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Before the
Federal Communications Commission
Washington, D.C. 20554
)
In the Matter of File No. EB-07-SE-144
)
South Central Utah Telephone NAL/Acct. No. 200832100004
Association, Inc. )
FRN # 0001607175
)
Notice of apparent Liability for forfeiture
Adopted: October 31, 2007 Released: November 1, 2007
By the Chief, Spectrum Enforcement Division, Enforcement Bureau:
I. introduction
1. In this Notice of Apparent Liability for Forfeiture ("NAL"), we find
that South Central Utah Telephone Association, Inc. ("South Central")
apparently willfully and repeatedly violated Section 20.19(f) of the
Commission's Rules ("Rules") by failing to comply with the labeling
requirements for digital wireless hearing aid-compatible handsets. For
South Central's apparent violations, and for the reasons discussed
below, we propose a forfeiture in the amount of twenty-four thousand
dollars ($24,000).
II. BACKGROUND
2. In the 2003 Hearing Aid Compatibility Order, the Commission took a
number of actions to further the ability of persons with hearing
disabilities to access digital wireless telecommunications. Among
other actions, the Commission required manufacturers and digital
wireless service providers to collectively take steps to increase the
number of hearing aid-compatible handset models available, and
established phased-in deployment benchmark dates for the offering of
hearing aid-compatible digital wireless handset models. In this
regard, the Commission required entities within each of these classes
that do not fall within the de minimis exception to begin to offer
digital wireless handset models with reduced emission levels that meet
at least a U3 rating for radio frequency interference by September 16,
2005. In connection with the offer of hearing aid-compatible handset
models, the Commission also required entities to label the handsets
with the appropriate technical rating, and to explain the technical
rating system in the owner's manual or as part of the packaging
material for the handset. In order to monitor efforts to make
compliant handsets available, the Commission required manufacturers
and digital wireless service providers to report every six months on
efforts toward compliance with the hearing aid compatibility
requirements for the first three years of implementation (on May 17,
2004, November 17, 2004, May 17, 2005, November 17, 2005, May 17,
2006, and November 17, 2006), and then annually thereafter through the
fifth year of implementation (on November 19, 2007 and November 17,
2008).
3. In June 2005, the Commission reconsidered certain aspects of the
Hearing Aid Compatibility Order and modified the preliminary handset
deployment benchmark specific to Tier I wireless carriers (i.e.,
carriers with national footprints). Specifically, the Hearing Aid
Compatibility Reconsideration Order established that by September 16,
2005, Tier I wireless carriers must offer four digital wireless
handset models per air interface, or twenty-five percent of the total
number of digital wireless handset models offered by the carrier
nationwide, that meet a U3 rating. The Hearing Aid Compatibility
Reconsideration Order, however, did not modify the preliminary
deployment benchmark or associated labeling requirements for Tier II
or Tier III wireless carriers. Tier II and Tier III wireless carriers
that do not fall within the de minimis exception, therefore, were
required to include in their handset offerings at least two U3-rated
handset models per air interface, and to comply with the associated
labeling requirements, by September 16, 2005.
4. On April 11, 2007, the Commission released the Wireless Hearing
Aid-Compatible Waiver Order, addressing individually each waiver
petition filed by nineteen Tier II and Tier III wireless carriers,
including South Central, for relief from the hearing-aid compatibility
requirements for wireless digital telephones. In its waiver request,
South Central requested a waiver that would extend the September 16,
2005 compliance deadline by one year. South Central cited the
unavailability of U3-rated handsets as grounds for its request. The
Commission noted, however, that South Central's November 17, 2005
Report stated that it was "currently marketing six CDMA handsets that
meet the M3 rating." Accordingly, the Commission concluded that South
Central came into compliance with the preliminary handset deployment
benchmark as of November 17, 2005, and granted South Central a waiver
nunc pro tunc to extend the deadline for compliance with Section
20.19(c)(2)(i) of the Commission's rules until that date. The
Commission found that this brief delay was de minimis and that it did
not unduly deprive South Central's subscribers of access to hearing
aid-compatible handsets.
