federal communications commission da 98-2550...

Federal Communications Commission

Before the Federal Communications Commission

Washington, D.C. 20554

In the Matter of ) )

AT&T CORP. ) )

ACCESS TELECOM ) )

GTE HAWAIIAN TEL INTERNATIONAL INC. ) )

IDB WORLDCOM SERVICES INC. ) )

IT&E OVERSEAS, INC. ) )

MCI INTERNATIONAL, INC. ) )

PACIFIC GATEWAY EXCHANGE ) (BERMUDA) LIMITED )

) PCI COMMUNICATIONS, INC. )

) SEQUEL CONSULTING, INC. )

) TRANSOCEANIC COMMUNICATIONS, INC. )

) WORLDxCHANGE COMMUNICATIONS )

) WORLDTOUCH COMMUNICATIONS, INC. )

) GUAM-PIDLIPPINES CABLE LIMITED )

PAR1NERSHIP ) )

DA 98-2550

Application for a license to land and operate in the ) File No. SCL-AMD-19980902-00018 United States a private fiber optic cable system ) extending between Guam and the Philippines, the ) Previous File No. SCL-98-004 G-P Cable System.

CABLE LANDING LICENSE

Adopted: December 14, 1998 Released: December 15, 1998

By the Chief, Telecommunications Division:

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Federal Communications Commission DA 98-2550

I. Introduction

I. In this Order, we grant the application of the participating parties (Joint Applicants)1

pursuant to the Cable Landing License Acf for authority to land and operate a private fiber optic submarine cable system, the Guam-Philippines Fiber Optic Submarine Cable System (G-P Cable System) extending between Guam and the Philippines. This system will be operated on a non-common carrier basis. We find that the Joint Applicants have provided sufficient information under our rules to comply with the Cable Landing License Act, and we grant the cable landing license subject to the conditions listed below.

II. Application

2. Access, IT &E and PCI are corporations organized and existing under the laws of the Territory of Guam. AT&T is a corporation organized and existing under the laws of the state of New York. HT!, WorldCom, MCII, TOCI and WorldTouch are corporations organized and existing under the laws of the state of Delaware. PGE is a corporation organized and existing under the laws of · Bermuda. Sequel, d/b/a Sequel Concepts, is a corporation organized and existing under the laws of the state of New Jersey. WorldxChange is the doing-business name of Communications TeleSystems International, a corporation organized and existing under the laws of the state of California G-P LP is a limited partnership organized under the laws of the Cayman Islands. G-P LP has one general partner, the Guam-Philippines Cable Company of Hong Kong (GPCC). 3 GPCC acts as the management arm of G-P LP and is responsible for the day-to-day operation and maintenance of the G-P Cable System. Kanematsu Corp., a diversified Japanese trading company, owns 99.99 percent of GPCC's shares.4 G-P LP will own approximately 90 percent of the G-P Cable System, the other Joint Applicants will .own approximately 4 percent, and foreign carriers will own approximately 5 percent. The G-P Cable System is scheduled to begin service on March 31, 1999.

3. The G-P Cable System will consist of three segments. Segment A, owned by TOCI, will consist of the appropriate share of the existing cable station at Tanguisson Point, Guam. Segment B, owned by the Joint Applicants and foreign carrier owners, will consist of the entire submarine cable, including interfaces at both ends, and will contain two optical fiber pairs. One optical fiber

The Joint Applicants are AT&T Corp. (AT&T); Access Telecom (Access); GTE Hawaiian Tel International Inc. (HTI); IDB WorldCom Services, Inc. (WorldCom); IT&E Overseas, Inc. (IT&E); MCI International, Inc. (MCm; Pacific Gateway Exchange (Bermuda) Limited (PGE); PC! Communications, Inc. (PCI); Sequel Consulting, Inc. (Sequel); Transoceanic Communications, Inc. (TOCI); WorldxChange Communications (WorldxChange); WorldTouch Communications, Inc. (WorldTouch); and Guam-Philippines Cable Limited Partnership (G-P LP). See Application of AT&T Corp. et al., File No. SCL-AMD-19980902-00018 (filed Apr. 30, 1998).

2 An Act Relating to the Landing and Operation of Submarine Cables in the United States, 47 U.S.C. §§ 34-39 (1994) (Cable Landing License Act).

