
electronic format. For example, one respondent reported that cost and 
revenue information from telephone companies, such as AT&T and 
Verizon, is submitted electronically to FCC. In three instances, the 
respondent reported that the bureau or office receives the information 
in a paper format. For example, 1 respondent reported that entities 
using certain radio frequency identification devices are required to 
submit their information on paper to register the location of these 
devices.[Footnote 30] Additionally, 3 respondents reported receiving 
electronic and paper submissions, and 1 respondent reporting receiving 
both paper and CD submissions. 

The frequency of the collection also varied among the information 
collection instruments. Nine information collections are annual. For 
example, one respondent reported that FCC collects information 
annually from a sample of cable operators on average rates charged for 
the basic cable service, cable programming service tiers, and cable 
equipment. The frequency of the collection for the remaining 
collection instruments varied, from onetime submissions when filing an 
application to triennial filings. 

Information management. After collecting the information, bureaus and 
offices manage it in various ways. For all 30 collection instruments, 
15 respondents reported that the bureau or office stores the 
information in a database. As we discussed previously, in nine 
instances the reporting entity or a third party maintains the 
information. The remaining respondents to our questionnaire reported 
that the bureau or office stores information in an internal network 
system or a file cabinet. 

Respondents to our questionnaire reported that bureaus and offices use 
several quality control procedures to ensure the accuracy of 
information. For example, three respondents reported that information 
systems run validity checks that ensure (1) certain data do not fall 
outside a reasonable range for that data and (2) all data have been 
submitted as required. A respondent reported that drop-down menus for 
individuals submitting data electronically provide checks on the 
quality of the data, as do pop-up warnings for data entries outside of 
the expected reasonable range. Other respondents reported that staff 
review the information for completeness and accuracy. For the 9 
collection instruments wherein the reporting entity or a third party 
maintains the information, 4 respondents reported that the bureau or 
office may randomly select items for review, request the records be 
provided to the commission, and review the records for compliance with 
the commission rules; 3 respondents reported that the bureau or office 
does not verify the information. In terms of correcting errors, some 
respondents reported that the bureau or office contacts the individual 
or organization that submitted the information and asks that entity to 
make corrections. Other respondents reported that the bureau or office 
will contact the individual or organization and ask for clarification 
and update the information internally. 

Respondents to our questionnaire also identified several approaches 
the bureaus and offices employ to safeguard information. For the 21 
collection instruments where FCC maintains the information, 12 
respondents reported that their bureau's or office's information 
collections contain business sensitive or confidential information. 
Nine respondents reported that the information collections are less 
sensitive: 6 reported that the information is generally public data, 1 
reported that the information is not typically business sensitive or 
confidential, and 2 reported that the information is not business 
sensitive or confidential. To ensure the safeguarding of information, 
17 respondents reported that the bureau or office limits access to 
information. For example, 1 respondent who reported that much of the 
information is business sensitive also reported that access to the 
information is limited to bureau staff. In addition, staff members are 
instructed to keep the information and any related notes and 
worksheets confidential and to keep any paper copies of the 
information in locked cabinets. Fourteen respondents also reported 
that the information is safeguarded with data backup and storage, and 
2 respondents reported that information is protected by encryption. 
Two respondents reported that confidential submissions are kept in a 
locked file cabinet. 

Information dissemination. FCC disseminates the information gathered 
through some of the collection instruments we reviewed to the public. 
Specifically, 15 respondents to our questionnaire reported that the 
information collected is disseminated through internal or external 
reports. Of the 15 respondents, 11 reported that some of the 
information collected is disseminated to the public on FCC's Web site. 
For example, 1 respondent reported that information on applications 
and licenses for experimental use of radio frequencies is publicly 
accessible. Other respondents reported the public can request the 
information or view the information at FCC. For example, 1 respondent 
reported that in order to protect the identity of the entity 
submitting information, FCC releases redacted information in response 
to a request for information. Additionally, several respondents 
reported that internal reports are generated from the information 
collected. For example, 1 respondent reported that the bureau or 
office generates internal workload, trend, and management reports from 
the information. 

