Kent Bressie 6 November 2012

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1 Managing the Parade of Regulatory Horribles in the United States Kent Bressie 6 November 2012

2 1. The Parade of Horribles 2

3 FCC FCC Universal Service Contributions FCC has proposed to reform contribution rules for federal Universal Service Fund by eliminating the international only and limited interstate revenues exemptions on which many undersea cable operators rely. Under the FCC s proposal, undersea cable operators would pay a percentage-of-revenues assessment (currently, 15.7 percent of end-user revenues) on all revenues from sales of capacity touching the United States, regardless of whether the sales are actually made in the United States. FCC staffers responsible for proposal know little about undersea cables and are preoccupied with achieving competitive parity with prepaid calling card providers. 3

4 FCC FCC Annual Regulatory Fees When FCC finally revised its methodology for capacity-based fees in 2009 (after a 6-year fight), the undersea cable industry thought it had finally resolved the problem of burdensome and distortive fees. Now, the FCC has proposed to increase undersea cable operator fees by 230 percent, even though it does very little to regulate undersea cables and has increased regulatory activity for broadband and wireless services. FCC International Bureau staff objected strongly to FCC proposal and continue to disagree with Office of Managing Director. 4

5 FCC FCC Reporting Requirements FCC has proposed to impose new capacity reporting requirements on undersea cable operators, even though the FCC has been eliminating many other reporting and filing requirements for other services. Undersea cable operators objected strongly to original proposals made in 2004 but mostly failed to object to slightly revised proposals in 2011, perhaps due to regulatory fatigue. Requirements could be used to justify higher regulatory fees. 5

6 Team Telecom Team Telecom Security Reviews Departments of Justice, Defense, and Homeland Security and Federal Bureau of Investigation (together, Team Telecom ) conduct national security reviews of applications seeking: An FCC license for new facilities or services, or FCC consent to transfer or assign a license in a merger or acquisition For applicants with notable foreign ownership or international infrastructure, Team Telecom typically requires a security agreement with: Information security restrictions (confidentiality of surveillance, traffic routing, storage of data and records, and requirements for any foreign surveillance) Infrastructure security restrictions (sourcing of equipment and services for installation and maintenance) Team Telecom petitions FCC to condition any license or transaction approval on compliance with a security agreement or assurances letter. 6

7 Team Telecom Uncertainty and Delay Team Telecom does not act pursuant to any particular law, has adopted no formal regulations, and retains substantial power and discretion. Has recently shown flexibility in allowing operators to outsource NOC operations and surveillance and law enforcement responsibilities. Delays in negotiating security agreements and assurances letters are the single biggest source of delay in FCC licensing. 7

8 Team Telecom FCC Cable Landing License Processing Times for Recent New Systems System Date FCC Application Filed Date Security Agreement Signed Date FCC License Granted Total Licensing Time AMX-1 Mar. 30, 2012 pending pending ongoing AT&T GOKI Mar. 29, 2011 none* April 14, days HANTRU1 Feb. 25, 2009 none* June 10, days Honotua Sept. 26, Dec. 3, 2010 Dec. 6, days 2008 American Samoa Hawaii Aug. 13, 2008 Jan. 9, 2009 Jan. 15, days CB-1 June 3, 2008 Feb. 11, 2009 Feb. 13, days Unity May 16, 2008 Sept. 21, Oct. 5, days 2009 PPC 1 Feb. 11, 2008 Sept. 4, 2008 Sept. 10, 212 days 2008 AAG Aug. 23, 2007 June 10, July 2, days 2008 UUI TERRA-SW Sept. 14, none Oct. 28, days 2010 * Systems likely exempted from Team Telecom reviews at the request of military customers. GCI SEAFAST Oct. 23, 2007 none Dec. 6, days 8

9 Environmental Permitting State-Level Environmental Permitting Florida DEP / Board of Trustees of the Internal Improvement Trust Fund has imposed limits on the number of cables and conduits for each reef pass; also requires prior completion of FCC licensing before state will license. New Jersey permitting greatly favors interests of local fishermen. California state and local permitting processes can take two years and result in burdensome conditions. 9

10 Alternative Energy Conflicts with Alternative Energy Facilities The rush to harness wind, waves, and ocean currents to generate electricity has intensified conflicts with undersea cable installation and maintenance activities. Although International and U.S. law grant unique protections to undersea cables, some agencies particularly the Bureau of Ocean Energy Management pay little heed to such protections. Alternative energy facilities spatial requirements threaten to impede access for undersea cable installation and maintenance, foreclose use of diverse routes, and increase damage from vessels. Alternative energy facilities pose additional threats from bottom-scouring caused by structures such as wind turbine towers and from crossings by more numerous power-transmission cables. 10

11 2. Myths and Misunderstandings About Undersea Cables 11

12 Myths & Misunderstandings Fundamental Misunderstandings Undersea cables have something to do with submarines. 12

13 Myths & Misunderstandings Technology-Related Myths Satellites, rather than undersea cables, provide most international connectivity. Undersea cables use old technology. Wireless is better than wired. Undersea cables are frequently replaced to increase capacity. 13

14 Myths & Misunderstandings Physical-Characteristic Myths Installation and operation of undersea cables poses significant risks to the environment and marine life. Undersea cables are huge and have the diameter of pipelines. It takes years to install undersea cables. 14

15 Myths & Misunderstandings Market-Related Myths There is an excess of undersea cable capacity and therefore little need for new infrastructure in the foreseeable future. 15

16 3. Strategies for Improving Regulation, or At Least Limiting the Impact of Poor Regulation 16

17 Strategies Industry Should Develop and Disseminate Critical Data Industry could provide much better information to governments regarding: Primacy of undersea cables for various economic and governmental activities; Role of undersea cables in providing mobile backhaul and transporting Internet content; How capacity is sold; and Benign environmental characteristics. 17

18 Strategies Industry Should Take a Pro-Active Approach Engage with regulators, lawmakers, and customers. Educate in advance. Participate in key proceedings. Organize site visits to cable stations and cable ships. Use current events (e.g., earthquakes and tsunamis) as educational opportunities. Capture the public s imagination. 18

19 Kent Bressie WILTSHIRE & GRANNIS LLP th Street, N.W., Suite 1200 Washington, D.C U.S.A office mobile fax Kent Bressie 19

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