5. The Commission found, however, that South Central had not come fully
into compliance with the labeling requirements for hearing
aid-compatible hearing aid-compatible handsets even as of the date of
the April 11, 2007, Wireless Hearing Aid-Compatible Waiver Order. The
Commission found that South Central's November 17, 2005 Report
indicated that three Motorola handsets it offered complied with the
labeling requirements. However, the Commission pointed out that the
Section 20.19(f) labeling requirements apply to all hearing
aid-compatible handset models offered by a carrier. Furthermore, the
Commission stated that although Section 20.19(c)(2) may require only
that a Tier III carrier offer two hearing aid-compatible handset
models per air interface, if the carrier chooses to provide a greater
number of hearing aid-compatible handset models, each of those handset
models must comply with the labeling requirements. The Commission
observed that as of November 17, 2005, only three of South Central's
six hearing aid-compatible models were complaint with labeling
obligations. As of May 17, 2006, only five of the eight hearing
aid-compatible handsets offered by South Central were fully complaint
with labeling requirements. Finally, South Central's November 17, 2006
Report showed that, as of that date, only six of its nine hearing
aid-compatible handsets were fully complaint with labeling
obligations.
6. The Commission found that with respect to its request for waiver of
the labeling requirements for hearing aid-compatible handsets, South
Central had failed to demonstrate unusual or unique circumstances, or
the existence of any other factor, that would warrant relief from the
labeling requirement for a protracted, indeterminate period of time.
The Commission stated that Section 20.19(f) imposes on both service
providers and manufacturers the responsibility to ensure that hearing
aid compatible handsets are properly labeled, and that the dependence
of service providers on manufacturers for handset labeling in the
first instance does not excuse the service providers from taking steps
to achieve compliance with the labeling requirements. Moreover, the
Commission found that the record did not establish that South Central
made reasonable efforts to obtain labeling from manufacturers for all
of its hearing aid-compatible handsets, and that other Tier III
carriers have been able to come into compliance with those
requirements and have been able to identify precisely when they
achieved such compliance. Thus, the Commission concluded that South
Central did not make the requisite showing to justify a waiver of
Section 20.19(f) of the Rules, denied this aspect of the South Central
Petition, and referred South Central's apparent violation to the
Enforcement Bureau.
III. Discussion
A. Failure to Comply with Labeling Requirements for Wireless Hearing-Aid
Compatible Handsets
7. Section 20.19(f) of the Rules provides that wireless digital hearing
aid-compatible handsets shall clearly display the U-rating, as defined
in Section 20.19(b), on the packaging material of the handset and that
an explanation of the technical rating system shall be included in the
owner's manual or as an insert with the packaging material for the
handset by September 16, 2005. As stated above, in the Wireless
Hearing Aid-Compatible Waiver Order, the Commission determined that
South Central apparently failed to come into compliance with the
labeling requirements for three of its six hearing aid-compatible
models as of November 17, 2005; as of May 17, 2006, only five of its
eight hearing aid-compatible models were in compliance; and the
November 17, 2006 Report showed that, as of that date, only six of its
nine hearing aid-compatible models were in compliance. Accordingly, we
conclude that South Central apparently willfully and repeatedly failed
to comply with the labeling requirements in violation of Section
20.19(f) of the Rules.
A. Proposed Forfeiture
8. Under Section 503(b)(1)(b) of the Act, any person who is determined by
the Commission to have willfully or repeatedly failed to comply with
any provision of the Act or any rule, regulation, or order issued by
the Commission shall be liable to the United States for a forfeiture
penalty. To impose such a forfeiture penalty, the Commission must
issue a notice of apparent liability and the person against whom such
notice has been issued must have an opportunity to show, in writing,
why no such forfeiture penalty should be imposed. The Commission will
then issue a forfeiture if it finds by a preponderance of the evidence
that the person has violated the Act or a Commission rule. We conclude
under this standard that South Central is apparently liable for
forfeiture for its apparent willful and repeated violations of Section
20.19(f) of the Rules.
9. Under Section 503(b)(2)(B) of the Act, we may assess a common carrier
a forfeiture of up to $130,000 for each violation, or for each day of
a continuing violation up to a maximum of $1,325,000 for a single act
or failure to act. In exercising such authority, we are required to
take into account "the nature, circumstances, extent, and gravity of
the violation and, with respect to the violator, the degree of
culpability, any history of prior offenses, ability to pay, and such
other matters as justice may require."
