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AT&T's market share was one of the factors the Commission based its  {Ov-decision on in the AT&T Order.(#`   X-x` `  b.Supply Elasticity  X_-x30.` ` Two factors determine supply elasticity in a market. One is if existing competitors have or can relatively easily acquire significant additional capacity, then supply elasticities tend to be high. The other factor is low barriers to entry. Barriers to entry may  X -be legal (e.g., governmental imposed restrictions), economic (e.g., capital costs, economies of  X -scale) or technological (e.g., a new innovation protected by a patent).? h OR<ԍ` ` #W*f9 xr G;0X#See International Competitive Carrier#X\  P6G; P#  31.(#` Ƶ Even if existing competitors lack excess capacity, supply elasticity tends to be high if new suppliers can enter  X -the market relatively easily.@ <h O<ԍ` ` #W*f9 xr G;0X#See AT&T Order#X\  P6G; P#  48.(#` ƞ  X -x31.` ` The record indicates that Comsat's competitors have excess capacity available to offer fulltime video services to Comsat's current customers if Comsat raised its prices. Based on data in the 1996 Brattle Report, the unutilized 27/36 MHz transponder capacity for PanAmSat, Orion and Columbia, Comsat's competitors in this market, on transatlantic and transpacific routes increased significantly from 1993 to 1996. Moreover, the 1996 Brattle Report projects that in 1996 Comsat's competitors will have more idle 27/36 MHz transponder capacity on their transatlantic and transpacific routes than Comsat will be utilizing to provide fulltime and occasionaluse video service to its customers. For example, in 1996, Comsat's competitors were projected to have approximately 90 unutilized transponders available on these routes, while Comsat was projected to be utilizing approximately 70  X-transponders for fulltime and occasionaluse video services.Ah OR!<ԍ` ` #W*f9 xr G;0X#See#X\  P6G; P# 1996 Brattle Report at 24.(#` ƥ Neither PanAmSat, Hughes nor the Networks contested this market data. This idle capacity provides Comsat's competitors with enough capacity to serve all of Comsat's customers should they choose to migrate away from Comsat because of a Comsat price increase. We also think it is relevant that PanAmSat through its PAS4 satellite has the capacity to provide fulltime video service directly to the Indian Ocean region from the United States, whereas Comsat is unable to provide direct full"R| A0*''@@"ԫtime video service to that region without using multiple satellites and, presumably, charging a higher price. Although not all of the idle capacity of Comsat's competitors will be utilized for fulltime video services, this idle capacity indicates that supply elasticity is high in the fulltime video services market.  X-x32.` ` Legal barriers to entry in many countries make it difficult for a United States satellite service provider to begin providing services in the fulltime video services market. Historically, the most significant entry barrier in international telecommunications has been obtaining an operating agreement with the monopoly telecommunications service provider  X1-before providing service to a particular country.B1h O <ԍ` ` #W*f9 xr G;0X#See International Competitive Carrier #X\  P6G; P# 33.(#` Ƶ In the case of United States satellite service providers, a significant legal barrier to entry continues to be authorization to provide service in a particular country, including the authority to transmit and receive from an earth station within a country (sometimes referred to as landing rights). Thus, a United States satellite service provider seeking to provide fulltime video service in a country must first obtain authorization from that country. The Networks state that they have become less reliant on INTELSAT for fulltime video services, especially over dense routes, because these routes  X-have become subject to more effective competition since 1994.Chh O<ԍ` ` #W*f9 xr G;0X#See#X\  P6G; P# Comments of Networks at 89.(#` Ƨ Moreover, we note that under the World Trade Organization's ("WTO") Basic Telecommunications Services Agreement (the "WTO Agreement") concluded earlier this year, 49 WTO member countries, including most countries that constitute origination and termination points in the fulltime video service market, have committed to offering market access for satellite service and facilities in their countries. Thus, the legal barriers in the fulltime video service market do not appear significant and as the commitments made under the WTO Agreement are implemented in 1998 and beyond, we are hopeful that the WTO member countries where it remains difficult to obtain the required authorizations will over time be replaced with more open markets.  