WASHINGTON, D.C. – April 15, 2025 – INCOMPAS, the internet and competitive networks association, filed comments on the Federal Communications Commission’s (FCC) Notice of Proposed Rulemaking that seeks input on how to improve and streamline the rules to facilitate efficient deployment of submarine cables while ensuring the security, resilience and protection of this critical infrastructure.
“Submarine cables form the backbone of our global digital economy, carrying over 95% of intercontinental global internet traffic, and 99% of transoceanic digital communications,” said Christopher L. Shipley, Executive Director of Public Policy at INCOMPAS. “Our recommendations aim to support the Commission’s dual objectives of enhancing national security while preventing unnecessary regulatory burdens that could impede infrastructure development.”
In its filing, INCOMPAS offered several recommendations that prioritize both national security and continued infrastructure investment:
- Enhanced Interagency Coordination: The FCC should coordinate with the Executive Branch, including Team Telecom agencies and the State Department, to ensure its regulatory decisions reflect comprehensive security assessments and mitigation strategies.
- Innovation-Focused Regulatory Framework: The proceeding should prioritize removing deployment barriers rather than introducing new regulatory hurdles that could delay critical infrastructure projects.
- Procedural Safeguards in Revocation Actions: Executive Branch involvement is required in all revocation proceedings to facilitate adequate due process protections, and affected parties should have an opportunity to preliminarily address concerns through meaningful mitigation measures.
- Appropriate Licensing Requirements: Refrain from requiring all capacity holders (such as data center owners) to obtain submarine cable landing licenses, as this would exceed the Commission’s statutory authority under the Cable Landing License Act.
- Protection of Sensitive Information: Avoid requiring disclosure of sensitive information in the application process, including precise submarine cable landing locations and future business plans, which could be unnecessary and potentially harmful.
“INCOMPAS stands ready to collaborate with the Commission on solutions that strengthen and streamline America’s submarine cable rules, while protecting national security interests,” added Shipley. “We look forward to working with the Commission on solutions, as it works to finalize its regulatory approach.”
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