Information retention and disposal. Bureaus and offices collecting 
information via the collection instruments we reviewed retain the 
information for a period of 1 year to indefinitely. Specifically, 7 
respondents to our questionnaire reported that the bureau or office 
retains the information indefinitely. For example, 1 respondent 
reported that although the actual survey forms are kept for 5 years, 
spreadsheets of information on surveys of license and spectrum 
auctions are kept indefinitely. Another respondent reported that the 
information is retained indefinitely because the disposal procedures 
are not yet in place. We also asked about the procedures for disposing 
of information. Six respondents reported that information is 
transferred to the NARA after being retained by FCC for 5 years. Two 
respondents reported that paper documents are shredded and electronic 
records are physically destroyed or erased electronically. 

FCC's Bureaus and Offices Follow Commission-and Governmentwide 
Guidance, but Prior GAO Reports and Some Stakeholders Identified 
Certain Weaknesses in FCC's Information Collection and Management 
Practices: 

According to our review of 30 OMB-approved information collections, 
FCC's bureaus and offices appear to follow commission-and 
governmentwide policies and procedures for the collection and 
management of information. For example, the bureaus and offices 
conduct quality control procedures for these information collections. 
However, in prior reports, we have identified weaknesses in FCC's 
information collection and management practices, and some stakeholders 
with whom we spoke noted the same or similar weaknesses. In 
particular, these reported weaknesses concern FCC's information 
collection processes and the estimated burden hours associated with 
FCC's information collections. 

On The Basis Of Responses To GAO's Questionnaire, FCC's Bureaus And 
Offices Appear To Follow Commission And Governmentwide Guidance: 

For the 30 information collections that we reviewed, FCC's bureaus and 
offices appeared to follow commission-and governmentwide policies and 
procedures for the collection and management of information. In 
particular, we compared the 30 responses from our questionnaires with 
the commission's internal policies and procedures and federal guidance 
on information collection and management practices. We found that the 
bureaus and offices followed the relevant policies and procedures for 
these 30 information collections. For example, respondents to our 
questionnaire reported carrying out a variety of commissionwide 
information management procedures, including the following: 

* Quality control. FCC bureaus and offices responsible for the 
collections reported using a variety of quality control procedures for 
managing the collections to ensure the accuracy and integrity of the 
information in the collections. These quality control procedures 
include general processes to verify information, such as edit checks; 
Web-based filing systems, which incorporate presubmission checks for 
internal consistency; and notification of the filers of erroneous 
information and the legal obligation to correct the information and 
resubmit the document. 

* Safeguarding sensitive and confidential information. The bureaus and 
offices collecting confidential information reported implementing a 
variety of safeguards. These safeguards include system limitations 
that restrict access to the information and encryption of the data in 
information collections. 

Prior GAO Reports And Some Stakeholders Identified Certain Weaknesses 
In FCC's Information Collection and Management Practices: 

As mentioned previously, in several reports, we have found weaknesses 
in certain information collection, management, and reporting processes 
at FCC. In several instances, FCC has not implemented our 
recommendations. For example, we recommended that FCC consider 
collecting additional data and developing additional measures to 
monitor competition for dedicated access service on an ongoing basis; 
FCC disagreed that it needed to better define competition and collect 
additional data, although on November 5, 2009, it released a Public 
Notice inviting comment on an appropriate analytical framework for 
examining dedicated access.[Footnote 31] Some stakeholders with whom 
we spoke also identified certain weaknesses in FCC's processes. 

Information collection. We recently reported that when issuing a NPRM 
to gather public input before adopting, modifying, or deleting a rule, 
including those rulemakings involving information collection 
instruments, FCC rarely includes the text of the proposed rule in the 
notice, an omission that may limit the effectiveness of the public 
comment process.[Footnote 32] We recommended that FCC, where 
appropriate, include the actual text of proposed rules or rule changes 
in either a NPRM or a FNPRM before the commission votes on new or 
modified rules to improve the transparency and effectiveness of the 
decision-making process. Six stakeholders with whom we spoke also 
expressed concern about FCC's lack of specificity when proposing the 
collection of information through the notice and comment process. For 
example, four stakeholders said that FCC does not initially specify 
the information that it wants to gather through a proposed collection 
instrument in the NPRM. Additionally, an official representing a major 
telecommunications company said that FCC issues NPRMs that do not 
contain the proposed rule for stakeholders to review and comment on. 
This official added that NPRMs usually contain a general description 
of what the rule will be and the companies can submit comments. The 
lack of specificity in the NPRM makes it harder for stakeholders and 
the public to provide meaningful input on the proposed information 
collection instrument. 