X-x33.` ` In addition, economic and technological barriers to entry also can make it difficult for another satellite service provider to enter the fulltime video service market. A new entrant would require a substantial capital investment in constructing, launching and operating additional satellites to achieve the global coverage required to provide fulltime  X7-video service.D7h O!<ԍ` ` #X\  P6G; P#It has been our experience that it takes an average of two years to construct and launch a satellite at a cost of approximately $80 to $200 million. (#` Fiberoptic cable is an alternative technology for the international transmission of video signals. However, fiberoptic cables are not a costefficient means to  X -transmit video at this point and do not interconnect with all geographic markets.E ph O*&<ԍ` ` #W*f9 xr G;0X#See #X\  P6G; P#GAO Report at 38.(#` Ɯ The 1996" E0*''@@[" Brattle Report suggests that fiberoptic cable will become a viable means for transmitting video in the future, however, the record identifies only one such pointtopoint fiberoptic  X-video link currently in existence: between the United States and the United Kingdom.Fh OK<ԍ` ` #X\  P6G; P#See 1996 Brattle Report at 1011.(#` Ƈ The small capacity and fixed location of this single fiberoptic link mitigates against its existence having any significant impact on the provision of fulltime video services. Nevertheless, several satellite companies, including PanAmSat, Columbia and Orion, have established themselves as effective competitors in the fulltime video services market. These companies have supplied additional capacity to the fulltime video services market notwithstanding the economic and technological barriers to entry that exist in this market.  #F   X -x` ` c. Cost Advantages  X -x34.` ` Hughes raises a concern that Comsat has the potential to crosssubsidize its international video transmission services with revenues from its core telephone business. Hughes offers no support in the record for its concern about the potential for crosssubsidization. Presumably, Hughes is concerned that Comsat will include in its switched voice and private line tariffs costs that are not related to the provision of these services.  Xy-However, as a common carrier, Comsat's rates must be just and reasonable,sGyhh O<ԍ` ` #]\  PC P#47 U.S.C.  201.(#` s and the Commission may conduct a hearing on its own initiative or upon receipt of a complaint to  XK-determine the lawfulness of Comsat's rates.HKh O<ԍ` ` #\*f9 xC0X#See#]\  PC P# 47 U.S.C.  204(a).(#` ơ In addition, the Commission in its August 1996  X6-Order found the switched voice and private line services market that Comsat's competes in to be substantially competitive, except for thin routes. Substantial competition in this service market should exert competitive pressure on Comsat's ability to increase its rates for switched voice and private line services. Consequently, we view it as unlikely that Comsat will be able to crosssubsidize its fulltime or occasionaluse video services with revenues from its satellite delivered public switched telephone network services or its private line services.  X-x` ` d. Size and Access to Resources  Xi-x35.` ` Another factor we considered in determining whether Comsat lacks market power in the fulltime video services market is whether or not Comsat enjoys special market power because of its size or access to resources. One of the reasons that PanAmSat opposes Comsat's streamlined tariff relief request is because Comsat's competitors do not yet match the size of INTELSAT in terms of number of satellites and transponder capacity. INTELSAT operates 24 satellites, holds 29 orbital locations and maintains 883 international transponders"H0*''@@<"  X-while PanAmSat utilizes only 128 international transponders.Ih Oy<ԍ` ` #W*f9 xr G;0X#See#X\  P6G; P# Comments of PanAmSat at 2.(#` ƥ Presumably, a smaller number of INTELSAT's transponders are actually available for international video transmission services because INTELSAT and Comsat also provides international telephone and other services. According to the 1996 Brattle Report, Comsat is also unable to provide direct uplinks to seven of INTELSAT's satellites that provide service to the Indian Ocean region. On the other hand, the 1996 Brattle Report indicates that PanAmSat operates four satellites currently and expects to have an additional four satellites operational by 1998. PanAmSat has received authority to construct, launch and operate PAS9 and has filed applications to construct, launch and operate PAS10, PAS11, PAS12 and PAS13. PanAmSat merged its operations with a Hughes affiliate to form an international satellite network that will enable PanAmSat to take advantage of at least three Hughes satellites capable of providing fulltime  X -video services from the United States.J2 hh O<ԍ` ` #]\  PC P#The Commission authorized the merger of PanAmSat's and Hughes's satellite fleets. See Hughes Communications, Inc. and Anselmo Group Voting Trust/PanAmSat Licensee Corp.,  {O-Order, FCC 97121 (Released April 4, 1997). The transaction was consummated on May 16, 1997.