As Kelley Drye reported in an earlier post, the Federal Communications Commission (FCC) is considering rules that would impose on submarine cable system licensees, and possibly users, network outage reporting obligations similar to those already applicable to other communications providers.  The FCC’s Notice of Proposed Rulemaking (NPRM) solicits comments on a number of issues including, but not limited to, who should be subject to the reporting requirements, proposed outage reporting triggers and time frames, and measures that can be taken to speed the cable deployment process – an issue that could implicate the Team Telecom review process.  See our Advisory on the NPRM for more details.

The NPRM was published yesterday in the Federal Register, which set the comment date asDecember 3, 2015, and reply comment date as December 18, 2015.  Submarine cable licensees – and entities that utilize submarine cable systems – should review the NPRM and consider whether to participate in the comment cycle to ensure their views are heard.