G-P LP also has five limited partners: Kanematsu Corp., Tyco Submarine Systems, Ltd., Kokusai Denshin J:)enwa Submarine Systems, Inc., Philippine Long Distance Telephone Company (PLOT), and Nishimen Corporation.

4 Kanematsu Corp. has no 10-percent or greater shareholders.

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pair, the service fiber pair, will operate at 5 Gbps, with the total configuration upgradeable to 20 Gbps. Segment C, owned by PLDT, will consist of the appropriate share of the existing cable station at Batangas, the Philippines. The G-P Cable System will employ multiplex and/or digital cross connect equipment, or an appropriate share thereof in each of the cable stations, as required. The design capacity of the G-P Cable System will consist of thirty-two Basic System Modules providing 2,016 MIUs5 or any increase or decrease as determined from time to time by the G-P Cable System Management Committee. The G-P Cable System will be connected using suitable facilities to the domestic networks in Guam and the Philippines and will also be extended to the terminals of other cable systems, such as TPC-5 and APCN Cable Systems. 6

fil Comments

4. The application was placed on public notice on May 13, 1998. Worldx.Change, one of the Joint Applicants, filed comments urging the Commission to grant the application subject to conditions. The other Joint Applicants filed comments in opposition to WorldxChange. Tyco Submarine Systems also filed comments urging the Commission to grant this application expeditiously. On September 2, 1998, the Guam-Philippines Cable Limited Partnership (G-P LP), together with all the Joint Applicants except Worldx.Change, filed a request to amend the application to add G-P LP as a licensee. We placed the amendment on public notice, 7 and Worldx.Change filed comments on the amendment. Pursuant to Section 1. 767(b) of the Commission's rules, 8 the Cable Landing License Act, and Executive Order No. 10530, we informed the Department of State of the application and the amendment.9 The Department of State, after coordinating with the National Telecommunications and Information Administration and the Department of Defense, stated that it has no objection to issuance of the cable landing license. 10

5 A l\1IU is the minimum unit of investment in the G-P Cable System, mapped into a VC-12 with effective usage of 2.048 Mbps and the additional 420,571.43 bps required for multiplexing in each direction. See Application at 6.

6 In the future, the G-P Cable System will be connected to the China-US Cable System landing in Guam and the SE-ME-WE-3 Cable System in the Philippines.

7 Public Notice Report No. TEL-00007NS (Sept. 11, 1998).

8 47 C.F.R. § 1.767(b) (1997).

9 Letter from Diane J. Cornell, Chief, Telecommunications Division, International Bureau, FCC, to Steven W. Lett, Deputy U.S. Coordinator, Office of International Communications and Information Policy, U.S. Department of State (May 12, 1998).

10 - Letter from Ambassador Vonya B. Mccann, United States Coordinator, International Communications and Information Policy, U.S. Department of State, to Regina M. Keeney, Chief, International Bureau, FCC (Dec. 8, 1998).

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IV. Discussion

A. The Amendment

5. WorldxChange originally argued that the application "lacks an indispensable party, over whom the Commission must acquire jurisdiction to ensure the cable will serve the public interest," because the majority owner, G-P LP, was not an applicant. Subsequently, G-P LP and the other Joint Applicants (other than WorldxChange) filed a request to amend the application to include G-P LP as an applicant. WorldxChange's comments on the amendment stated that the application is now properly before the Commission because the indispensable party had been added as a coapplicant.11 We grant the amendment. As a result, the Joint Applicants together own about 94 percent of the G-P Cable System. This license is granted subject to the condition that the licensees maintain both de jure and de facto control of the cable system.

B. Private Submarine Cable Policy

6. The Joint Applicants propose to operate the G-P Cable System as a non-common carrier system in which capacity will not be sold indifferently to the user public. Tue Joint Applicants will offer bulk capacity in the G-P Cable System to a specific class of eligible users, including common carriers, on an original ownership, indefeasible right of user or lease of capacity basis. The Joint Applicants request a license under the Commission's private submarine cable policy, which is intended to promote competition in the provision of international transmission facilities. 12 Pursuant to this policy, the Commission has authorized non-common carrier cables where (1) there is no legal compulsion to serve the public indifferently and (2) there are no reasons implicit in the nature of the operations to expect an indifferent holding-out to the eligible user public.13 This two-part test is derived from a court decision known as NARUC I. 14

7. · WorldxChange argues that we should authorize the G-P Cable System as a "hybrid" private/common carrier cable. Specifically, WorldxChange proposes that, for three years, 25 percent of the system's capacity should be reserved for common carriers on a nondiscriminatory basis without regard to the amount of capacity purchased by each carrier. Such regulation is warranted, according to WorldxChange, because of the cable's mixed carrier/non-carrier ownership and because it will be a bottleneck facility.