(#` ƈ These events will significantly expand PanAmSat's transponder capacity in the shortrun and create opportunities for PanAmSat to increase its market share by crossselling international video transmission services to Hughes' existing customer base. When Orion's and Columbia's satellites are considered, in the shortrun, Comsat's competitors will have approximately 14 satellites operational compared to  X-INTELSAT's 24 satellites. Thus, Comsat has demonstrated that its competitors have increased the number of satellites and transponders being utilized to provide fulltime video  Xb-services than was evident from the record relied upon in the August 1996 Order.  X6-x36.` ` PanAmSat and Hughes also request that Comsat's Petition be denied because Comsat's status as a signatory to INTELSAT confers on Comsat special benefits that are difficult to measure in market power terms. PanAmSat and Hughes contend that Comsat's signatory status entitles it to special benefits including access to orbital locations, free of any one country's regulatory processes, operational advantages conferred upon INTELSAT's satellites by the Article XIV consultation process, privileges and immunities that insulate it from business risks and expenses that private companies face and financing options that are much more favorable than those available to private companies. As discussed above, we find that Comsat has demonstrated a diminution in INTELSAT's and Comsat's market power in  Xg-the fulltime video services marketKgbh Oz"<ԍ` ` #W*f9 xr G;0X#See#X\  P6G; P# # W*f9 xr G;0X#supra#X\  P6G; P#  2634.(#` since the close of the record relied upon in the August  XR-1996 Order. In International Competitive Carrier, the Commission found Comsat to be a dominant carrier possessing market power in the provision of television service because, at that time, Comsat was the only provider of television service. Today, PanAmSat, Orion, Columbia and other satellite carriers compete against INTELSAT and Comsat, and each other,"K0*''@@[" in the fulltime video services market. Increased competition in the international video  X-transmission services market since the International Competitive Carrier decision has resulted in a decline of Comsat's market share and market power in this service market. We agree that Comsat benefits from the special benefits that result from its status as a signatory to INTELSAT. These special benefits constitute a competitive advantage to Comsat and INTELSAT in a competitive market. However, they have not insulated Comsat from a diminution of its market power in the fulltime video services market. We are not persuaded that maintaining dominant tariffing requirements is a remedy to competitive harm that would  XJ-be directly attributable to these special benefits.LJh O <ԍ` ` #]\  PC P#We would reconsider our waiver if it is demonstrated that only dominant tariff regulation will protect against such competitive harm.(#` We note that in the August 1996 Order the Commission found that substantial competition existed in the international switched voice and private line telephone market, notwithstanding Comsat's special benefits. Here also, Comsat has demonstrated the existence of a sufficient level of competition in the fulltime video services market to merit the streamlined tariff relief sought by Comsat. However, our limited action here does not prejudge Commission consideration of these issues in the context of the Comsat NonDominant Proceeding in which Comsat is seeking broader regulatory relief as  X -discussed, supra, in footnote 7.  X-x37.` ` In light of the high demand and supply elasticities in the fulltime video services market, Comsat's limited ability to crosssubsidize fulltime video service rates and the improved satellite and transponder capabilities of Comsat's competitors, we conclude that substantial competition exists in the fulltime video services market. Therefore, good cause has been demonstrated for waiving our tariffing procedures and granting Comsat limited, streamlined tariff relief for its fulltime video services.  X- x  X-x2.` ` OccasionalUse Video Services  X-x38.