FCC Record, Volume 26, No. 7, Pages 4843 to 5761, March 28 - April 08, 2011 Page: 5,225
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Federal Communications Commission
service long run incremental costs incurred to receive, transmit, and terminate international service.s2
Second, a U.S. carrier can request additional transition time for a route if annual reductions in settlement
rates would entail a loss of greater than 20 percent of a country's annual telecommunications revenues.53
21. TeleCuba did not attempt to support its waiver request before us now in terms of either
standard. Rather, TeleCuba's waiver request is based upon the premise that it can re-introduce direct
services to Cuba only by agreement to pay ETECSA an $0.84 per minute rate for termination of all traffic
including roaming services. TeleCuba seeks to establish a working relationship with ETECSA that would
enable it to provide a direct "single path" to Cuba in order to offer customers improved call quality (in
terms of reduced latency and post-dial delay) and an alternative to currently available indirect services
involving multiple hops at higher cost and lower quality.54 TeleCuba states that its contacts at the Cuban
Ministry of Communications frequently ask about the status of TeleCuba's ability to pay $0.84 per
minute for termination of traffic on a direct basis55 and that ETECSA has indicated that it did not want to
meet with TeleCuba until TeleCuba could commit to the $0.84 per minute rate.56 TeleCuba anticipates
the ability to negotiate lower rates in the future as it increases direct traffic."s
22. No commenters opposed TeleCuba's request for a waiver of the benchmark rate. Both
AT&T and Verizon support granting a benchmark waiver. Both carriers believe that supporting the
Administration's policy of fostering greater communications between the United States and Cuba and
promoting contacts between Cuban-Americans and their relatives in Cuba will serve the public interest.58
AT&T believes that re-establishment of direct communications between the United States and Cuba
presents a "unique situation" in the context of TeleCuba's waiver requests, and agrees that "it may be
necessary to allow some additional temporary flexibility in U.S. carrier settlement rates as a predicate to
the re-establishment of bilateral international traffic arrangements with the U.S.-Cuba route."59 Verizon
believes that a narrow waiver to permit a temporary increase in settlement and benchmark rates would
allow U.S. carriers "to investigate the re-establishment of relationships with Cuban providers and/or the
construction of potential facilities on the U.S.-Cuba route."" Verizon supports TeleCuba's requested
three-year benchmark waiver period as reasonable, given that a shorter period of time might not allow
sufficient opportunity for carriers to explore the most efficient relationships or to complete the amount of
work required to establish services between the United States and Cuba.61 Additionally, Verizon
emphasizes that any waiver must apply to all U.S. carriers who may wish to establish direct
communications between the United States and Cuba.62
23. We find that the public interest would be served by granting TeleCuba a waiver of the
52 Id. at 19842-43, 74.
54 See Petition at 2; see also Petitioner's Response to Supplemental Information Request at 2.
ss See Petitioner's Response to Supplemental Information Request at 2.
56 Id. at 3.
57 Id. at 2.
58 See AT&T Comments at 1-2; Verizon Reply Comments at 1-2.
59 See AT&T Comments at 2-3.
60o See Verizon Reply Comments at 3.
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United States. Federal Communications Commission. FCC Record, Volume 26, No. 7, Pages 4843 to 5761, March 28 - April 08, 2011, book, April 2011; Washington D.C.. (digital.library.unt.edu/ark:/67531/metadc52169/m1/397/: accessed March 26, 2017), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.