OMB Control Number
3060-1116
OMB Expiration Date October 31, 2008[[1]]
This message is a follow up to emails sent by the
FCC in April[[2]] seeking cooperation of submarine cable
operators in voluntarily providing information related to FCC-licensed submarine
cable(s). Based upon input provided
by operators[[3]], we hereby clarify our voluntary
information request.
We request that each operator advise the FCC
no later than June 2, 2008, whether it voluntarily commits to providing the
information requested in our earlier request as clarified in this email. Each operator should indicate the date
by which it can implement item (1) below and the date by which it can provide to
the FCC the information described in items (2), (3) and (4)
below.
Each operator may respond to the FCC
separately from this email chain.
As stated in our earlier emails, we seek
this voluntary cooperation, consistent with our authority and responsibilities
under the Cable Landing License Act, 47 U.S.C. § 34 et seq., the Communications
Act of 1934, as amended, 47 U.S.C. §§ 151, 154(i), 303(r) and 403, and Executive
Order 10530 §5(a) (May 10, 1954), reprinted as amended in 3 U.S.C. § 301. This information is needed in order to
support Federal Government national security and emergency preparedness
communications programs, for the purposes of providing situational awareness of
submarine cable system performance as well as a greater understanding of
potential physical threats to the cable system. We recognize that the information
requested is sensitive, for national security and/or commercial reasons, and as
explained below we presumptively will treat it as confidential upon
submission.
We clarify the earlier request as set forth
below. In doing so, we emphasize
that we are not asking for a voluntary commitment to provide information not
already generated in the operation of the cable systems or in the possession of
the operator.
Format, content,
thresholds, frequency, and timeliness: We recognize that
operator-generated information covering system status and restoration
data in item (1) below (and all subparts) varies widely in format, content,
threshold, and volume. Some may not generate all fields of data.
Some may have a low threshold for generating a report and others may have
a higher threshold. Whatever the case may be, our view is that if the
company feels it is important enough that it generates the information for
itself or for another owner/operator, then that threshold is acceptable. Because of these great differences, and
to minimize the burden on licensees, we do not request that a formal report be
produced. At the same time, we recognize that operators will need to apply
discretion in determining what is the appropriate data for sharing with the
Federal Government. Original information suffices and is actually
preferred at the time of its generation with full recognition that such
information is, like all developing information, subject to change as a given
situation is clarified.
Specifically, we ask that each operator
voluntarily commit to providing the following information, if it is information
the operator already generates, with respect to its cable system(s). If an operator is not already generating
data related to a particular field identified below, then it should simply
indicate in its reply that such data for that field is not available.
(1) System status and restoration: We understand that every owner/operator
of a submarine cable generates and receives varying forms of email and other
data or documents related to the technical performance of its system and
developments that may have an impact on its operation or security. This information, which provides
owner/operators with situational awareness on an ongoing basis for their
submarine cables includes, but is not limited to, email messages, frequently
referred to as "international restoration" messages (for consortia systems),
“trouble tickets,” and so forth. While we recognize that the form and content of
such communications can vary widely depending on the company producing them, the
arrangements which generate them, and the reasons for which they are being
produced, we desire the following fields of data for systems landing on U.S.
sovereign soil (to the extent they are generated in the normal course of
business):
1. Indications of potential problems
(alarms, safety and security concerns, changes in latency, fiber degradation and
any other concerns you may have);
2. Potential
traffic-impacting/hazardous conditions/impairments (electrical and optical
faults such as shunt and power conductor faults, fiber break, undersea and
terrestrial component failures, terminal equipment failures, card failures,
circuit pack problems, faulty switches, planned maintenance or construction,
other maritime hazards);
3. Impact information
(affected facilities as well as outage and return to normalization
times);
4. Restoration
activity (ring switches, auto span switches, facility restoration status
pursuant to approved restoration plans);
5. Repair activity
(fault localization, repair plans, progress, vessel activity, power
reconfiguration);
6. Periods of test
activity - Optical time domain reflectometry (OTDR), coherent OTDR (COTDR), and
other technical measurement activity for fault localization; link tests;
terminal equipment tests (we do not request the actual test
measurements);
7.