` ` Unlike the fulltime video services market, we find that the occasionaluse video services market is not substantially competitive and, therefore, deny Comsat's request for streamlined tariff relief for rate increases for such services. However, as the Networks urge us, we grant Comsat's request for streamlined tariff relief for occasionaluse video rate reductions because it will result in lower rates, which is in the public interest.  X&-x39.` ` Comsat's submissions do not demonstrate that the occasionaluse video market is substantially competitive. In addition, PanAmSat and the Networks both commented that the international occasionaluse video services market is not yet competitive. The Networks, however, did not object to granting Comsat streamlined tariff relief for occasionaluse video service rate reductions. The 1996 Brattle Report and the record fails to separately detail Comsat's loss of customers, market share and pricing trend data attributable to the occasionaluse video service market. It is, therefore, difficult for us to address adequately the demand""0L0*''@@!" elasticity in this market. On the other hand, the 1996 Brattle Report and the commenters did provide some information that enables us to analyze the supply elasticity and characteristics of Comsat's size and resources that are evident in this submarket in order to determine if substantial competition exists.  Xv-x` ` a. Supply Elasticity  XH-x40.` ` First, we believe that this market lacks substantial competition because it is characterized by supply inelasticity. PanAmSat, the Networks and the GAO Report point out that Comsat's competitors have limited capacity to provide occasionaluse video services and  X -that users turn to INTELSAT for this type of service.M0 h O| <ԍ` ` #W*f9 xr G;0X#See#X\  P6G; P# Comments of PanAmSat at 4; Comments of Networks at 15. # W*f9 xr G;0X#See also#X\  P6G; P# GAO Report at 41 (users claim that they are more likely to use INTELSAT for occasionaluse video services because many of the alternative providers systems are tied up in longterm contracts and they lack excess capacity).(#`  The Networks rely on their own experience stating that PanAmSat, the largest United States international satellite carrier, has  X -little or no available occasionaluse capacity. N h OF<ԍ` ` #W*f9 xr G;0X#See#X\  P6G; P# Comments of Networks at 16.(#` Ʀ As PanAmSat and other Comsat competitors prepare to launch new satellites that will provide additional transponder capacity, the capacity on these satellites is likely to be presubscribed for fulltime video service leaving limited  X-capacity available for occasionaluse video service after satellite launch.Oh`h O<ԍ` ` #X\  P6G; P## W*f9 xr G;0X#See #X\  P6G; P#1996 Brattle Report at 22. In order to arrange financing for the construction, launch and operation of a satellite, a satellite operator will lease its fulltime video service circuits to customers prior to satellite launch.(#` Ɠ Even if Comsat's competitors maintain available capacity on the transatlantic and transpacific routes and that  Xb-digital compression technologiesPb h O<ԍ` ` #X\  P6G; P#"Digital compression technology" reduces the bandwidth or number of bits needed to transmit information, like a video signal, by eliminating long strings of identical bits or bits that do not change in successive sampling intervals (e.g., video frames). Compression technology saves transmission time or capacity on satellite transponders and reduces the storage space required on information storage devices.(#`  exist to increase transponder capacity for occasionaluse video services as contended by the 1996 Brattle Report, this capacity cannot easily be made available to provide occasionaluse video services in countries where Comsat's competitors lack landing rights. In addition, the fiberoptic video link between the United States and the United Kingdom is neither costeffective nor suitable for video transmissions from one point"PP0*''@@"  X-to multiple locations at the same time as is required for occasionaluse video services. Qh Oy<ԍ` ` #X\  P6G; P#According to the 1996 Brattle Report, Vyvx is providing occasionaluse video service between fiber video networks in the United States and Canada and the United Kingdom. The Networks claim that Vyvx's fiber video link charges are more than onethird higher than the charges for end to end satellite transmission. Moreover, the link does not offer service in other countries where users may demand occasionaluse video services.(#`  Therefore, the existence of this fiber link does not alleviate any capacity shortage among  #F Comsat's competitors in the occasionaluse video service market nor would it be a viable alternative for use by Comsat's competitors in those countries where they lack landing rights.  