The mandatory special access data request (CD Dec 13 p5) will impose...

not previously subject to any reporting obligations on special access services will now require “significant time commitments from staff,” NCTA said. The cable association said it will be difficult for respondents to accurately estimate the burden associated with the data request for Paperwork Reduction Act (PRA) purposes, “given that the Commission has not released any information about the data entry system it is developing for collection of the data.” NCTA said it was concerned about a “lack of transparency” in connection with the PRA process, such as no detailed breakdown of how the commission concluded that its data request would require more than 6,000 respondents to spend more than 850,000 hours compiling and submitting data. Comcast and Cox were particularly concerned about the requirement to submit a map identifying all fiber routes connecting their networks to end user locations; all nodes on their networks used to interconnect with third-party networks; and the year those nodes went live. The companies “do not use maps with that level of detail in the normal course of their business,” the filing said. “It would be tremendously burdensome to create such maps” solely for responding to the commission’s data request, it said. NCTA also raised concern over the “security risks” of keeping so many detailed maps at the commission, warning the identified interconnection locations would be “a target for hackers."