Burden hour estimates. OMB recently released a request for comments on 
improving implementation of the PRA.[Footnote 33] In its request, OMB 
noted that agencies' estimation methodologies can sometimes produce 
imprecise and inconsistent estimates of the burdens associated with 
information collection instruments. In particular, OMB noted that some 
estimates are not based on sufficiently rigorous or internally 
consistent methodologies. Additionally, OMB noted that some 
information collections may impose significant burdens on small 
businesses. Therefore, OMB sought comment on a variety of topics, 
including the following: 

* examples of substantially inaccurate burden estimates for 
information collections, 

* new or improved practices for estimating burden, 

* examples of information collections that inaccurately estimate the 
impact of burden upon small entities, and: 

* whether or not a separate burden estimate should be created for 
small entities. 

Seven stakeholders with whom we spoke expressed concern about FCC's 
burden hour estimates and the overall burden associated with the 
commission's information collections, particularly the burden on small 
companies.[Footnote 34] Three stakeholders mentioned that FCC's burden 
hour estimates are not accurate. For example, an official with a 
telecommunications company said that the burden estimates for some of 
the information collections the company submits are underestimated. In 
particular, this official said that aggregating and submitting 
information to FCC on broadband service (FCC Form 477) takes longer 
than FCC's estimate; FCC's estimated average burden hours per response 
for the Form 477 is 72 hours, yet this official said the time to 
prepare and submit the Form 477 is off by a factor of 10. Six 
stakeholders mentioned the burdensome nature of some FCC collections, 
particularly for small companies. For example, one association said 
that providing data is a burden for some of the smaller companies, 
which might have as few as 500 customers. Another official noted that 
inaccurate estimates can adversely affect small companies, since the 
additional burden could negatively affect their operations. In 
general, these stakeholders did not provide concrete examples to 
substantiate their concerns about the estimated burden. 

FCC Is Currently Reviewing Its Information Management Processes: 

On July 22, 2009, the FCC Chairman directed the Office of Strategic 
Planning and Policy Analysis (OSPPA) to conduct a top-to-bottom review 
of the commission's systems and processes for information collection, 
processing, analysis, and dissemination. According to the Chairman, he 
initiated the review to uncover opportunities to improve the 
commission's information capabilities. In particular, the Chairman 
sought information on whether any (1) new information should be 
collected to support the commission's mission, (2) existing 
information reporting requirements could be streamlined or eliminated 
because they are unduly burdensome or no longer relevant, and (3) 
existing technological platforms and management processes could be 
modernized in order to make the commission's use of information more 
efficient and effective. The Chairman asked OSPPA to answer 20 
questions, including the following: 

* For each bureau and office, what significant information is 
collected and which information is used most heavily internally or 
externally? 

* Is there overlap among bureaus or offices with regard to information 
collection? 

* What formal operational processes exist to manage the full 
information "life cycle" and are there any bottlenecks? 

* Does FCC make regular efforts to gather best practices from other 
information collections agencies? 

* What reports does FCC regularly generate to make information 
available to the public, what are the most important information 
systems, and what metrics does FCC have to track public consumption of 
information? 

According to FCC officials, OSPPA has taken several steps to carry out 
the Chairman's request. In particular, OSPPA (1) sought information on 
the current information collection efforts and future information 
needs in FCC's bureaus and offices and (2) identified potential gaps 
between the current collections and future needs. OSPPA officials said 
that the current effort will likely identify areas for greater 
investigation for the bureaus and offices, and that the current effort 
is the beginning of a multiyear review and transition process. 

