Reminder: Quarterly International Reports Due September 30, 2013
Kelley Drye Client Advisory
September 12, 2013

Please be reminded of the upcoming due dates for the Reports listed below:

Quarterly Section 63.10(c)(2) International Traffic and Revenue Report

All foreign-affiliated carriers, including both resellers and facilities-based carriers, that are classified as dominant must file a quarterly report detailing traffic and revenue data for each service provided on those routes on which the carrier is classified as dominant.  The information must be divided among service billed in the United States, service billed outside the United States, and service transiting the United States and cover the calendar quarter period of April 1, 2013 through June 30, 2013.  The report must be filed with the FCC by September 30, 2013.

Note: The Commission now requires carriers to combine traffic data for off-shore U.S. points with the data for domestic U.S. points.  As a result, carriers should only be reporting traffic between the United States and foreign points.  The off-shore U.S. points are as follows: Alaska, Guam, Hawaii, Puerto Rico, U.S. Virgin Islands, American Samoa, Baker Island, Howland Island, Jarvis Island, Johnston Atoll, Kingman Reef, Midway Atoll, Navassa Island, Northern Mariana Islands (includes Rota, Saipan and Tinian), Palmyra Atoll and Wake Island.

Quarterly Section 63.10(c)(3) Quality of Service Report

Foreign-affiliated carriers that are classified as dominant must provide information regarding the provisioning and maintenance of all basic network facilities and services procured from its foreign carrier affiliate for those routes on which the carrier is classified as dominant.   These reports should contain the following: "the types of circuits and services provided; the average time intervals between order and delivery; the number of outages and intervals between fault report and service restoration; and for circuits used to provide international switched service, the percentage of ''peak hour'' calls that failed to complete." The report for the calendar quarter of April 1, 2013 through June 30, 2013 must be filed with the FCC by September 30, 2013.

Quarterly Section 63.10(c)(4) International Circuit Status Report

Foreign-affiliated, facilities-based carriers, that are classified as dominant, must file a report on the status of all circuits used to provide international service on those routes on which the carrier is classified as dominant.  Information regarding activated or idle circuits must be reported on a facility-by-facility basis.  FCC staff requests carriers filing circuit data reports identify the transmission facilities used, i.e., U.S. - United Kingdom cable system, etc. for each route on which the carrier is dominant and identify the number of channels or circuits for each system if more than one system is used. The report for the calendar quarter of April 1, 2013 through June 30, 2013 must be filed with the FCC by September 30, 2013.

Note: The Commission now requires carriers to combine the circuit data for off-shore U.S. points with the data for domestic U.S. points.  As a result, carriers should only be reporting circuits between the United States and foreign points.  The off-shore U.S. points are identified above under the discussion of the Traffic and Revenue Report.

Please be advised that attorneys in Kelley Drye & Warren's Communications practice group are experienced in addressing international reporting issues and are able to assist clients in filing the international carrier reports.

For further information on any of these filings, please contact Robert Aamoth at (202) 342-8620, Denise Smith at (202) 342-8614 or your usual Kelley Drye attorney.