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OMB 3060–1158: USTelecom Comments on Enhanced Transparency Rule Adopted in the 2015 Open Internet Order


USTelecom submits these comments in response to the notice released by the Federal Communications Commission (Commission or FCC) seeking comment pursuant to the Paperwork Reduction Act (PRA) of 1995 (PRA Notice) on the new, enhanced transparency rule adopted in the 2015 Open Internet Order. The Commission’s burden estimates for the new information collection requirements fall well short of what broadband Internet access service (BIAS or broadband) providers will have to do to comply with them. Moreover, contrary to the PRA’s primary purpose “to reduce, minimize and control burdens and maximize the practical utility and public benefit,” the new requirements go beyond what is necessary for the Commission to ensure that broadband customers have sufficient information to make informed choices about their broadband services. The Commission therefore should modify both the burden estimates and the scope of the information collection to better reflect the PRA’s goals and requirements.