Attachment ATT STA Request Colu

This document pretains to SCL-STA-20190823-00027 for Special Temporal Authority on a Submarine Cable Landing filing.

IBFS_SCLSTA2019082300027_1864829

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of ) ) The Columbus II Submarine Cable System ) File No. SCL-LIC-19921110-00004 Operating Between the United States ) Mainland and St. Thomas in the U.S. Virgin ) Islands ) APPLICATION FOR SPECIAL TEMPORARY AUTHORITY On behalf of the licensees of the Columbus-2 submarine cable system,1 SCL-LIC- 19921110-00004, AT&T Corp. (“AT&T”), pursuant to 47 U.S.C. §§ 34-39, Executive Order 10,530, and 47 C.F.R. § 1.767, hereby requests that the Commission grant Special Temporary Authority (“STA”) to allow the continued operation of the Columbus-2 cable following the expiration of the existing cable landing license on October 1, 2019, while the Commission considers the application for a new cable landing license for this cable filed on March 27, 2019.2 AT&T acknowledges, on behalf of the licensees, that the grant of this STA will not prejudice any action the Commission may take on the application for a new cable landing license, and that this STA can be modified or revoked by the Commission upon its own motion without a hearing. AT&T also acknowledges on behalf of the licenses that such continued operation of the cable would remain subject to the conditions set forth in the cable landing license released on July 13, 1993. 1 The licensees include: AT&T Corp. and Telefonica Larga Distancia De Puerto Rico, Inc. 2 See Application For Cable Landing License, File No. SCL-LIC-20190326-00010, filed March 27, 2019. See also, Public Notice, SCL-00242S, May 22, 2019. The application is currently under review by the “Team Telecom” Executive Branch agencies. As noted in the application, only the domestic segment of Columbus-2 linking the U.S. Mainland and St. Thomas in the Virgin Islands are now in operation. The application and this request for the grant of Special Temporary Authority request the continued operation of this domestic segment.

-2- AT&T submits that the continued operation of the Columbus-2 cable is overwhelmingly in the public interest in helping to meet the demand for voice, data and internet services on routes between the U.S. mainland and the U.S. Virgin Islands, and connecting to other cables extending to various Caribbean islands, and Central and South America, and that it would not serve the public interest to cease operation of this cable, even on a temporary basis. The cable has been operated successfully for 25 years, has a current design capacity of 800 Gbps per second, and the United States terminal points currently operate at up to 600 Gbps. Maintaining reliable communications facilities serving the U.S. Virgin Islands is particularly important following the “massive damage” to these islands caused by Hurricane Maria.3 As the U.S. Virgin Islands continues to work to overcome these major challenges, it is even more critical to avoid any diminution in the communications facilities that link consumers in this territory with the rest of the world. AT&T therefore requests the grant of this request. Respectfully submitted, AT&T Corp. Of Counsel: ________________________ James Talbot Mark D. Schneider AVP- Senior Legal Counsel Sidley Austin LLP AT&T Services, Inc. & 1501 K Street, NW Assistant Secretary Washington, DC 20005 AT&T Corp. (202) 736-8058 Suite 1000 mschneider@sidley.com 1120 20th Street, N.W. Washington, D.C. 20036 3 Connect America Fund, WC Docket No. 10-90, Order, 2017 WL 4479977, rel. Oct 4, 2017, ¶ 1. See also, The Uniendo a Puerto Rico Fund and the Connect USVI Fund, Order and Notice of Proposed Rulemaking, WC Docket No. 18-143, rel. May 29, 2018 (approving additional funding to restore communications networks in Puerto Rico and the Virgin Islands and seeking comment on almost $900 million in long-term funding for network expansion).

-3- (202) 457-3048 jjtalbot@att.com Dated: August 23, 2019

-4- CERTIFICATE OF SERVICE I hereby certify that the foregoing application was served on the following by first-class mail on August 23, 2019: U.S. Coordinator, EB/CIP U.S. Department of State 2201 C Street, NW Washington, DC 20520-5818 Office of Chief Counsel/NTIA U.S. Department of Commerce 1401 Constitution Ave., N.W. Washington, DC 20230 Defense Information Systems Agency ATTN: GC/DOI 6910 Cooper Avenue Fort Meade, MD 20755-7088


Document Created: 2019-08-23 16:52:28
Document Modified: 2019-08-23 16:52:28
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