Additionally, the Chairman initiated an assessment of FCC's database 
and communications infrastructure. According to the Chairman, an 
initial review strongly suggested that a significant upgrade will be 
warranted to bring the commission into the 21st century. The Chairman 
also stated that an upgrade will permit the commission and its staff 
to function much more efficiently and facilitate public use of its Web 
site. FCC also launched an internal online forum where employees can 
submit ideas for improvement and reform, and FCC plans to launch a 
section on its Web site allowing the public to offer ideas for reform 
as well. 

Agency Comments: 

We provided FCC with a draft of this report for its review and 
comment. FCC provided written comments, which appear in appendix II. 
In its written comments, FCC discussed the various efforts under way 
at the commission to improve its data management processes. FCC also 
provided technical comments that we incorporated where appropriate. 

As agreed with your office, unless you publicly announce the contents 
of the report earlier, we plan no further distribution of it until 30 
days from the date of this report. At that time we will send a copy of 
this report to the Chairman of the Federal Communications Commission. 
The report also is available at no charge on the GAO Web site at 
[hyperlink, http://www.gao.gov]. 

If you have any questions about this report, please contact me at 
(202) 512-2834 or wised@gao.gov. Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this report. GAO staff who made major contributions to this 
report are listed in appendix III. 

Sincerely yours, 

Signed by: 

David J. Wise: 
Director, Physical Infrastructure Issues: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

This report examines (1) the information the Federal Communication 
Commission (FCC) collects; (2) how FCC collects and manages 
information; (3) the strengths and weaknesses, if any, in FCC's 
information collection and management practices; and (4) the status of 
FCC's internal review of its information collection and management 
practices. 

To describe the information FCC collects, we obtained and reviewed 
FCC's list of information collection instruments approved under the 
Paperwork Reduction Act (PRA); we reviewed collection instruments that 
were approved as of April 22, 2009. The list included FCC's 
description of the information collection, the PRA number, the name of 
the bureau or office responsible for managing the collection, and the 
estimated annual burden hours associated with the collection. We also 
interviewed FCC officials from seven bureaus and offices, including 
the Chief Information Officer. We discussed the availability, formats, 
and special characteristics of FCC's information collections. 

To describe how FCC collects and manages information, we reviewed 
commissionwide directives on FCC's (1) records management program, (2) 
forms management program, (3) management of nonpublic information, and 
(4) information security program. We reviewed the National Institute 
of Standards and Technology's guidance on security procedures for 
information, the Office of Management and Budget's (OMB) Office of 
Information and Regulatory Affairs directives on managing and securing 
information, and the National Archives and Records Administration's 
(NARA) guidance for retaining and disposing of information. We also 
interviewed FCC officials. 

Additionally, to obtain information on how various FCC bureaus and 
offices collect and manage information, we developed two 
questionnaires that covered various aspects of the information life 
cycle--collection, management, dissemination, and retention and 
disposal. We developed one questionnaire for collection instruments 
where FCC retains the information and a second questionnaire for 
collection instruments where the filing entity or a third party 
maintains the information. We pretested the questions to determine 
appropriateness and made revisions based on the results of the 
pretest. To select the information collection instruments from which 
we would obtain information via the questionnaires, we initially asked 
FCC for the repository (e.g., the database where the information 
resides) associated with each of its information collections; FCC 
officials said the commission could not readily provide that 
information because it does not maintain its records in such a manner. 
In response, we adopted an alternative, multistep approach. We asked 
FCC to classify the 413 OMB-approved information collection 
instruments into categories based on activity or use (e.g., licenses 
and surveys); FCC divided its 413 collection instruments into 21 
categories. We determined the average burden hours for each of the 21 
categories, based on the estimated annual burden hours for the 
collection instruments in each category. We established three strata 
based on the average burden hours (greater than 46,803 hours, 46,803 
hours to 17,904 hours, and less than 17,904 hours). We selected one 
category from each of the first two stratum and two categories from 
the third strata in order to obtain a mix of collection types and to 
eliminate collections that received extremely limited submissions. 
Finally, we judgmentally selected collection instruments from each of 
these four categories; this process resulted in the selection of 30 
information collection instruments. Because of the nature of our 
selection process, our results can not be used to evaluate FCC's 
collection processes overall. Of the 30 collection instruments, FCC 
maintains the information for 21 collection instruments and the filing 
entity or a third party maintains the information for the remaining 9 
collection instruments. We received responses for all 30 collections. 
After receiving the 30 responses, we reviewed and analyzed the answers 
and followed up on selected answers and documentation provided in the 
questionnaire by interviewing the responsible officials. 