8. The fact that a cable system is owned by common carriers does not mean that such a cable is subject to common carrier regulation. Rather, the test for whether or not a cable should be

II See WorldxChange September 25 Comments at 5.

12 See Tel-Optik, Ltd, 100 F.C.C.2d 1033, 1040-42, 1046-48 (1985); see also Cable & Wireless, pie, 12 FCC Red 8516 (1997).

1 ~ See Cable & Wireless, 14; see also Optel Communications, Inc., 8 FCC Red 2267 (1993) .(conditional license).

14 National Association of Regulatory Utility Commissioners v. FCC, 525 F.2d 630, 642 (D.C. Cir.) (NARUC l), cert. denied, 425 U.S. 992 (1976).

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regulated as a common carrier cable system is based on the two-prong NARUC I test outlined above. Thus, we do not find dispositive WorldxChange's argument that some of the capacity of the G-P Cable System should be subject to common carrier regulation because some of its owners are common carriers.

9. The first part of the NARUC I test directs us to consider whether there is any legal compulsion to serve the public indifferently. In applying this prong of the test to submarine cable authorizations, the Commission has stated that there will be no legal compulsion to serve the public indifferently where there is no public interest reason to require facilities to be offered on a common carrier basis. This public interest analysis has generally focused on the availability of alternative facilities. Where there are sufficient alternatives, the licensee will lack market power and will not be able to charge monopoly rates for cable capacity. The Commission has found that, in those circumstances, the public interest would be served by allowing a submarine cable to be offered on a non-common carrier basis. 15 This logic applies whether or not the owners of the cable system are themselves carriers.

10. We do not agree with WorldxChange that the G-P Cable System is a bottleneck facility. We find that the existence of other facilities will constrain the ability of the Joint Applicants to exercise market power. Although the existing cable facilities directly between Guam and the Philippines have reached total usable capacity limits, there are alternative facilities, both cable and satellite, providing connectivity between Guam and the Philippines. For example, TPC-5 connects Guam and Japan, where it connects with the APCN Cable Network, which has a terminal point in the Philippines. In addition, alternative service is available from the U.S. mainland· via HA W-4 and TPC-3, which lands in Guam and Japan and then connects to APCN. WorldxChange makes a number of arguments that the alternative routes are inferior because indirect routes are more expensive, some of the alternatives use non-common carrier cable systems, and satellite links are not a satisfactory alternative. We find that alternative indirect routes, circuits on non-commort carrier cable systems, satellite links, and the prospect of future cable construction constrain the ability of the G-P Cable System to exercise market power. Satellite circuits, for example, may be inferior for carrying voice traffic, but can nevertheless compete with fiber optic circuits for providing many non-voice services.

11. Furthermore, the G-P Cable System is designed not only to provide capacity between Guam and the Philippines, but to be a link between cables providing transpacific capacity.16

Therefore, the system will have to compete in the much larger market for carriage of transpacific traffic. The ability of the G-P Cable System to exercise market power in that larger market will be constrained by the existence of many other transpacific facilities. The transpacific route currently is served by a number of submarine cable systems, including HA W-4rrPC-3, NPC, TPC-4, PacRim.East, and TPC-5. In addition, other submarine cable systems are planned in the Pacific, including the PC-1 cable system and the China-US Cable Network. 17 Satellite facilities are also available in the Western

IS See, e.g., Cable & Wireless, 12 FCC Red at 8523.

16 See Application at 6-7.

17 See PC Landing Corp., File No. SCL-98-006, DA 98-2351 (rel. Nov. 23, 1998); AT&T Corp. et al., SCL-98-002, DA 98-1711 (rel. Aug. 28, 1998) (China-US Cable).

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Pacific Region, including the Mabuhay satellite, INTELSAT (174°E), AsiaSat, and commercial capacity from NASA's Tracking and Data Relay Satellite System (TDRSS).

