Justification for non-substantive change request

Federal Communications Commission

Explanation of Non-Substantive Changes to OMB Control Number: 3060-0806:

• FCC Form 470

Purpose of this Submission: This submission is being made for proposed non-substantive changes to an existing information collection pursuant to 44 U.S.C. § 3507. This submission seeks to make minor, non-substantive changes to the instructions, the process by which applicants fill out this form, and the descriptions of services (drop-down menu options) used for the FCC Form 470. These changes are designed to clarify the purpose of the form and information desired so that applicants may complete the application with greater specificity and precision. The form is electronically available through an online database, and a representative sample of the information requested from respondents is included with this submission.

Background: On October 1, 2019, the Wireline Competition Bureau and the Office of Managing Director released a Public Notice (PN) seeking comment on whether and how the FCC Form 470 drop-down menu options may be improved to minimize the potential for applicant confusion and, to the extent practicable, reduce administrative burdens on program participants. In response, commenters suggested modifications and requested changes to the instructions but generally supported the changes to the process and the drop-down menu options proposed in the PN. Commenters’ suggestions are incorporated in this request to the extent that they adhere to the guidelines set forth in the PN, comply with Commission rules, and are technically feasible. We seek to modify FCC Form 470 to implement these changes for FY2022, which commences July 1, 2022. However, we anticipate releasing the Form 470 a year prior, on July 1, 2021, as is the usual practice.

Summary of Proposed Changes to the FCC Form 470:

• We propose to provide applicants with additional guidance, warnings, and explanations for “category one” services to help guide applicants to the correct drop-down menu option for the service on which they seek bids. The guidance will be provided in ways such as:

  • Providing explanatory statements at the beginning of the page;

  • Providing warnings when selections may impact or are inconsistent with other areas of the Form 470; and

  • Informing applicants of commonly selected items within a given section or question.

• We propose to modify the steps applicants must take and questions they must answer, to fill out the FCC Form 470, to reduce confusion and administrative burdens. Changes include:

  • Adding guiding statements to lead applicants to the relevant category one drop-down menu options; and

  • Enabling applicants to multi-select “category two” drop-down menu options.

• We propose to modify the options in the drop-down menu field of the FCC Form 470 to more accurately reflect the services on which applicants are requesting bids and reduce applicant confusion. Changes include:

  • Adding the phrase “and necessary software and licenses” to category two internal connections drop-down menu options to clarify that these elements are eligible under this category; and

  • Changing the category one drop-down menu option “Internet Access and Transport Bundled” to “Internet access and data transmission service” to clarify that these services do not have to be bundled together.