BILL POSCY 6r11 DISTRICT, rLOniOA COMl.lll r(ES: SCIENCE, SPACE, ANO TECHNOLOGY Sr ACE Suoco"11.111 1 CE OvrASIGUT Suoco~.1M1TT£E flNANCIAL SERVICES fuJANCIAL INSTITUTIO:Js Suoco:.1\11TTEE MONETARY POLICY ANO TRADE SUBCOMMITTEE ffinugrc1u1 uf tl1c llhtUeh .§htfcs iijumu~ i1f 1lh~µrc.ucttfutiuc1; lUnul1iugt11u, DQ! 211515 l.1H10EAOF: llOUSE AEROSPACE CAUCUS AErUOLICAIJ STUDY COW.llTIEE cmlGRESSIONAL AUTISM CAUCUS l.llLITARY VETEAAllS CAUCUS Chairman Aj it Pai Commissioner Mignon Clyburn Commissioner Michael O'Riell y Commissioner Jessica Rosenworcel Commissioner Brendan Carr Federal Conununicat ions Commission 445 12th Street SW Washington, DC 20554 August 9, 20 17 \'tww.poscy. llouse.gov \'IASIUNGTO~" OFFICE: 120 CAtmo:i House OrncE Bu1LD1t1G WASHINGTO'I, DC 205 15 (202) 225 -367 1 FAX: 1202) 225-3516 f.\AIN DISTRICT OFFICE: 2725 JUDGE FRAU JA1.,•Esm1 WAY, BLOG. c MELBOURNE, Fl 32940 132 1) 632-1776 FAX: 1321) 639-8595 DISTRICT OFFICE: 1tm1A11 R1vrn Coumv Am.11.,_ Bwa. A (772) 221>-170 1 DISTRICT OFFICE: ORlVAno Cournv GovEANMErff On1cEs IN T ITUSVILLE (321) 383 6090 RE: ill Docket No. 98-96 - 1998 Dicnuinl Regulatory Review - Review of Accounts of Settlement in the M nritimc Mobile nucl Mnritime-Sntcllitc Rndio Services nnd Withclrnwnl of the Commission ns nn Accounting Authority in the Mnritimc Mobile nnd Mnritime-Sntellitc Radio Services ("2016 Acco1111ti11g Authority Secoud FNPRM>') Dear Chairman Pai and FCC Commissioners: I am pleased to see that the current Commission is making a concerted effort to close long-pending proceedings that have languished over the years. Addressing and closing these proceedings is essential to bringi ng certainty to vital sectors of the economy, which will, in turn, encourage i1movation and stimulate the economy. Similarly, l applaud your efforts to usher in a new era of transparency and ope1mess at the Conunission. T hese initiatives are in the best interests of industry pm1icipants and taxpayers alike. l have been alerted to recent action by the FCC in a long-standing docket addressing the Commission's role as the accounting authority of last resort. 1 This proceeding is of particular interest to me given the important mari time safety issues pursuant to the FCC's determination to cease operating as the default accounting authority. I have had the oppot1unity to review the Commission 's December 2016 Second Notice of Proposed Rulemaking, as well as the comments submitted in the docket. I am encouraged that the Commission is re-visiting this issue, and I am in agreement with the Commission 's decision to exit this role as l believe that these functions are more properly fi lled by the private sector, rather than by a government agency. However, I do remain concerned regarding the adequacy of the Commission's transition plans and share concerns raised by the U.S. Coast Guard. Based on my understanding of the issue, relying solely on an outreach effort to migrate all current users to a new accounting authority has many downsides. Over-dependence on outreach efforts will likely further 1 1998 B ie1mia l Regulatmy Review - Review of Accounts Settlement in the Maritime Mobile and Maritime Mobile-Satellite Radio Services and Withdrawal of the Commission as an Accounting Authori ty in the Maritime Mobile and Ma ri time Mobile-Satellite Radio Services, Second Further Notice o.f Proposed R11le111aki11g, 31 FCC Red 13785 (2016) (Second Further Notice). PRINTED ON RECYCLCO PAPER 657 delay the Commission' s long-stated desire to exit the role of accounting authority of last resort, and it would require unnecessary expenditure of Conunission resources and taxpayer dollars. An outreach effort to reach a majority of users would need to be robust, coordinated, overly complex, and extremely labor intensive. Furthermore, the Coast Guard noted that there is no guarantee of success. In sho11, regardless of the cost or expansiveness of any outreach effort, there are concerns that not all users will take the necessary proactive steps to register with a new accounting authority once the Conunission exits that role. Should maritime users not receive the notice or fail to act on it, the Commission's plan could pose real and substantial sa fety risks. Users who either do not have access to or simply ignore the Commission's outreach efforts will lose access to li fe-sav ing conurnmications services. This puts ocean-going vessels in danger and imposes an unreasonable additional burden on the Coast Guard. Rather than relying on a cumbersome, protracted process with serious questions of universal success, has the Commission considered simply assigning its USOl designation to COMSAT, INC., the ouly party ou the record that has expressed the willingness and documented ability to serve as the replacement default accounting authority? It would seem to be that this would be the obvisous and less burdensome solution. My understanding is that while there have been multiple opportunities for other private entities to come forward and volunteer to fill the gap left by the Conunission's departure from serving as the authority of last resort, COMSAT is the only one that volunteered to assume the role of default accounting authority. As I am sure you will agree, it is of the utmost Importance that we ensure the continuity of lifesaving maritime conununications by maintaining this critical service. COMSAT has more than a fifty-year history in the industry of satellite conununications. As I understand it, COMSAT currently serves as an accounting authority under the designation USI 1, and the U.S. Coast Guard has recognized its capability of assuming the role of de fault accounting authority. As you know, assigning the role of accounting authority to COMSAT would in no way obligate any party to use the organization as their accounting authority. Instead, COMSAT would stand by to fill the role should a user fail to affirmatively choose to appoint an accounting authority. Given the location and demographics of my district , issues of maritime safety are of a paramount concern to my constituents and to me. The Conunission is presented with an opportunity to avoid u1mecessary red tape, save taxpayer dollars, and ensure the continuity of lifesaving maritime conununications services. Based on the above, please give foll and fair consideration to COMSAT's request to take on the Commission's role of default accounting authority. Thank you for your time on this matter, and I look forward to any feedback you can provide on this alternative. Cc: Rachael Bender Erin McGrath Dana Shaff er