12. Accordingly, we conclude that it is not necessary to require that the G-P Cable System be operated on a common carrier basis at this time. For the same reasons, it is unnecessary to require any portion of its capacity to be reserved for carriers and offered at nondiscriminatory rates, as Worldx.Change suggests. We note, however, that we always have the ability to impose common carrier or common-carrier-like obligations on the operations of this or any other submarine cable system if the public interest so requires. Furthermore, we have always maintained the authority to classify facilities as common carrier facilities subject to Title II of the Communications Act if the public interest requires that the facilities be offered to the public indifferently.18

13. Regarding the second prong of the NARUC !test, the Joint Applicants state that capacity will not be sold indifferently to the user public. Instead, the G-P Cable System will offer bulk capacity to particular bulk capacity users who will be able to obtain capacity on the system through ownership and leases of capacity. Thus, there is no reason to expect that capacity in the proposed cable system would be held out to the public indifferently. The fact that most of the initial owners of capacity are themselves common carriers does not change this analysis.

14. Based on the above analysis, we conclude that the Joint Applicants will not offer capacity in G-P Cable System to the public on a comm.on carrier basis and that the public interest does not require that they do so. Accordingly, we find that the applicants will not provide a telecommunications service for a fee to such class of users as to be "effectively av.ailable directly to the public" and thus will not be "telecommunications carriers" under the 1996 Act.19 We conclude that it is appropriate. to license the G-P Cable System on a non-common carrier basis.

C. Ownership and Landing Points

15. The Joint Applicants have provided the ownership information required by Section l.767(a)(6), Section 63.18(e)(6), and Section 63.18(h) of the Commission's rules. None of the Joint Applicants is affiliated with a foreign carrier in the Philippines, the only foreign point at which the G-P Cable System lands.20 Therefore, we find that the Joint Applicants' foreign affiliations do not

18 See, e.g., Foreign Participation Order if 95; Cable & Wireless, 12 FCC Red at 8531; China-US Cable if 15.

19 See 47 U.S.C. § 153(44) (defining "telecommunications carrier"); Cable & Wireless if 17.

20 G-P LP states that it is not affiliated with any foreign carrier. See Amendment to the Joint Application for a Cable Landing License (filed Sept. 2, 1998), at 10-11. It does not, however, explain the extent of each limited partner's ownership other than to list those limited partners. One of those limited partners is the Philippine Long Distance Telephone Company (PLDn, which is the incumbent carrier in the Philippines and has not been found to lack market power. We accept G-P LP's representation that PLDT's ownership interest does not rise to the level of an affiliation under our rules, but we also note that, even if it does create an affiliation, that affiliation would not warrant our concern. Because the Philippines is a member of the World Trade Organfzatlon, we presume that the affiliation does not pose any concerns that would justify denial of the application for competitive reasons. See Foreign Participation Order ft 93, 50. No party has attempted to rebut this presumption.

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raise any concerns in our consideration of this application under Section 2 of the Cable Landing License Act.

16. The Joint Applicants have complied with Section l.767(a)(5) of the Commission's rules by providing, with the application, specific information on the cable landing location in Guam, a United States Territory. The location of the cable station in Tanguisson Point, Guam, is a matter of public record. 21 This license is therefore not subject to any further public notice or Commission approval of the cable system's landing points pursuant to the procedure in Section 1.767(a)(5).

D. Other Issues

1. Pricing Issues

17. WorldxChange argues that the application is defective because it fails to disclose the "discriminatory" pricing schedule of the G-P Cable System. WorldxChange argues that the pricing on the G-P Cable System is discriminatory, especially the volume discounts offered to the larger carriers. WorldxChange also argues that the Joint Applicants may not sell their MIUs and are "severely limited as to their use of their MIUs. "22 In response, the other Joint Applicants agree that the Agreement does not specify the prices for capacity but argue that each purchaser, including WorldxChange, knew the pricing schedule when it made its purchasing decision.

18. The Commission's policies allow capacity on a non-comm.on carrier cable system to be sold at discriminatory prices or pursuant to individualized decisions. Pricing and service quality are controlled by market forces rather than by common carrier regulation. Because we have found that there are sufficient alternative current and future facilities serving the Guam-Philippines route and the larger transpacific route, we find that there is no need to require capacity on the G-P Cable System to be offered on a nondiscriminatory basis.

19. WorldxChange also argues that the pricing on the G-P Cable System is contrary to the Cable Landing License Act, under which the Commission may grant licenses "upon such terms as shall be necessary to assure just and reasonable rates and service in the operation and use of cables so licensed. "23 In this case, for the reasons already discussed, we are satisfied that market forces will assure just and reasonable rates and service. Because there are sufficient alternative current and future facilities serving the Guam-Philippines route and the larger transpacific route, competition will constrain the licensees• ability to exercise market power.