10. The Commission's Forfeiture Policy Statement and Section 1.80 of the
Rules do not establish a base forfeiture amount for violations of
labeling requirements for hearing aid-compatible handsets set forth in
Section 20.19(f) of the Rules. Enforcement of these requirements is
important to ensure that individuals with hearing disabilities have
access to information that they need to make informed decisions as to
which wireless telephone best meets their individual needs. Moreover,
as the Commission has observed, the number of Americans with hearing
disabilities is growing, and so is wireless phone use. We note that a
base forfeiture amount of $8,000 has been established for violations
of the emergency accessibility rules. The emergency accessibility
requirements and the labeling requirements for wireless hearing
aid-compatible handsets both serve the important goal of promoting
public safety by ensuring that consumers with disabilities have access
to information that they need. Consistent with our recent decision in
a similar case, we view these violations as analogous and find that
the $8,000 base forfeiture amount is appropriate for apparent
violations of Section 20.19(f). We find that South Central failed to
come into compliance with the labeling requirements for each of three
handsets it was offering, until at least through the release date of
the Wireless Hearing Aid-Compatible Waiver Order. Each such failure is
a separate violation. Accordingly, we propose a forfeiture of $8,000
for each of South Central's failures to comply with the labeling
requirements for wireless hearing aid-compatible handsets, for a total
proposed forfeiture of $24,000.
iV. ordering clauses
11. Accordingly, IT IS ORDERED that, pursuant to Section 503(b) of the
Act, and Section 1.80 of the Rules, South Central Utah Telephone
Association, Inc., IS NOTIFIED of its APPARENT LIABILITY FOR A
FORFEITURE in the amount of twenty-four thousand dollars ($24,000) for
willful and repeated violation of Section 20.19(f) of the Rules.
12. IT IS FURTHER ORDERED that, pursuant to Section 1.80 of the Rules,
within thirty days of the release date of this Notice of Apparent
Liability for Forfeiture, South Central Utah Telephone Association,
Inc. SHALL PAY the full amount of the proposed forfeiture or SHALL
FILE a written statement seeking reduction or cancellation of the
proposed forfeiture.
13. Payment of the forfeiture must be made by credit card through the
Commission's Debt and Credit Management Center at (202) 418-1995, or
by check or similar instrument, payable to the order of the Federal
Communications Commission. The payment must include the NAL/Acct. No.
and FRN No. referenced above. Payment by check or money order may be
mailed to Federal Communications Commission, P.O. Box 358340,
Pittsburgh, PA 15251-8340. Payment by overnight mail may be sent to
Mellon Bank/LB 358340, 500 Ross Street, Room 1540670, Pittsburgh, PA
15251. Payment by wire transfer may be made to ABA Number 043000261,
receiving bank Mellon Bank, and account number 911-6106.
14. The response, if any, must be mailed to the Office of the Secretary,
Federal Communications Commission, 445 12th Street, S.W., Washington,
D.C. 20554, ATTN: Enforcement Bureau - Spectrum Enforcement Division,
and must include the NAL/Acct. No. referenced in the caption.
15. The Commission will not consider reducing or canceling a forfeiture in
response to a claim of inability to pay unless the petitioner submits:
(1) federal tax returns for the most recent three-year period; (2)
financial statements prepared according to generally accepted
accounting practices; or (3) some other reliable and objective
documentation that accurately reflects the petitioner's current
financial status. Any claim of inability to pay must specifically
identify the basis for the claim by reference to the financial
documentation submitted.
16. Requests for payment of the full amount of the NAL under an
installment plan should be sent to: Associate Managing Director -
Financial Operations, 445 12th Street, S.W., Room 1-A625, Washington,
D.C. 20554.
17. IT IS FURTHER ORDERED that a copy of this Notice of Apparent Liability
for Forfeiture shall be sent by first class mail and certified mail
return receipt requested to Brant Barton, Chief Executive Officer,
South Central Utah Telephone Association, Inc., P.O. Box 555,
Escalante, Utah 84726 and to Harold Mordkofsky, Blooston, Mordkofsky,
Dickens, Duffy & Prendergast, LLP, 2120 L Street, N.W., Washington, DC
20037.
FEDERAL COMMUNICATIONS COMMISSION
Kathryn S. Berthot
Chief, Spectrum Enforcement Division
Enforcement Bureau
47 C.F.R. S: 20.19(f).
The "labeling requirements" are two-part, mandating that the packaging for
wireless hearing aid-compatible handsets display the technical rating of
the handset and that an explanation of the technical rating system be
included as an insert in the packaging material or incorporated in the
owner's manual for the handset.
