Justification Letter

Federal Communications Commission
45 L Street, NE
Washington, D.C. 2A554
April24,2A23
Mr. Alexander Hunt
Chief, Information PolicY Branch
Office oflnformation and Regulatory Affairs
Office of Management and Budget
725 17h Street, N.W.
Washington, D.C.20543
Dear Mr. Hunt:
and Budget
The Federal Communications Commission (Commission) requests Office of Management
processing"
"emergency
the
under
herein
described
(OXg) approval to submit the information collection
is
The
Commission
(5
1320'13)'
proririort of the Paperwork Reduction Act (PRA) of 1995 CfR $
approval
OMB
request
requesting clearance for a new one-time information collection. We respectfully
foithis one-time collection ao later than37 days after it is received at OMB.

promotion of national security is an integral part of the Commission's public interest responsibility and one of
the core purposes for which iongr*r. created the Commission. In the Evolving Risks Order and Noticer the
Commission is taking another important step to protect the nation's telecommunications infrastructure
from threats in an evolving national security and law enforcement landscape by proposing comprehensive
changes to the Commission's rules that allow carriers to provide international telecommunications service
purstiant to section 214 of the Communications Act af 1934, as amended (Act).2 Through the proposals.in
the Evalving Risks Order and Notice the Commission is astingto ensure that the Commission is exercising
appropriate wersight of international section 214 arfihoriration holders to safeguard U.S.
telecommunications networks. To make sure that these proposals are effective and efficient the
Commission needs up-to-date information about the carriers that are providing service using international
section 214 authorizations. Consequently, as part of the Evolving Risl$ Order and Notice the Commission
adopted a one-time collection of foreign ownership information from international section 214
authorization holders
The collection of this information is a necessary first step for the Commission to make an informed decision
concerning the proposed rules and procedures set fo*h in the Evolving Risks Order and Notice. The
Commission has incomplete and outdated information about international section 214 authoization holders.
For example, the Commission's records in its electronic database for international section 214 authorization
- the International Communications Filing System (ICFS) - reflect there are approximately 7,000
international section 214 atthonzation holders, though we estimate the more accurate number is closer to
approximately 1,500 active authorization holders. Additionally, we do not have visibility on authorized
carriers' current foreign ownership. The information derived from this one-time collection will allow the
Commission to determine the number of active authorization holders and whether they have reportable
foreign ownership. In addition, the information will enable the Commission to identifr those authorization
I Review of International Section 214 Authorizations to Assess EvolvingNational Security, Law Enfarcement, Foreign
Poticy, and Trade Poticy Risl*, IB Docket No. Zi-l 19; Amendment of the Schedale of Application Fees Set Forth in
Sections 1.11A2 througft 1.1109 of the Commissian's Rules,MD Docket No.23'134, Order and Notice of Proposed
Rulemaking, FCC23-28 (rel. Apr. 25,2023) (Evolving Risks Order and Notice).
2

47 U.S.C. $

2i4.

but discontinued service under their international
holders that are no longer in business or are in business
and
assist the Commission in developing a timely
section 214 authority. Overall, the information will
section 214 authorizations that are most likely to
effective process for prioritizing the review-oiirrt.roatlonal
and/or trade policy corcems'
raise national ,.**ity, law enforrcemen! foreign policy,
rures and poricies that will better protect
Delay in obtaining this information win deray the iru]ryenlajion
states in light of evolving national security'
telecommunications services and in&astructure in tle unlteo
law enforcement, foreign policy, and trade policy risks'

PRAapp.roval as set forth in 5 CFR $
We believe that these circumstances meet the criteria for emergency
necessary regular submission requirements under the
1320. 13(a).3 The Commission will conduct all of the
PRA after approval of this emergency request'
immediately provide any additional
The Commission staff is ready to work with your PRA Desk Officer to
for ttrisone-time information
request
emergency
information needed to ensure oMB approvaf of this
your PRA Desk Officer contact
have
Please
collection no later than37 days after iiis received at OMB.
are any questions or if you need
there
if
Cathy williams atga}4lg-291g or at Cathy.Williams@fcs.gov
additional information.
Sincerely,

MARK

ffi:*Iffifl,*

STEPHENS

mf,'if;r

Mark Stephens
Managrng Director
Federal Communications Commission

I "Any such request shall be accompanied by a witten determination that: (1) The collection of information:
(i) Is needed prior to the expiration of time periods established under this Part; and (ii) Is essential to the mission of the
agency; and (2) The agency caffrot reasonably comply with the normal clearance procedures under this part because:
(i) Public harm is reasonably likely to result if normal clearance procedures are followed; (ii) An unanticipated event
has occurred; or (iii) The use of normal clearance procedures is reasonably likely to prevent or disrupt the collection of
information or is reasonably likely to cause a statutory or court ordered deadline to be missed'" 5 CFR $ 1320'13(a).