20. As noted, however, we retain authority to impose additional obligations on the operations of this cable system should it become necessary in order to ensure just and reasonable rates

21 See Cable Landing License for Haw-4/TPC-3, GP-2 Cable System, SCL-85-003 (rel. Dec. 27, 1985), modified Aug. 27, 1988.

22 - WorldxChange June 10 Comments at 3-5.

47 u.s.c. § 35.

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and service. 24 We grant this license subject to such a condition. 25 For example, if market conditions were to change so substantially as to create a capacity shortage, we might find additional regulations necessacy to control the licensees' exercise of market power. Also; if pricing or service decisions appear to be made for an unlawful or anticompetitive purpose, we would consider addressing such an action pursuant to our authority under the Cable Landing License Act.26

2. Robinson-Patman Act

21. In its comments on the request to amend the application to add G-P LP as ail applicant, WorldxChange raised for the first time its argument that the volume discount pricing violates the Robinson-Patman Antidiscrimination Act.27 The Robinson-Patman Act, which amended Section 2 of the Clayton Act, is an antitrust statute directed at price discrimination. Its purpose is to limit the forcing of price concessions by large-volume buyers. The other Joint Applicants, in response, point out that the Robinson-Patman Act applies only to "commodities of like grade and quality, "28 and they argue that none of the interests at issue here are covered by that term. The other Joint Applicants argue that WorldxChange purchased "an ownership interest in the G-P Cable System giving it a right to use the cable system and a conditional right to the unsold portion of the cable system's common reserve." Those interests, the other Joint Applicants claim, are "intangible rights, rather than commodities of like grade and quality. "29

22. We agree with the other Joint Applicants that the Robinson-Patman Act does not apply to the interests at issue here. It is well established that the Robinson-Patman Act does not apply to "intangibles" or to "services. "30 The rights obtained by WorldxChange and the other Joint Applicants include various rights and interests that are clearly not tangible commodities:

• •

24

An ownership interest in the G-P Cable System; The right to use the G-P Cable System;

See supra , 12.

See infra, 25(6).

26 Worldx.Change asks the Commission to instruct the Joint Applicants that no discrimination against, or intimidation of: WorldxChange in its access to and use of the G-P Cable System as a result of its filing comments in this proceeding will be tolerated. Any such retaliation would not be countenanced by the Commission.

27 15 U.S.C. § 13(a); see WorldxChange Sept. 25 Comments at 10-14.

Joint Applicants October 7 Reply Comments at 13 (quoting 15 U.S.C. § 13(a)).

29 Id

30 See ABA Section of Antitrust Law, Antitrust Law Developments (Fourth), vol. I, at 441-42, and cases cited therein; e.g., National Communications Ass'n v. American Tel. &: Tel. Co., 808 F. Supp. 1131, 1135-36 (S.D.N.Y. 1992) (holding that long-distance voice telecommunications services do not constitute commodities under the Robinson-Patman Act).

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• The indefeasible right to use applicable portions of the cable stations in Guam and the Philippines;

• The right to request transit facilities in Guam and the Philippines; • A contingent ownership interest in that part of the cable system's common reserve_that G-P LP

is unable to sell during a IO-year period from the system's ready-for-service date; and • Liquidation rights at the tennination of the G-P Cable System.31 -

Even if individual units of capacity in the cable system were deemed "commodities of like grade and quality" for the purpose of this analysis, the applicability of the Robinson-Patman Act would tum on the "dominant nature of the transaction. "32 If a sale of commodities is incidental to the provision of services, it is outside the scope of the Act Here, we find that the services and intangibles involved in this transaction clearly outweigh any commodities, and therefore the Robinson-Patman Act does not apply.

E. Environmental Impact

23. Based on the infonnation provided by the Joint Applicants and pursuant to the Commission's procedures implementing the National Environmental Policy Act of 1969,33 we conclude that the grant of the requested authorization would not significantly affect the environment. Consequently, the Joint Applicants are not required to submit an environmental assessment, and this application is categorically excluded from environmental processing.

IV. Conclusion

24. .Accordingly, we conclude that U.S. interests under the Cable Landing License Act will be served by grant of the license to the Joint Applicants as conditioned below.

