Annual International Circuit Status Reports Due On April 2, 2012
Federal Communications Commission
445 12th St., S.W.
Fax-On-Demand 202 / 418-2830
Washington, D.C. 20554TTY 202 / 418-2555
March 6 , 2012
ANNUAL INTERNATIONAL CIRCUIT STATUS REPORTS DUE ON APRIL 2, 2012
Changes in the Reporting RequirementsSection 43.82 of the Commission’s rules requires each facilities-based carrier that provides
international telecommunications services to file a Circuit Status Report by April 2, 2012.1 The reporting
requirements have changed since carriers filed their Circuits Status Reports last year.
All facilities-based carriers providing international telecommunications services must file a
Circuit Status Report if they had any activated or idle circuits as of December 31, 2011.2 The
information that must be reported, and the filing format for the Circuit Status Report, is set out in the
Circuit Status Filing Manual (Filing Manual).3 However, the Commission made changes to the reporting
requirements in the First Report and Order and Further Notice of Proposed Rulemaking in IB Docket
No. 04-112 that are not reflected in the current Filing Manual.4 Specifically, carriers are:
(1) no longer required to report circuits from off-shore U.S. points separately;5
(2) no longer required to report any circuits between the United States and offshore U.S. points;6
1 Section 43.82 of the Commission’s rules requires that the reports be filed by March 31 each year. 47 C.F.R. §
43.82. Since the March 31 falls on a Saturday this year, the filing date for this year’s report will be April 2.
Compliance with Section 43.82 is a specific condition of a carrier’s international Section 214 authorization. Failure
to comply with general or specific conditions of an authorization, or with other relevant Commission rules and
policies, could result in fines and forfeitures.
2 If a carrier did not have any activated or idle circuits as of December 31, 2011, it is not required to file a Circuit
Status Report and is not required to file a letter stating that it has no circuits to report.
3 Manual for Filing Section 43.82 Circuit Status Data in Accordance with the FCC’s Rules and Regulations, 10
FCC Rcd 8605 (1995) (“Filing Manual”). The filing manual is accessible on the FCC’s website at
4 See Reporting Requirements for U.S. Providers of International Telecommunications Services; Amendment of Part
43 of the Commissions Rules, IB Docket No. 04-112, First Report and Order and Further Notice of Proposed
Rulemaking, FCC 11-76, 26 FCC Rcd 7274, 7284, 7293-95, paras. 24-25, 51-55 (2011).
5 Id. at 7295, para. 55.
(3) no longer required to file a Circuit Addition Report.7
In filing their reports, carriers should now combine the circuit data for off-shore U.S. points with the data
for domestic U.S. points. Carriers thus should only report circuits between the United States and foreign
points.8 To the extent that a carrier is unable to implement these changes in time for filing its Circuit
Status Report this year, it may file a request for a waiver to continue reporting under the old requirements
for off-shore U.S. points for this reporting year.9
The Filing Manual requires carriers to report the total number of activated and the total number
of idle circuits using the following categories: submarine cable, satellite, and landline (cable or
The Filing Manual defines international facilities-based circuits as “international circuits in
which a carrier has an ownership interest. For this purpose, the term ownership interest includes outright
ownership, indefeasible right of use (IRU) interests, or leasehold interests in bare capacity in an
international facility, regardless of whether the underlying facility is a common or non-common carrier
submarine cable or…satellite system.”10 The Filing Manual further explains that leasehold interests in
bare capacity “are distinct from private lines leased from another reporting international carrier.”11 Thus,
any telecommunications carrier that has leased an international circuit from another common carrier, a
non-common carrier, or a foreign carrier, other than a lease of private line “service” or “capacity” from
a common carrier, must file a Circuit Status Report and include that circuit in its report. Such a circuit
should be reported as a facilities-based circuit, and not as a facilities-based resold circuit. Private line
resellers should report their resold circuits using the Facility Codes 11, 12 and 13 as specified in the
Facilities-based carriers that are regulated as dominant on particular U.S. international routes
under Section 63.10 must provide their circuit status information on a facility-specific basis for the
dominant route only.13 Carriers should provide the information in a separate appendix using the same
table format in the Filing Manual, but they should add a column labeled “Facility Name” after “Data
Carriers should file their reports on compact disc (CD) media. We will not accept reports filed
7 Id. at 7284, para. 25.
8 Id. at 7295, para. 55. See 47 C.F.R. § 43.82(a). The “United States” is defined as the “several States and
Territories, the District of Columbia, and the possessions of the United States, but does not include the Canal Zone.”
47 U.S.C. § 153(58).
9 Id. at 7295, n.123.
10 Filing Manual at 5.
12 See sample filing-template, Attachment 1.
13 47 CFR § 63.10 (c)(5).
We will accept Excel files. Attachment 1 contains a sample filing-template in Excel with brief
For ease of reference, Attachment 2 contains a list of the International Point country codes
carriers can use in filing their circuit reports.
The detailed Filing Manual, along with other instructions that are needed to fulfill this filing
requirement, can be found on the FCC website at http://transition.fcc.gov/ib/pd/pf/csmanual.html. The
Filing Manual is also available through the Commission's contractor for public service records
duplication: Best Copy and Printing, Inc. Portals II, 445 12th Street S.W., Room CY-B402, Washington,
D.C. 20554, telephone (800)-378-3160.
Carriers must submit two (2) copies of their transmittal letter and report, and one set of data, in
CD form, to Chief, Policy Division, International Bureau. Carriers must file their original transmittal
letter and the report with Marlene Dortch, FCC Secretary. The detailed filing addresses can be found on
the FCC Office of the Secretary home page at http://transition.fcc.gov/osec/. In addition, carriers should
file a complete set of their submission, i.e., copies of transmittal letter and report, with the Commission’s
contractor, Best Copy and Printing, Inc. (same mailing address as above).
For further information contact Cathy Hsu of the Policy Division, International Bureau, at (202)
418-2114, email: Cathy.Hsu@fcc.gov.
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