X-x41.` ` Nor is it clear from the evidence in the record that the presence of resellers in the occasionaluse video services market, which resell capacity on transponders leased from Comsat or its competitors, is an indication that this market is effectively competitive. Resellers acquiring capacity at retail rates would not be price competitive with Comsat and its competitors because the reseller would have a higher cost structure. Resellers acquiring capacity at cost would be able to compete with Comsat and its competitors on price, however, Comsat and its competitors would have a disincentive to lease capacity to resellers at such rates and, if they did, would have an incentive to impose anticompetitive restrictions on the resale of such capacity. The record's lack of evidence about this issue makes it difficult for us to make a determination about the rates at which resellers are acquiring capacity for resale in the occasionaluse video services market and its impact on competition in this market.  Xy-x42.` ` On the other hand, Comsat's exclusive access to INTELSAT's excess transponder capacity and Comsat's competitors' lack of similar capacity for the provision of  XK-occasionaluse video services confers market power on Comsat to set supracompetitive ratesRKh O<ԍ` ` #]\  PC P#Supracompetitive rates are rates set above competitive levels.(#` ƞ for occasionaluse video service. Even sophisticated users like the Networks that possess significant bargaining power are left with little choice but to use the Comsat/INTELSAT satellite system for occasionaluse video services because of its excess capacity and unique global reach discussed below. Comsat is the only choice and it is in a position to charge rates above competitive levels. Given Comsat's excess capacity in the occasionaluse video services market and its competitors' lack of such capacity, we find it necessary to maintain our current tariff rules applicable to Comsat's occasionaluse video service rate increases.  X|-x43.` ` The same legal, economic and technological barriers to entry discussed for full Xe-time video services exist in the occasionaluse video services market.Se(h O>#<ԍ` ` #W*f9 xr G;0X#See supra#X\  P6G; P#  3233.(#` Ơ The experience of the Networks confirm the existence of legal barriers to entry in the occasionaluse video services"NS0*''@@"  X-market.Th Oy<ԍ` ` #W*f9 xr G;0X#See#X\  P6G; P# Comments of Networks at 8, n.10.(#` ƫ Similar to fulltime video services, we believe that as WTO member countries implement their market access commitments made under the WTO Agreement, barriers to entry, particularly legal barriers, are likely to diminish. #F   X-x` ` b. Size and Resources  Xv-x44.` ` Second, the Commission noted in its August 1996 Order that INTELSAT's global reach in terms of connectivity and transponder capacity represents a key advantage that  XJ-it maintains over its competitors.UJhh Oc <ԍ` ` #X\  P6G; P## W*f9 xr G;0X#August 1996 Order#X\  P6G; P#  33.(#` In terms of connectivity, Comsat continues to have a significant advantage over its competitors in the occasionaluse video services market because the INTELSAT system operates in more than 136 countries through a network of thousands  X -of earth stations.V h O<ԍ` ` #W*f9 xr G;0X#See#X\  P6G; P# GAO Report at 43. (#` ƞ Comsat's competitors appear to be expanding the global connectivity and coverage provided by their occasionaluse video services, but the reality is that Comsat's competitors cannot yet offer the global connectivity provided by INTELSAT. We understand  X -that Comsat and its competitors utilize socalled "fly away"W h O<ԍ` ` #X\  P6G; P#"Flyaway earth stations" are portable earth stations that can be set up anywhere for satellite communications.(#` earth stations for occasionaluse video transmissions, but the record is devoid of any information regarding those countries in which Comsat's competitors have landing rights and are authorized to utilize earth stations for their occasionaluse video transmissions and those countries in which they lack such rights and authorizations. The experience of the Networks, the primary users of occasionaluse video services, supports this conclusion. PanAmSat, Comsat's largest competitor, still lacks earth station capacity and the inplace infrastructure necessary to send transmissions to an  X-earth station in many foreign countries.Xh O<ԍ` ` #W*f9 xr G;0X#See#X\  P6G; P# Comments of Networks at 16.