V. Ordering Clauses

25. Consistent with the foregoing and pursuant to the Cable Landing License Act and Executive Order 10530, we hereby GRANT AND ISSUE the Joint Applicants a license to land and operate a non-common carrier fiber optic cable system (two fiber pairs, initially operating at 5 Gbps per pair, upgradeable to 20 Gbps) extending from Guam to the Philippines. This grant is subject to all rules and regulations of the Federal Communications Commission; any treaties or conventions relating to communications to which the United States is or may hereafter become a party; any action by the Commission or the Congress of the United States rescinding, changing, modifying, or amending any rights accruing to any person hereunder; and the following conditions:

31

(1) The location of the cable system within the territorial waters of the United States of America, its territories and possessions, and upon its shore shall be in conformity with plans approved by the Secretary of the Army, and the cables shall be moved or shifted by the

See Joint Applicants October 7 Reply Comments at 15.

32 - See Antitrust Law Developments (Fourth}, vol. I, at 441.

33 47 C.F.R. §§ 1.1301-.1319 (1997).

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Licensees at their expense upon the request of the Secretary of the Army whenever he or she considers such course necessary in the public interest, for reasons of national defense, or for the maintenance or improvement of harbors for navigational purposes;

(2) The Licensees shall at all times comply with any requirements of United States government authorities regarding the location and concealment of the cable facilities, buildings, and apparatus for the purpose of protecting and safeguarding the cables from injury or desttuction by enemies of the United States of America;

(3) The Licensees or any persons or companies controlling them, controlled by them, or under direct or indirect common control with them do not enjoy and shall not acquire any right to handle traffic to or from the United States, its territories, or its possessions unless such service be authorized by the Commission pursuant to Section 214 of the Communications Act, as amended;

(4) The Licensees or any persons or companies controlling them, controlled by them, or under direct or indirect common control with them shall not acquire or enjoy any right to land, connect, or operate submarine cables that is denied to any other United States company by reason of any concession, contract, understanding or working arrangement to which the Licensees or any persons controlling them, controlled by them, or under direct or indirect common control with them are parties;

(5) Neither this license nor the rights granted herein shall be transferred, assigned, or in any manner either voluntarily or involuntarily disposed of or disposed of indirectly by transfer of control .of the Licensees to any persons, unless the Federal Communications Commission shall give prior consent in writing;

(6) Pursuant to Section 2 of the Cable Landing License Act, 47 U.S.C. § 35; Executive Order No. 10530, as amended; and Section 214 of the Communications Act of 1934, as amended, 47 U.S.C. § 214, the Commission reserves the right to impose additional common carrier or common-carrier-like regulation on the operations of the cable system if it finds that the public interest so requires;

(7) The Commission reserves the right to require the Licensees to file an environmental assessment or environmental impact statement should it determine that the landing of the cable at those locations and consttuction of necessary cable landing stations would significantly affect the environment within the meaning of Section 1.1307 of the Commission's procedures implementing the National Environmental Policy Act of 1969; this license is subject to modification by the Commission upon its review of any environmental assessment or environmental impact statement that it may require pursuant to its rules;

(8) The Licensees shall maintain dejure and defacto control of the U.S. portion of the cable system, including the cable landing stations in the United States, sufficient to comply with the requirements of this license;

- (9) This license is revocable by the Commission after due notice and opportunity for hearing pursuant to section 2 of "An Act Relating to the Landing and Operation of Submarine Cables

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in the United States," 47 U.S.C. § 35, or for failure to comply with the terms of the authorizations;

(10) The Licensees shall notify the Commission in writing of the date on which the cable is placed in service, and this license shall expire 25 years from such date, unless renewed or extended upon proper application, and, upon expiration of this license, all rights granted under it shall be terminated; and

(11) The terms and conditions upon which this license is given shall be accepted by the Licensees by filing a letter with the Secretary, Federal Communications Commission, Washington, D.C. 20554, within 30 days of the release of the cable landing license.

26. This Order is issued under Section 0.261 of the Commission's rules, 47 C.F.R. § 0.261, and is effective upon adoption. Petitions for reconsideration under Section 1.106 or applications for review under Section 1.115 of the Commission's rules, 4 7 C.F .R. §§ 1.106, 1.115, may be filed within 30 days of the date of public notice of this order (see 47 C.F.R. § 1.4(b)(2)).

FEDERAL COMMUNICATIONS COMMISSION

Diane J. Cornell Chief, Telecommunications Division International Bureau

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