By Wiltshire & Grannis
Wiltshire and Grannis has published a regulatory advisory explaining the potential impact on international undersea cable operators and satellite operators of the FCC's just-released notice of proposed rulemaking (“NPRM”) regarding reform of annual regulatory fees. Among other proposals, the NPRM proposes an extraordinary 332-percent increase in these fees for providers licensed by the FCC's International Bureau, particularly international undersea cable systems and geostationary satellites. Note that this proceeding is separate from the FCC's pending proceedings to (1) eliminate the international-only and limited-interstate-revenues exemptions relied on by those same operators with respect to contribution obligations for the federal Universal Service Fund, and (2) establish regulatory fees for Fiscal Year 2012 (payable in September 2012).