(#` Ʀ And, limited landing rights in many countries actually prevent Comsat's competitors from accessing its earth stations from other parts of a foreign country which effectively restricts the mobility of a user of occasionaluse video service in covering a fastbreaking news story or event that may be occurring in a location  X-where the earth station is not located.Y h O$"<ԍ` ` #W*f9 xr G;0X#Id. #]\  PC P#Because the record does not identify those countries that provide landing rights (and the scope of those landing rights) to Comsat's competitors and those countries that do not, it is difficult for us to determine the specific number of countries that Comsat maintains an advantage in the occasionaluse video services market attributable to INTELSAT's global reach and connectivity. As a general matter, Comsat's market power in this market would be less in those countries that its competitors have comparable landing rights. (#` Ʀ Although the proposed combinations among Comsat's"8Y0*''@@" competitors, including, but not limited to, PanAmSat's combination with Hughes, and new satellite entrants into the international video transmission services market are expected to increase competition in the occasionaluse video service market, we remain unconvinced from the record that Comsat's competitors yet are able to match INTELSAT's ubiquitous market access and occasionaluse transponder availability. Comsat continues to benefit from INTELSAT's superior global connectivity in the occasionaluse video service market and this militates against a finding that substantial competition exists in the occasionaluse video services market.  X1-x45.` ` The WTO Agreement provides Comsat's competitors in the international video transmission services market with a greater opportunity to access markets worldwide. As Comsat's competitors are able penetrate these markets, their global connectivity will improve significantly. As a result, we expect that the superior global connectivity now enjoyed by INTELSAT will become a less significant factor in terms of assessing Comsat's market power in the occasionaluse video service market specifically, and in the international video  X -transmission services market, more generally. ^^  Xy-x46.` ` Therefore, we find that Comsat has not demonstrated good cause for waiving our tariff rules for occasionaluse video service rate increases. Accordingly, Comsat should continue to comply with Sections 61.38 and 61.58 of the Commission's Rules for tariff filings concerning occasionaluse video service rate increases. Comsat has demonstrated good cause for waiving our tariff rules applicable to occasionaluse video service rate decreases.  X- C.xRestructuring of INTELSAT x  X-x47.` ` The commenters urge the Commission to defer all action on streamlined tariff relief until after INTELSAT is restructured. The Networks make a more limited request. They seek postponement of any Commission action relating to streamlining tariff relief for Comsat's occasionaluse video service until after INTELSAT is restructured and Comsat's competitors obtain direct access to INTELSAT's facilities. We do not believe that we should delay in granting Comsat's request for streamlined tariff relief until after the INTELSAT  X7-restructuring is effective. Z27h O<ԍ` ` #\*f9 xC0X##]\  PC P#We note that the Commission's delegation of authority to the International Bureau and Common Carrier Bureau to act on a new Comsat request for streamlined tariff relief of its international video transmission services was not contingent on completing the INTELSAT  {O!-restructuring. See# ]\  PC P# August 1996 Order n.73.(#`  As discussed above, we are granting Comsat's Petition for its fulltime video services because we find that this market is subject to substantial competition. In a market where substantial competition exists, competitive market forces can substitute for regulation in protecting the public against unreasonably high rates for fulltime video services. We do not believe that a sufficient connection exists between INTELSAT's restructuring and the limited, streamlined tariff relief we are granting to Comsat in this Order. The United" Z0*''@@" States has taken the position that any INTELSAT restructuring promote competition in international satellite services. If this is not the case, there are regulatory responses available  X-to the Commission to protect competition in the United States.p[jh OK<ԍ` ` #\*f9 xC0X#See#]\  PC P# Amendment of the Commission's Regulatory Policies to Provide Domestic and  {O#-International Satellite Service in the United States, Further Notice of Proposed Rulemaking, FCC 97252 (Released July 18, 1997).(#` p In either event, our grant of limited, streamlined tariff relief for Comsat's fulltime video service and for occasionaluse video service rate decreases will not hinder our ability to monitor developments and take appropriate remedial action if there is harm to competition.  