NTIA Comments on Submarine Cable Landing License NPRM

NTIA supports improving submarine cable security, but cautions the Commission to avoid duplicative licensing requirements that applicants or licensees already comply with via agreements with the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector.

NTIA agrees with the Commission’s statement that national security and law enforcement threat environments for communications networks have evolved significantly since the Commission last updated its rules and commends the Commission’s renewed focus and engagement to combat threats posed by foreign adversaries. Still, NTIA encourages the Commission to contemplate, as this proceeding seeks to do, the national security imperative that is the United States technology and telecommunications sector’s competitiveness with its foreign counterparts, particularly the People’s Republic of China (China). These comments seek to strike a balance between national security considerations and the broader economic implications of streamlining or reducing regulatory barriers.

The ability to predictably and efficiently lay submarine cables is foundational to secure the United States’ position as the unrivaled world leader in critical and emerging technologies, such as artificial intelligence and quantum information science. In the spirit of President Trump’s Executive Order “Reducing Anti-Competitive Regulatory Barriers,” NTIA encourages the Commission to reduce barriers to regulatory approvals, focus on enhanced coordination and improve existing processes with Executive Branch agencies and the Committee, and remain mindful that discouraging investment in the United States may lead to increased investment in our adversaries’ networks and technologies.