(February 14) In comments filed with CISA in response to proposed updates to the National Cyber Incident Response Plan (NCIRP), NTCA recommended the agency establish a clear and consistent method for timely communication of cyber events with broadband providers of all sizes. NTCA also recommended engaging small broadband providers in nationwide cyber training exercises to avoid making future updates to the NCIRP absent new guidance that is not duplicative of other federal guidance. Finally, NTCA pointed out that reliance on Title 47 of the Communications Act/Section 706 of the Telecommunications Act is inappropriate in this context.