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                                                                                                          June 22, 2000
  
       Separate Statement of Commissioner Susan Ness
  
  
     Re:  Review of Commission Consideration of Applications under the Cable Landing
     License Act
  
  Last July, the Commission granted a submarine cable landing license for the Japan-U.S.
  Cable Network ("JUS CN").  During the proceeding, it was alleged that the entities
  involved in the consortium controlled key inputs for other undersea cable systems serving
  the same routes, including access to landing stations, backhaul facilities, and local
  interconnection.   It was also alleged that such entities had the incentive and ability to
  deter construction of additional capacity.  In granting the JUS CN cable license, the
  Commission recognized the value of commencing a broader proceeding to examine the
  licensing of submarine cables and the best manner to promote competition and benefit
  consumers.
  
  The recent increase in submarine cable capacity has been a tremendous success story,
  driven by the desire of more and more carriers to provide international data and Internet
  access services.  Undersea cable capacity on transatlantic and transpacific routes has been
  increasing exponentially between 1995 and 1998.  Such capacity growth is expected to
  continue at least for the next few years.  At the same time, market prices for both
  transatlantic and transpacific bandwidth have fallen dramatically with increased supply.  It
  therefore seems truly appropriate to adopt policies that would streamline our procedures
  to expedite granting cable landing authority.
  
  For these reasons, I support this initiation of a proceeding to identify ways to promote
  competition in the operation of undersea cable systems, and at the same time streamline
  our submarine cable licensing process.  The International Bureau has expended significant
  thought and effort in crafting very specific proposals that would permit more expeditious
  authorization of certain cable landing applications.  I do not view these proposals as the
  end product of our process.  Instead, in opening this proceeding, I hope that comment on
  these proposals will result in a simpler, and more extensive, streamlining of our processes. 
  The Commission should try to avoid inadvertently raising the costs of entering the
  undersea cable market in the course of "streamlining" its processes.  Thus, in addition to
  commenting on the efficacy of these proposals, I encourage parties to suggest ways to
  make these streamlining efforts more expansive.