To describe the strengths and weaknesses in FCC's information 
collection and management practices, we compared the 30 responses from 
the questionnaires with the commission's internal policies and 
procedures and federal guidance on information collection and 
management practices. We also interviewed 19 stakeholders, including 
representatives from communication companies, industry trade 
associations, consumer and public interest groups, state regulators, 
and academic and industry experts. We selected these stakeholders to 
include a cross section of industries regulated by FCC, including 
radio and television broadcasters, cable television operators, 
satellite operators, and wireline and wireless telephone companies, as 
well as parties representing consumers and regulators that are 
affected by the commission's policies and rulemaking. We reviewed 
prior GAO reports and performed a literature review of best practices 
for the collection and management of information. 

To describe the steps FCC is taking to address information management 
weaknesses, we reviewed a memoranda dated July 22, 2009, from the FCC 
Chairman initiating a review of the commission's information 
management collections and processes. We also reviewed a congressional 
hearing statement made by the Chairman in which he discussed FCC's 
initiatives to improve information management.[Footnote 35] We met 
with the Chief of the Office of Strategic Planning and Policy Analysis 
to discuss progress on the commissionwide information management 
review the Chairman requested in July of 2009. 

[End of section] 

Appendix II: Comments from the Federal Communications Commission: 

Federal Communications Commission: 
Office Of Managing Director: 
Washington, D.C. 20554 

January 14, 2010: 

David Wise: 
Director, Physical Infrastructure Issues: 
United States Government Accountability Office: 
Washington, D.C. 20548: 

Re: GA0-10-249: 

Dear Mr. Wise: 

Thank you for the opportunity to review and comment on the Government 
Accountability Office (GAO) Draft Report, Telecommunications — 
Information Collection and Management at the Federal Communications 
Commission. 

While the report does not contain any specific recommendations for 
action by the Federal Communications Commission (Commission or FCC), 
the report does acknowledge that Chairman Julius Genachowski has made 
modernizing and reforming the FCC's data management processes a 
priority. Indeed, the Chairman has frequently noted that as the 
nation's expert agency on communications, the FCC must have access to, 
and base its decisions on, data that are accurate and relevant. 

Specifically, to ensure that the FCC is data-driven in its decision-
making, the Chairman directed the FCC's Office of Strategic Planning 
and Policy Analysis to conduct a top-to-bottom review of the FCC's 
systems and processes for data collection, processing, analysis, and 
dissemination. A start to the longer process of data reform at the 
Commission, the review addresses whether any new data should be 
collected, whether any existing data reporting requirements can be 
eliminated or reduced, and whether existing technological platforms 
can be modernized to make the Commission's use of data more effective 
and efficient. The review includes an inventory and initial 
examination of the over 400 data collections discussed in your report. 

As a part of the Commission's data review, the Office of the Managing 
Director is also assessing the database and communications 
infrastructure of the FCC. An initial review strongly suggests that a 
significant upgrade is warranted to bring the Commission into the 21' 
century. The FCC's website and database infrastructure are many years 
out of date, and upgrades will permit the Commission and its staff to 
function much more efficiently and facilitate public use of the 
agency's website. Moreover, the FCC is looking at its licensing, 
comment and complaint filing systems to see whether they can be 
improved. The Commission has launched an initiative that will combine 
all the functions of many of our current licensing applications into a 
single consolidated system. The new consolidated system will give the 
public a consistent interface and will standardize business practices 
across Bureaus and Offices. 

The FCC is also committed to soliciting public feedback and input as 
it undertakes these efforts. Most recently, the Commission launched a 
new site, Reboot.FCC.Gov, where citizens can offer their ideas for FCC 
reform. The Reboot site also offers new ways to access FCC data 
through FCC.gov/data. This new site is an online clearinghouse for 
data sets made public by the Commission. The data sets are organized 
in two ways: by the type of data set and by tho Bureau or Office 
publishing the data. The launch of FCC.gov/data is the first of many 
steps in reforming how the FCC publishes and manages its data. New 
data sets will be regularly added to FCC.gov/data, and the work to 
present the data in more functional and easily accessible formats will 
be ongoing. 

