Home / Insights and Advisories / Facilities-Based International Carriers Must File Route Lists with FCC by November 14, 2018
The Federal Communications Commission (“FCC”) recently released filing requirements for certain carriers holding international Section 214 authority, which requires that these carriers file and maintain international route lists as laid out in Section 63.22(h) of the FCC’s rules. The filings must be submitted no later than November 14, 2018. This filing requirement was adopted in 2017, as the FCC eliminated the requirement for annual traffic and revenue reporting. These lists will provide FCC the information needed for potential merger review and to monitor route competitiveness.
Who Must File
International facilities-based service providers who provide FCC international Section 214 facilities-based services must file and continuously update a list of all U.S.-international routes where they have direct termination arrangements with a foreign carrier.
However, the FCC does not require listing routes where the U.S. carrier has no arrangement with a carrier in the destination market, but instead provides service to that market via arrangements with a third party carrier in intermediate countries.
When to File
What to File
International Facilities-based service providers are required to include the following in their initial and updated lists:
How to File
Providers must file their route lists electronically, in PDF format, within the International Bureau Filing System (“IBFS”) Filing System. Step-by-step instructions for filing these lists can be found here. The FCC further encourages filers to email a courtesy copy of any route submissions to internationalroutelist@fcc.gov.
Confidentiality
The FCC stated that they will not treat international route list filings as available for public inspection. Filers can indicate they want confidential treatment through the IBFS filing system, and should further label each page of the list filing as containing commercial proprietary information exempt from public disclosure under the Freedom of Information Act and Section 0.459 of the FCC’s rules.
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