GAO 

United States Government Accountability Office

Report to the Honorable Edward J. 

Markey, House of Representatives 

TELECOMMUNICATIONS

Information Collection 

and Management at 

the Federal 

Communications 

Commission 

January 2010 

GAO-10-249 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

January 2010

TELECOMMUNICATIONS

Information Collection and Management at the 

Federal Communications Commission 

Highlights of GAO-10-249, a report to the 

Honorable Edward J. Markey, House of 

Representatives 

The Federal Communications 

Commission (FCC) regulates 

industries that affect the lives of 

virtually all Americans. FCCregulated 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. 

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. 
Page i GAO-10-249 

Contents 

Letter 1

Background 5 

FCC Uses OMB-Approved Collection Instruments to Gather a Wide 

Variety of Information on the Industries That It Regulates 9 

FCC Bureaus and Offices Collect and Manage Most of the 

Commission’s Information Following Commissionwide 

Programs, Policies, and Procedures 13 

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 20 

FCC Is Currently Reviewing Its Information Management 

Processes 23 

Agency Comments 24 

Appendix I Objectives, Scope, and Methodology 25 

Appendix II Comments from the Federal Communications 

Commission 28 

Appendix III Contact and Acknowledgments 30 

Tables 

Table 1: GAO Reports Identifying Weaknesses with Certain 

Information Collection, Management, and Reporting 

Efforts at FCC 2 

Table 2: Description of FCC Bureau Responsibilities 6 

Table 3: FCC’s OMB-Approved Information Collection Instruments 

by Bureau and Office, as of April 2009 10 

Table 4: FCC’s OMB-Approved Information Collection Instruments 

by Type and Category, as of April 2009 11 

Telecommunications 
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 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately. 

Page ii GAO-10-249 Telecommunications
Page 1 GAO-10-249 

 

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.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.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 

1

GAO, Executive Guide: Effectively Implementing the Government Performance and 

Results Act, 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, 

GAO-08-125 (Washington, D.C.: Feb. 15, 2008). 

Telecommunications 
 

presence, extent, or change in competition in any given area.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 Topic Findings 

Recommendations to 

FCC 

Status of 

recommendations 

GAO-06-425 FCC’s enforcement 

of junk fax laws 

• 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. 

• Revise its complaint form 

and guidance to 

consumers. 

• Develop data 

management strategies 

to make the consumer 

complaint database more 

usable. 

• 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. 

 

3

GAO, Telecommunications: FCC Needs to Improve Its Ability to Monitor and Determine 

the Extent of Competition in Dedicated Access Services, 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). 

Page 2 GAO-10-249 Telecommunications
 

Report Topic Findings 

Recommendations to 

FCC 

Status of 

recommendations 

GAO-07-80 Competition for 

dedicated access 

service 

• 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. 

• Consider collecting 

additional data and 

developing additional 

measures to monitor 

competition on an 

ongoing basis. 

• 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. 

GAO-08-125 FCC’s program to 

enforce relevant 

laws and rules 

• 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. 

• Improve how it collects 

and analyzes data on 

complaints received. 

• 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. 

GAO-08-383 Number and 

ownership of media 

outlets, such as 

radio and television 

stations 

• 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. 

• Identify processes and 

procedures to improve 

the reliability of its data 

on gender, race, and 

ethnicity. 

• 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. 

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 

Page 3 GAO-10-249 Telecommunications
 

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).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,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 

 

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).

Page 4 GAO-10-249 Telecommunications
 

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. 

Under the Communications Act, as amended, FCC regulates interstate and 

international communications by radio, television, wire, satellite, and 

cable.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 

Background 

 

6

47 U.S.C. § 151 et seq. 

Page 5 GAO-10-249 Telecommunications
 

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 Responsibility 

Consumer and Governmental 

Affairs Bureau 

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. 

Enforcement Bureau 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. 

International Bureau 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. 

Media Bureau 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. 

Public Safety and Homeland 

Security Bureau 

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. 

Wireless Telecommunications 

Bureau 

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. 

Wireline Competition Bureau 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. 

Page 6 GAO-10-249 Telecommunications
 

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.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.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.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.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 

 

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. 

1044 U.S.C. § 3102. 

Page 7 GAO-10-249 Telecommunications
 

from unauthorized access, use, disclosure, disruption, modification, or 

destruction of information collected or maintained by or on behalf of the 

agency.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.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.13

To develop new rules or modify existing rules, including rules pertaining 

to information collection instruments, FCC initiates a rulemaking 

process.14 When implementing a rulemaking process, FCC must follow the 

procedures set forth in the Administrative Procedure Act (APA).15 The 

APA generally requires a “notice and comment” or “notice and comm

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 

ent 

 

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

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

13For example, see NARA, Agency Recordkeeping Requirements: A Management Guide, at 

http://www.archives.gov/records-mgmt/publications/agency-recordkeepingrequirements.html.

14For 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). 

15The 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. 

Page 8 GAO-10-249 Telecommunications
 

“written data, views, or arguments.”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.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. 

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.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 threequarters 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 

FCC Uses OMBApproved Collection 

Instruments to Gather 

a Wide Variety of 

Information on the 

Industries That It 

Regulates 

 

165 U.S.C. § 553(b). 

17FCC 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. 

18FCC 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). 

