OMB Control Number 
3060-1116
OMB Expiration Date October 31, 2008[[1]]
This message is a follow up to emails sent by the 
FCC in April[[2]] seeking cooperation of submarine cable 
operators in voluntarily providing information related to FCC-licensed submarine 
cable(s).  Based upon input provided 
by operators[[3]], we hereby clarify our voluntary 
information request.
We request that each operator advise the FCC 
no later than June 2, 2008, whether it voluntarily commits to providing the 
information requested in our earlier request as clarified in this email.  Each operator should indicate the date 
by which it can implement item (1) below and the date by which it can provide to 
the FCC the information described in items (2), (3) and (4) 
below.
Each operator may respond to the FCC 
separately from this email chain.
As stated in our earlier emails, we seek 
this voluntary cooperation, consistent with our authority and responsibilities 
under the Cable Landing License Act, 47 U.S.C. § 34 et seq., the Communications 
Act of 1934, as amended, 47 U.S.C. §§ 151, 154(i), 303(r) and 403, and Executive 
Order 10530 §5(a) (May 10, 1954), reprinted as amended in 3 U.S.C. § 301.  This information is needed in order to 
support Federal Government national security and emergency preparedness 
communications programs, for the purposes of providing situational awareness of 
submarine cable system performance as well as a greater understanding of 
potential physical threats to the cable system.  We recognize that the information 
requested is sensitive, for national security and/or commercial reasons, and as 
explained below we presumptively will treat it as confidential upon 
submission.  
We clarify the earlier request as set forth 
below.  In doing so, we emphasize 
that we are not asking for a voluntary commitment to provide information not 
already generated in the operation of the cable systems or in the possession of 
the operator.   
Format, content, 
thresholds, frequency, and timeliness:  We recognize that 
operator-generated information covering system status and restoration 
data in item (1) below (and all subparts) varies widely in format, content, 
threshold, and volume.  Some may not generate all fields of data. 
 Some may have a low threshold for generating a report and others may have 
a higher threshold.  Whatever the case may be, our view is that if the 
company feels it is important enough that it generates the information for 
itself or for another owner/operator, then that threshold is acceptable.  Because of these great differences, and 
to minimize the burden on licensees, we do not request that a formal report be 
produced. At the same time, we recognize that operators will need to apply 
discretion in determining what is the appropriate data for sharing with the 
Federal Government.  Original information suffices and is actually 
preferred at the time of its generation with full recognition that such 
information is, like all developing information, subject to change as a given 
situation is clarified.  
Specifically, we ask that each operator 
voluntarily commit to providing the following information, if it is information 
the operator already generates, with respect to its cable system(s).  If an operator is not already generating 
data related to a particular field identified below, then it should simply 
indicate in its reply that such data for that field is not available.   
(1)               System status and restoration:  We understand that every owner/operator 
of a submarine cable generates and receives varying forms of email and other 
data or documents related to the technical performance of its system and 
developments that may have an impact on its operation or security.  This information, which provides 
owner/operators with situational awareness on an ongoing basis for their 
submarine cables includes, but is not limited to, email messages, frequently 
referred to as "international restoration" messages (for consortia systems), 
“trouble tickets,” and so forth. While we recognize that the form and content of 
such communications can vary widely depending on the company producing them, the 
arrangements which generate them, and the reasons for which they are being 
produced, we desire the following fields of data for systems landing on U.S. 
sovereign soil (to the extent they are generated in the normal course of 
business):
            
1.   Indications of potential problems 
(alarms, safety and security concerns, changes in latency, fiber degradation and 
any other concerns you may have); 
            
2.   Potential 
traffic-impacting/hazardous conditions/impairments (electrical and optical 
faults such as shunt and power conductor faults, fiber break, undersea and 
terrestrial component failures, terminal equipment failures, card failures, 
circuit pack problems, faulty switches, planned maintenance or construction, 
other maritime hazards);
            
3.   Impact information 
(affected facilities as well as outage and return to normalization 
times);
            
4.   Restoration 
activity (ring switches, auto span switches, facility restoration status 
pursuant to approved restoration plans); 
            
5.   Repair activity 
(fault localization, repair plans, progress, vessel activity, power 
reconfiguration);
            
6.   Periods of test 
activity - Optical time domain reflectometry (OTDR), coherent OTDR (COTDR), and 
other technical measurement activity for fault localization; link tests; 
terminal equipment tests (we do not request the actual test 
measurements);
            
7.   
Event/activity/message date/time – the information is to be provided when 
generated in the normal course of business as part of commercial communications 
processes; and 
            
8.   Addressees – Email 
addresses for any foreign owner/operators also receiving the information at the 
time of generation are also requested.  
Email addresses for specific individuals are not requested but are an 
acceptable substitute if they identify companies receiving the email. 
  