Event/activity/message date/time – the information is to be provided when
generated in the normal course of business as part of commercial communications
processes; and
8. Addressees – Email
addresses for any foreign owner/operators also receiving the information at the
time of generation are also requested.
Email addresses for specific individuals are not requested but are an
acceptable substitute if they identify companies receiving the email.
(3)
Undersea Location
Spreadsheet: We request that each operator
provide after-installation information in the form of an electronic spreadsheet
of its associated route position list (RPL). Please detail the position of all system
components – including repeaters, joints, branching units, repair splices,
burial positions, burial depth and whether the cable is armored or
unarmored. We request
that the operator report annually to update this information if there any
changes to the routing.
(4)
Restoration
Capability: We request that each operator
provide information on its submarine cable system restoration capability
(internal and external). Please
indicate whether the system has a Universal Restoration Manual, what type of
catastrophic restoration plans (or similar plans for extreme circumstances) are
in place and which other cable systems might be used for restoration. We request that the operator
provide a copy of any existing Restoration Manual, and report annually to update
this information.
Data Provision
Mechanisms: To simplify operators’
voluntary compliance with this request, we will allow them to provide the
information using alternative methods as shown below. For system status and restoration
data, operators will be able to provide information using either a document
management system established by the FCC (which will provide authentication
processes) or carbon copies to a designated FCC email address. For cable mapping and restoration
capability data, operators will be able to provide information to the FCC
using either computer-readable media such as CDs or DVDs or paper copies. We request that, in your responses to
this email, you elect which of these methods you will use to provide us the
information. The FCC point of
contact for the information collection will be
As mentioned above, and as stated in our
earlier emails, we recognize that the information requested is sensitive for
national security and/or commercial reasons. Information provided pursuant to this
request will be viewed as presumptively confidential upon submission because the
submissions would reflect voluntary reports on weaknesses in or damage to
national communications infrastructure, and the release of this sensitive
information to the public could potentially facilitate terrorist targeting of
critical infrastructure and key resources.
The submissions also may contain internal confidential information that
constitutes trade secrets and commercial/financial information that the
operator does not routinely make public and public release of the submitted
information could cause competitive harm by revealing information about the
types and deployment of cable equipment and the traffic that flows across the
system. For these reasons, the
information requested in (2) and (3) above is presumptively exempt from public
disclosure under Freedom of Information Act (FOIA) Exemption 3, 5 U.S.C. §
552(b)(3), and section 4(j) of the Communications Act of 1934, as amended, 47
U.S.C. § 154(j), as implemented in 47 C.F.R. § 0.457(c)(1)(i) (exempting
disclosure of “maps showing the exact location of submarine cables”). The information requested in (1) and (4)
above will be considered exempt under Exemption 4 of the FOIA, 5 U.S.C. §
552(b)(4). If a FOIA request is
filed for information submitted in response to this request, you will be
notified of the FOIA request and given the opportunity to oppose release of the
records. See 47 C.F.R. §
0.461(d)(3). We note that the
information provided in response to this request will be shared with the
Department of Homeland Security’s National Communications System (NCS) and
relevant Executive Branch agencies on a confidential basis. See 44 U.S.C. §
3510.
PAPERWORK REDUCTION ACT
STATEMENT
We have estimated that
each response to this collection of information will take an average of 550
hours. Our estimate includes the
time to read the instructions, look through existing records, gather and
maintain required data, and actually complete and review the form or
response. If you have any comments
on this estimate, or on how we can improve the collection and reduce the burden
it causes you, please write the Federal Communications Commission, Office of
Managing Director, AMD‑PERM, Washington, DC 20554, Paperwork Reduction Act
Project (3060‑1116). We will
also accept your comments via the Internet if you send an e-mail to PRA@fcc.gov.
Please DO NOT
SEND COMPLETED DATA TO THIS ADDRESS.
You are not required to respond to a collection of information sponsored
by the Federal government, and the government may not conduct or sponsor this
collection, unless it displays a currently valid OMB control number and/or we
fail to provide you with this notice.
This collection has been assigned an OMB control number of
3060‑1116.
THIS NOTICE IS
REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104-13, OCTOBER 1,
1995, 44 U.S.C. SECTION 3507.
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