Thank you for the opportunity to comment on the draft report. The FCC 
is committed to increasing openness and transparency, and we encourage 
public input on making the Commission a more open and data-driven 
agency. 

Sincerely, 

Signed by: 

[Illegible] for: 

Steven VanRoekel: 
Managing Director: 

[End of section] 

Appendix III: Contact and Acknowledgments: 

GAO Contact: 

David J. Wise (202) 512-2834 or wised@gao.gov: 

Acknowledgments: 

In addition to the contact listed above, Michael Clements (Assistant 
Director), Andy Clinton, Mya Dinh, Amy Rosewarne, Don Watson, Mindi 
Weisenbloom, and Elizabeth Wood made major contributions to this 
report. 

[End of section] 

Footnotes: 

[1] GAO, Executive Guide: Effectively Implementing the Government 
Performance and Results Act, [hyperlink, 
http://www.gao.gov/products/GAO/GGD-96-118] (Washington, D.C.: June 
1996). 

[2] GAO, Telecommunications: FCC Has Made Some Progress in the 
Management of Its Enforcement Program but Faces Limitations, and 
Additional Actions Are Needed, [hyperlink, 
http://www.gao.gov/products/GAO-08-125] (Washington, D.C.: Feb. 15, 
2008). 

[3] GAO, Telecommunications: FCC Needs to Improve Its Ability to 
Monitor and Determine the Extent of Competition in Dedicated Access 
Services, [hyperlink, http://www.gao.gov/products/GAO-07-80] 
(Washington, D.C.: Nov. 29, 2006). In addition, on November 5, 2009, 
FCC released a Public Notice inviting comment on an appropriate 
analytical framework for examining dedicated access. In particular, 
FCC noted that it would benefit from a clear explanation of how it 
should use data to determine systemically whether its pricing rules 
are working properly to ensure just and reasonable rates, terms, and 
conditions and to provide flexibility in the presence of competition. 
See FCC, Public Notice: Parties Asked to Comment on Analytical 
Framework Necessary to Resolve Issues in the Special Access NPRM, DA 
09-2388 (Washington, D.C.: Nov. 5, 2009). 

[4] The Paperwork Reduction Act (44 U.S.C. Part 35) requires FCC to 
obtain approval for its information collection instruments from OMB. 
FCC obtains separate approvals from OMB for each of its collection 
instruments. 

[5] Under the PRA, the term "burden" means the time, effort, or 
financial resources expended by persons to generate, maintain, or 
provide information to a federal agency. 44 U.S.C. § 3502(2). 

[6] 47 U.S.C. § 151 et seq. 

[7] The Paperwork Reduction Act of 1995, Pub. L. No. 104-13, 109 Stat. 
163 (1995) (codified in Chapter 35 of title 44 U.S.C.). 

[8] 44 U.S.C. § 3508. 

[9] 44 U.S.C. Chapter 31. 

[10] 44 U.S.C. § 3102. 

[11] FISMA, Pub. L. No. 107-347, tit. III, Section 301. See 44 U.S.C. 
§ 3544. 

[12] OMB, Circular No. A-130, Management of Federal Information 
Resources. 

[13] For example, see NARA, Agency Recordkeeping Requirements: A 
Management Guide, at [hyperlink, http://www.archives.gov/records-
mgmt/publications/agency-recordkeeping-requirements.html]. 

[14] For example, FCC used its rulemaking process to seek comments on 
how to improve its Form 477. FCC uses this form to gather information 
on broadband deployment throughout the United States. See Development 
of Nationwide Broadband Data to Evaluate Reasonable and Timely 
Deployment of Advanced Services to All Americans, Improvement of 
Wireless Broadband Subscribership Data, and Development of Data on 
Interconnected Voice over Internet Protocol (VoIP) Subscribership, 
Notice of Proposed Rulemaking, 22 FCC Rcd 7760 (2007). 

