• The Enforcement Bureau entered into a Consent Decree with a nationwide wireless carrier in connection with a 911 outage. The Consent Decree referenced Section 4.9 of the Commission’s rules  (regarding notifications to PSAPs of network outages) and Sections 20.18(b) and 64.3002 of the Commission’s rules (requiring carriers to deliver all 911 calls to a PSAP, a designated statewide answering default answering point, or an appropriate local emergency authority).  The carrier agreed to pay a fine of $17.5 million, agreed to an extensive compliance plan, and admitted that the rules required timely notification of the outage to PSAPs and that they did not provide such timely notice.  This was the highest single FCC enforcement action in this area, although the combined fines for carriers in connection with another 2014 outage was higher — $20.8 million.
  • The Enforcement Bureau entered into Consent Decrees with three providers of Internet protocol captioned telephone service regarding their failure to deliver 911 calls to PSAPs and related claims for reimbursement from the Telecommunications Relay Service Fund.  The companies admitted violations, agreed to pay penalties of $1.175 million, $235,000, and $25,000, and agreed to extensive compliance plans.
    • The $25,000 Consent Decree, with a small company that appears not to have been represented by an attorney, included a novel provision regarding future violations of the Consent Decree. The company agreed to a procedure, not reflected in the Communications Act or FCC rules, in which (1) the Bureau would notify the company of any noncompliance and propose a “civil penalty” (not a forfeiture) of up to $50,000, (2) the company would have an opportunity to respond, (3) the Bureau would then impose a civil penalty through a “Demand for Payment,” and (4) the company “shall pay” the civil penalty, apparently with no right to Commission review or court appeal.  It is not clear at this point whether this provision relates to specific circumstances of this case or in what other contexts the Bureau may attempt to use it.