Xv-R  X_-"C IV. Conclusion TP  X1-x48.` ` We conclude that granting Comsat's Petition in part to waive the applicability of Sections 61.38 and 61.58 of the Commission's Rules with respect to Comsat's fulltime video services is in the public interest because our current tariff procedures are more extensive than necessary in light of the substantial competition in this market. Streamlined tariff relief for this service will promote competition in this market which is likely to stimulate price reductions and more rapid service delivery for users of fulltime video services. For these reasons, we find that good cause is shown for grant of a waiver to permit streamlined tariff relief for Comsat's fulltime video services. We decline to extend our waiver of the tariff rules and streamlined tariff relief to Comsat's occasionaluse video services rate increases. Because Comsat's relationship with INTELSAT provides Comsat with excess capacity and superior global connectivity in this market, the record demonstrates that substantial competition does not yet exist in this market and that Comsat retains the market power to increase occasionaluse video service rates above competitive levels. However, granting Comsat streamlined tariff relief for occasionaluse video service rate decreases is likely to result in lower rates to the public. Thus, good cause exists to waive the tariff rules and grant streamlined tariff relief for rate decreases in this market. We preserve our right to review in advance any of Comsat's subsequent tariff filings for fulltime video services and occasionaluse video services and, if circumstances then warrant, to revisit the appropriateness of this waiver.  Xe-x49.` ` Comsat must still comply with Section 61.33 of our Rules which requires a concise explanation of the nature and purpose of the fulltime video service or occasionaluse video service tariff filing and whether the filing is for a rate increase or decrease. Comsat's fulltime video service tariffs may be filed on 14 days' prior notice and will be presumed lawful for purposes of advanced tariff review. Interested parties may file petitions against  X-these tariffs pursuant to the time tables prescribed in our existing rules.\h O$<ԍ` ` #X\  P6G; P#Under the Commission's Rules, petitions relating to tariffs filed on 14 days prior notice must  {Ou%-be filed within six days after the tariff is filed. # W*f9 xr G;0X#See#X\  P6G; P# 47 C.F.R.  1.773(a)(2)(i).# Xj\  P6G;9XP#(#` Ɵ We will thus have"d\0*''@@" an opportunity to identify and suspend and/or reject tariffs where necessary before they go  #F into effect. We will reject any tariffs that conflict on their face with a statute or an agency regulation or order.  X-x50.` ` The presumption of lawfulness for purposes of advance review does not change the substantive standards to be used in evaluating a tariff in a complaint proceeding or tariff investigation. Posteffective review procedures, including the complaint process and our authority to initiate investigations and find tariffs unlawful after they take effect, will continue to apply as before. In addition, we retain authority to institute at any time investigations of Comsat tariffs after they become effective and to declare tariffs unlawful. We will also consider in the complaint process claims of unlawful actions by Comsat.  X -.  V. Ordering Clauses TP  X -x51.` ` Accordingly, IT IS ORDERED, pursuant to Section 1.3 of the Commission's Rules, 47 C.F.R.  1.3, that a waiver of Sections 61.38 and 61.58 of the Commission's Rules, 47 C.F.R.  61.38, 61.58, IS GRANTED to Comsat Corporation and that Comsat  Xy-Corporation is allowed to make tariff filings as described, supra, on 14 days' prior notice and with a presumption of lawfulness for its INTELSAT fulltime video services and for its INTELSAT occasionaluse video services rate decreases. A waiver of Sections 61.38 and 61.58 of the Commission's Rules is DENIED to Comsat Corporation for its INTELSAT occasionaluse video service rate increases.  X-x52.` ` IT IS FURTHER ORDERED that this Order is issued pursuant to Section 0.261 of the Commission's Rules on Delegations of Authority, 47 C.F.R.  0.261. Petitions for reconsideration under Section 1.106 of the Commission's Rules, 47 C.F.R.  1.106, or applications for review under Section 1.115 of the Commission's Rules, 47 C.F.R.  1.115,  X-may be filed within 30 days of the release date of this Order. See 47 C.F.R.  1.4(b)(2). x  Xi-x53.` ` IT IS FURTHER ORDERED that this Order is effective upon release. x` `  hh x` `  hhFEDERAL COMMUNICATIONS COMMISSION x` `  hhPeter F. Cowhey  X!-x` `  hhChief, International Bureau#Xw PE37XP#