[15] The APA is the principal law governing how agencies make rules. 
Most federal rules are promulgated under the APA-established informal 
rulemaking process, which requires agencies to provide public notice 
of proposed rule changes, as well as to provide a period for 
interested parties to comment on the notices. 5 U.S.C. § 551 et seq. 

[16] 5 U.S.C. § 553(b). 

[17] FCC is not required to issue a NOI before issuing a NPRM. 
However, FCC must issue a NPRM before taking final action on a rule 
unless an exception to notice and comment applies. 

[18] FCC provided GAO with information on the 413 information 
collection instruments as of April 2009. Since that time, FCC may have 
received approval for new collection instruments or some collection 
instruments could have expired. For comparison purposes, other 
agencies utilizing a significant number of OMB-approved information 
collection instruments include the departments of Treasury (1,286 
collections), Agriculture (566 collections), Commerce (430 
collections), Homeland Security (419 collections), and Labor (413 
collections). 

[19] For both the Wireline Competition and Consumer and Governmental 
Affairs bureaus, the majority of the responses pertain to a single 
collection instrument. The Wireline Competition Bureau anticipates 
over 100 million responses to its Customer Proprietary Network 
Information and Other Customer Information instrument (OMB Control 
Number 3060-0715), and the Consumer and Governmental Affairs Bureau 
anticipates over 100 million responses to its consumer complaints 
instrument (OMB Control Number 3060-0519). 

[20] 44 U.S.C. § 3502(2). 

[21] The Federal Universal Service Fund supports four programs: the 
Low-Income, the High-Cost, the Schools and Libraries, and the Rural 
Health Care programs. 

[22] Regulatory fees are mandated by law, and FCC collects these fees 
to recover the regulatory costs associated with its enforcement, 
policy and rulemaking, user information, and international activities. 
See 47 U.S.C. § 159(a). 

[23] A bidding credit is a percentage discount applied to the high bid 
amount for a license if the bidder meets specific designated entity 
criteria established in the auction rules. 

[24] 44 U.S.C. § 3101 et seq. 

[25] FCC Directive: FCC INST 1110.1 (March 2007). This directive is 
nonpublic and for internal use only. 

[26] FCC Directive: FCC INST 1112.1 (February 2008). This directive is 
nonpublic and for internal use only. 

[27] FCC Directive: FCC INST 1139 (March 2007). This directive is 
nonpublic and for internal use only. 

[28] FCC Directive: FCC INST 1479.3 (July 2008). This directive is 
nonpublic and for internal use only. 

[29] FCC established these procedures to fulfill requirements of the 
Federal Information Security Management Act of 2002 (Pub. L. No. 107- 
347); OMB Circular A-130, Appendix III; and other applicable 
guidelines and laws. The Federal Information Security Management Act 
of 2002 was enacted as title III of the E-Government Act of 2002 and 
provides a comprehensive framework for ensuring the effectiveness of 
information security controls over information resources that support 
federal operations and assets. OMB Circular A-130, Appendix III, 
Security of Federal Automated Information Resources, establishes 
minimum controls for federal automated information security programs. 

[30] Radio frequency identification is an automated data capture 
technology that can be used to identify, track, and store information 
contained on the tag that it is attached to or embedded in an object, 
such as a product, case, or pallet. 

[31] FCC, Public Notice: Parties Asked to Comment on Analytical 
Framework Necessary to Resolve Issues in the Special Access NPRM, DA 
09-2388 (Washington, D.C.: Nov. 5, 2009). 

[32] GAO, FCC Management: Improvements Needed in Communication, 
Decision-Making Processes, and Workforce Planning, [hyperlink, 
http://www.gao.gov/products/GAO-10-79] (Washington, D.C.: Dec. 17, 
2009). 

[33] OMB, Improving Implementation of the Paperwork Reduction Act, 
Request for Comments, 74 Fed. Reg. 55269 (2009). 

[34] FCC officials noted that interested parties have an opportunity 
to comment on proposed collection instruments, but generally few 
choose to comment. 

[35] Written Statement of Julius Genachowski, Chairman, Federal 
Communications Commission, Before the Committee on Energy and 
Commerce, Subcommittee on Communications, Technology and the Internet, 
House of Representatives, September 17, 2009. 

[End of section] 

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