Page 9 GAO-10-249 Telecommunications
 

Bureau anticipates fewer than 10,000.19 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.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 

Number of 

collection 

instruments 

Estimated 

number of 

responses

Estimated 

annual

 burden hours

Media Bureau 139 26,060,594 7,204,822

Wireline Competition Bureau 85 146,943,153 6,485,604

Wireless Telecommunications 

Bureau 

74 2,160,965 2,661,209

International Bureau 30 21,238 163,968

Consumer and Governmental Affairs 

Bureau 

27 188,981,121 39,194,033

Office of Engineering and 

Technology 

21 2,099,423 653,411

Public Safety and Homeland Security 

Bureau 

19 18,092,277 856,821

Office of Managing Director 8 319,066 68,812

Enforcement Bureau 7 9,906 10,944

Office of General Counsel 3 12,515 9,230

Total 413 384,700,258 57,308,854

Source: FCC. 

 

19For 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). 

2044 U.S.C. § 3502(2). 

Page 10 GAO-10-249 Telecommunications
 

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 Category industry/purpose 

Number of 

collection 

instruments 

Estimated 

number of 

responses

Estimated 

annual 

burden hours

Requirements Wireless licensee requirements 59 1,221,133 1,352,762

Wireline carrier requirements 58 161,134,039 2,991,155

Broadcast licensee requirements 51 2,652,838 4,279,656

Cable system requirements 42 22,752,312 1,703,044

Public safety licensee requirements 19 18,092,277 856,821

Equipment authorizations and experimental radio 

requirements 

15 408,850 372,594

Satellite and earth station license requirements 16 805 26,381

Digital television requirements 13 534,687 438,178

Broadcast and cable equal employment 

opportunity reporting requirements 

6 40,836 623,432

Applications Satellite and earth station license applications 14 20,433 137,587

Broadcast and cable license applications 24 71,083 143,204

Public safety and wireless license applications 10 916,259 916,032

Equipment authorizations and experimental radio 

license applications 

6 1,690,573 280,817

Complaints Consumer complaints and enforcement 28 164,805,662 39,072,069

Financial and accounting Universal service fund 12 8,286,676 2,147,053

FCC financial operations 8 319,066 68,812

Wireline carrier accounting 15 19,218 268,538

Other Spectrum auctionsa6 30,628 401,893

Telecommunications relay serviceb5 1,685,365 126,626

Surveys 3 4,978 1,092,970

Legal procedures 3 12,515 9,230

Total 413 384,700,258 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. 

Page 11 GAO-10-249 Telecommunications
 

• 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.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.22

 

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

22Regulatory 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). 

Page 12 GAO-10-249 Telecommunications
 

• 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.23

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 Bureaus and 

Offices Collect and 

Manage Most of the 

Commission’s 

Information 

Following 

Commissionwide 

Programs, Policies, 

and Procedures 

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.24 To 

meet this requirement, FCC established a records management program 

 

23A 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. 

2444 U.S.C. § 3101 et seq. 

Page 13 GAO-10-249 Telecommunications
 

that sets out the policies, procedures, and activities needed to manage the 

commission’s recorded information.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.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 

 

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

use only. 

26FCC Directive: FCC INST 1112.1 (February 2008). This directive is nonpublic and for 

internal use only. 

Page 14 GAO-10-249 Telecommunications
 

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.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 

 

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

use only. 

Page 15 GAO-10-249 Telecommunications
 

systems,28 including the FCC network, applications and databases, and 

information created, stored, or processed.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 

 

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

use only. 

29FCC 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. 

Page 16 GAO-10-249 Telecommunications
 

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.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 

 

30Radio 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. 

Page 17 GAO-10-249 Telecommunications
 

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 

Page 18 GAO-10-249 Telecommunications
 

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. 

Page 19 GAO-10-249 Telecommunications
 

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 

Page 20 GAO-10-249 Telecommunications
 

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.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.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 

 

31FCC, 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). 

32GAO, FCC Management: Improvements Needed in Communication, Decision-Making 

Processes, and Workforce Planning, GAO-10-79 (Washington, D.C.: Dec. 17, 2009). 

Page 21 GAO-10-249 Telecommunications
 

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.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.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 

 

33OMB, Improving Implementation of the Paperwork Reduction Act, Request for 

Comments, 74 Fed. Reg. 55269 (2009). 

34FCC officials noted that interested parties have an opportunity to comment on proposed 

collection instruments, but generally few choose to comment. 

Page 22 GAO-10-249 Telecommunications
 

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. 

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: 

FCC Is Currently 

Reviewing Its 

Information 

Management 

Processes 

• 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 

Page 23 GAO-10-249 Telecommunications
 

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. 

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. 

Agency Comments 

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 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, 

David J. Wise 

Director, Physical Infrastructure Issues 

Page 24 GAO-10-249 Telecommunications
Appendix I: Objectives, Scope, and 

Methodology 

Page 25 GAO-10-249 

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 

Telecommunications 
Appendix I: Objectives, Scope, and 

Methodology 

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 

Page 26 GAO-10-249 Telecommunications
Appendix I: Objectives, Scope, and 

Methodology 

to improve information management.1 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. 

 

1

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. 

Page 27 GAO-10-249 Telecommunications
Appendix II: Comments from the Federal Appendix II: Comments from the Federal Communications Commission 

Communications Commission 

Page 28 GAO-10-249 Telecommunications 
Appendix II: Comments from the Federal 

Communications Commission 

Page 29 GAO-10-249 Telecommunications
Appendix III: Contac

A

t and 

cknowledgments 

Page 30 GAO-10-249 

Appendix III: Contact and Acknowledgments 

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

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. 

Telecommunications 

GAO Contact 

Acknowledgments 

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