Comments filed early this week in response to the FCC’s recent proposal to streamline the agency’s international reporting requirements demonstrate overwhelming support for elimination of circuit status, traffic and revenue reporting requirements, which are viewed as archaic and overly burdensome in light of current competitive conditions in the international calling market. Providers of international telecommunications services are required to file annual reports with the FCC that outline traffic totals and associated revenues for international voice, private line and miscellaneous services. Additionally, international service providers must file annual reports with the FCC that identify their submarine cable, satellite and terrestrial capacity between the United States and foreign destinations. Citing the competitive state of the international calling market, and acknowledging that monetary and time costs borne by carriers and the FCC in collecting, compiling and analyzing annual report data may now exceed the benefits of that information, the FCC launched rulemaking proceedings on March 23 that propose (1) to eliminate the annual traffic and revenue reporting requirement, and (2) streamline or eliminate the annual circuit capacity reporting requirement.

Recommending elimination of both the traffic/revenue report and the circuit capacity report, the United States Telecom Association (USTA) argued that “given the substantial competition in the international marketplace—including from overthe-top voice over Internet protocol providers—the . . . reports are burdensome and are no longer necessary.” Wireless association CTIA echoed USTA’s sentiments, describing the annual reporting requirement as “a vestige of a time when there was little or no competition in foreign markets or along U.S-international service routes.” Although USTA acknowledged the usefulness of annual reports, which, at that time “allowed the Commission to monitor U.S.- international routes for anti-competitive behavior,” CTIA told the agency that “today’s thriving international services marketplace does not raise those competitive concerns.”

AT&T, meanwhile, pointed to the “growing popularity and competitive impact of free international calling services,” which are not even covered in the annual reporting requirement. Asserting that “foreign termination rates have remained at historically low levels for many years and most Commission regulation that formerly relied on this data is no longer in effect,” AT&T claimed that the original purpose of the annual reporting requirement “no longer justifies the burdens.” As Sprint concurred with the FCC’s estimate that a filing entity spends an average of 203 hours each year collecting, preparing and filing an international traffic and revenue report and an additional 14 hours preparing a circuit capacity report, Inmarsat advised the FCC that “the value of today’s reports is questionable given that they may not even accurately reflect the U.S.-international marketplace,” which is increasingly dominated by non-interconnected voice over Internet protocol providers which are not subject to annual reporting obligations.