Attachment STA Request

This document pretains to ITC-STA-20181114-00209 for Special Temporal Authority on a International Telecommunications filing.

IBFS_ITCSTA2018111400209_1572686

                          Request for Special Temporary Authority

        Pursuant to Section 214 of the Communications Act of 1934, as amended (the “Act”),
Spectrotel, Inc. (“Spectrotel”) requests Special Temporary Authority (“STA”) to allow Spectrotel
to continue providing global resold international basic switched, private line and data services,
pending Commission approval of Spectrotel’s Joint Domestic and International Section 214
Application and Request for Waivers (“Joint Application”) filed on September 25, 2018.
Spectrotel incorporates by reference the information required by Section 63.18 provided in the
Joint Application. See IBFS File No. ITC-T/C-20180925-00178.

        Spectrotel recently became aware of the need to provide notice to the Commission of a
voluntary petition for bankruptcy relief filed on March 16, 2001, and to seek Commission
consent for a transfer of control that occurred in connection with the reorganization upon
emergence from bankruptcy, which was completed on November 25, 2002. As a result of
inappropriate guidance from counsel at the time of the 2001-02 reorganization, Spectrotel
management was only recently made aware of the required notice and application in connection
with its common carrier authorizations. Spectrotel filed the Joint Application to rectify the
inadvertent oversight. Spectrotel seeks waivers of the rules as needed to allow the Joint
Application to be filed outside of the required timeframe for such application.

        While the Joint Application remains pending, Spectrotel requests a grant of STA to allow
it to continue serving its customers under its current ownership and without interruption. Grant
of the instant STA will serve the public interest, convenience, and necessity because it will
permit the continued provision of service to Spectrotel’s customers who rely on Spectrotel for
telecommunications and other voice and data services. Allowing Spectrotel to continue
providing its regulated services also would ensure the existence of a competitive provider in the
marketplace. As detailed in the Joint Application, the reorganization transaction that allowed
Spectrotel to emerge from bankruptcy enabled the company to continue serving customers and to
introduce new and innovative services going forward. Therefore, the grant of STA and the Joint
Application would serve the public interest.

       Spectrotel acknowledges that grant of the requested STA will not prejudice any action the
Commission may take on the Joint Application, and that, once granted, the STA may be revoked
on the Commission’s own motion without hearing. Spectrotel further acknowledges that grant of
an STA and the Joint Application will not preclude enforcement action.

       For the foregoing reasons, Spectrotel respectfully requests that the Commission grant the
requested STA to allow Spectrotel to continue to provide service under its current ownership.



Document Created: 2018-11-14 13:37:12
Document Modified: 2018-11-14 13:37:12

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