(3)             
Undersea Location 
Spreadsheet:  We request that each operator 
provide after-installation information in the form of an electronic spreadsheet 
of its associated route position list (RPL).  Please detail the position of all system 
components – including repeaters, joints, branching units, repair splices, 
burial positions, burial depth and whether the cable is armored or 
unarmored.   We request 
that the operator report annually to update this information if there any 
changes to the routing.
(4)             
Restoration 
Capability:  We request that each operator 
provide information on its submarine cable system restoration capability 
(internal and external).  Please 
indicate whether the system has a Universal Restoration Manual, what type of 
catastrophic restoration plans (or similar plans for extreme circumstances) are 
in place and which other cable systems might be used for restoration.  We request that the operator 
provide a copy of any existing Restoration Manual, and report annually to update 
this information. 
Data Provision 
Mechanisms:  To simplify operators’ 
voluntary compliance with this request, we will allow them to provide the 
information using alternative methods as shown below.  For system status and restoration 
data, operators will be able to provide information using either a document 
management system established by the FCC (which will provide authentication 
processes) or carbon copies to a designated FCC email address.  For cable mapping and restoration 
capability data, operators will be able to provide information to the FCC 
using either computer-readable media such as CDs or DVDs or paper copies.  We request that, in your responses to 
this email, you elect which of these methods you will use to provide us the 
information.  The FCC point of 
contact for the information collection will be 
As mentioned above, and as stated in our 
earlier emails, we recognize that the information requested is sensitive for 
national security and/or commercial reasons.  Information provided pursuant to this 
request will be viewed as presumptively confidential upon submission because the 
submissions would reflect voluntary reports on weaknesses in or damage to 
national communications infrastructure, and the release of this sensitive 
information to the public could potentially facilitate terrorist targeting of 
critical infrastructure and key resources.  
The submissions also may contain internal confidential information that 
constitutes trade secrets and commercial/financial information that the 
operator does not routinely make public and public release of the submitted 
information could cause competitive harm by revealing information about the 
types and deployment of cable equipment and the traffic that flows across the 
system.  For these reasons, the 
information requested in (2) and (3) above is  presumptively exempt from public 
disclosure under Freedom of Information Act (FOIA) Exemption 3, 5 U.S.C. § 
552(b)(3), and section 4(j) of the Communications Act of 1934, as amended, 47 
U.S.C. § 154(j), as implemented in 47 C.F.R. § 0.457(c)(1)(i) (exempting 
disclosure of “maps showing the exact location of submarine cables”).  The information requested in (1) and (4) 
above will be considered exempt under Exemption 4 of the FOIA, 5 U.S.C. § 
552(b)(4).  If a FOIA request is 
filed for information submitted in response to this request, you will be 
notified of the FOIA request and given the opportunity to oppose release of the 
records.  See 47 C.F.R. § 
0.461(d)(3).  We note that the 
information provided in response to this request will be shared with the 
Department of Homeland Security’s National Communications System (NCS) and 
relevant Executive Branch agencies on a confidential basis.  See 44 U.S.C. § 
3510.
PAPERWORK REDUCTION ACT 
STATEMENT
We have estimated that 
each response to this collection of information will take an average of 550 
hours.  Our estimate includes the 
time to read the instructions, look through existing records, gather and 
maintain required data, and actually complete and review the form or 
response.  If you have any comments 
on this estimate, or on how we can improve the collection and reduce the burden 
it causes you, please write the Federal Communications Commission, Office of 
Managing Director, AMD‑PERM, Washington, DC 20554, Paperwork Reduction Act 
Project (3060‑1116).   We will 
also accept your comments via the Internet if you send an e-mail to [email protected]. 
Please DO NOT 
SEND COMPLETED DATA TO THIS ADDRESS.   
You are not required to respond to a collection of information sponsored 
by the Federal government, and the government may not conduct or sponsor this 
collection, unless it displays a currently valid OMB control number and/or we 
fail to provide you with this notice.  
This collection has been assigned an OMB control number of 
3060‑1116.
THIS NOTICE IS 
REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104-13, OCTOBER 1, 
1995, 44 U.S.C. SECTION 3507.