STATEMENT OF COMMISSIONER MICHAEL O’RIELLY Re: Section 43.62 Reporting Requirements for U.S. Providers of International Services, IB Docket No. 17-55; 2016 Biennial Review of Telecommunications Regulations, IB Docket No. 16-131, Report and Order. The item before us takes small but significant steps to reduce unnecessary data collection and reporting requirements for those providers of international services. In the first instance, the annual Traffic and Revenue Reports have long lived past their usefulness, and we eliminate the requirement completely. To put it in perspective, the time needed to collect and submit the requisite data by one industry participant was estimated at 790 hours per year and even the Commission’s own estimate of total industry cost was upwards of $1.3 million annually, which is unrealistically low. Further, the item makes clear that the Commission could obtain more accurate and comprehensive data on the international communications marketplace from commercial sources. In sum, eliminating this reporting requirement saves time and money previously spent by providers for information that, in fact, provided an incomplete picture of the international services marketplace. Sign me up. The item also streamlines the annual Circuit Capacity Reports pertaining to undersea cables. While I previously supported eliminating this reporting requirement completely, U.S. national security agencies have made a public request that it be retained given its informative qualities. Specifically, the Department of Homeland Security, on behalf of itself and other federal agencies, writes that the data collected is used “to protect and preserve national security and for emergency response purposes. The resulting analysis is also relied upon in the classified setting to influence key national security decision- making.” 1 Although I question whether this is the best mechanism to facilitate the collection of that information, I will give our national security experts due deference on their request. Since we are not prepared to eliminate the reporting requirement, I do appreciate that the item trims and streamlines the data collection process to reduce overall burdens on affected parties. I thank the Chairman and staff for making a number of edits to the text on my behalf. 1 Letter from Emily Early, Director (Acting), DHS NPPD Strategy, Policy, and Plans, Office of Cyber and Infrastructure Analysis, National Protection and Program Directorate, DHS, to Marlene Dortch, Secretary, FCC (Sept. 21, 2017).