Section 68.4(a) of the Commission's Rules Governing Hearing Aid-Compatible
Telephones, Report and Order, 18 FCC Rcd 16753 (2003); Erratum, 18 FCC Rcd
18047 (2003) ("Hearing Aid Compatibility Order"). The Commission adopted
these requirements for digital wireless telephones under authority of a
provision of the Hearing Aid Compatibility Act of 1988, codified at
Section 710(b)(2)(C) of the Communications Act of 1934, as amended, 47
U.S.C. S: 610(b)(2)(C).
See Hearing Aid Compatibility Order, 18 FCC Rcd at 16780; 47 C.F.R. S:
20.19(c). In adopting these requirements, the Commission observed, inter
alia, that "as wireless service has evolved to become increasingly more
important to Americans' safety and quality of life, the need for persons
with hearing disabilities to have access to wireless services has become
critical." Hearing Aid Compatibility Order, 18 FCC Rcd at 16757.
See 47 C.F.R. S: 20.19(e)(1)-(2). The de minimis exception applies on a
per air interface basis, and provides that manufacturers or mobile service
providers that offer two or fewer digital wireless handsets in the U.S.
are exempt from the requirements of the hearing aid compatibility rules.
For mobile service providers that obtain handsets only from manufacturers
that offer two or fewer digital wireless handset models in the U.S., the
service provider would likewise be exempt from the hearing aid
compatibility requirements. Manufacturers or mobile service providers that
offer three digital wireless handset models must offer at least one
compliant handset model. Mobile service providers that obtain handsets
only from manufacturers that offer three digital wireless handset models
in the U.S. are required to offer at least one compliant handset model.
Section 20.19(b)(1) of the Rules provides that a wireless handset is
deemed hearing aid-compatible if, at minimum, it receives a U3 rating "as
set forth in the standard document ANSI C63.19-2001[,] `American National
Standard for Methods of Measurement of Compatibility between Wireless
Communications Devices and Hearing Aids.'" 47 C.F.R. S: 20.19(b)(1). On
April 25, 2005, the Commission's Office of Engineering and Technology
announced that it would also certify handsets as hearing aid-compatible
based on the revised version of the standard, ANSI C63.10-2005. Thus,
applicants for certification may rely on either the 2001 version or 2005
version of the ANSI C63.19 standard. See OET Clarifies Use of Revised
Wireless Phone Hearing Aid Compatibility Standard Measurement Procedures
and Rating Nomenclature, Public Notice, 20 FCC Rcd 8188 (OET 2005). In
addition, we note that, since its 2005 draft version, the ANSI C63.19
technical standard has used an "M" nomenclature for the radio frequency
interference rating rather than a "U," and a "T" nomenclature for the
handset's inductive coupling rating, rather than a "UT." The Commission
has approved the use of the "M" and "T" nomenclature and considers the M/T
and U/UT nomenclatures as synonymous. See Section 68.4(a) of the
Commission's Rules Governing Hearing Aid-Compatible Telephones, Order on
Reconsideration and Further Notice of Proposed Rulemaking, 20 FCC Rcd
11221, 11238 (2005) ("Hearing Aid Compatibility Reconsideration Order").
See Hearing Aid Compatibility Order, 18 FCC Rcd at 16780; see also 47
C.F.R. S: 20.19(c)(1)-(3).
See Hearing Aid Compatibility Order, 18 FCC Rcd at 16785; see also 47
C.F.R. S: 20.19(f). In addition, to ensure that the rating information was
actually conveyed to consumers prior to purchase, the Commission required
digital wireless service providers to ensure that the U-rating of the
handsets is available to such consumers at the point-of-sale, whether
through display of the label, separate literature, or other means. See
Hearing Aid Compatibility Order, 18 FCC Rcd at 16785.
See id. at 16787; see also Wireless Telecommunications Bureau Announces
Hearing Aid Compatibility Reporting Dates for Wireless Carriers and
Handset Manufacturers, Public Notice, 19 FCC Rcd 4097 (WTB 2004).
See Hearing Aid Compatibility Reconsideration Order, 20 FCC Rcd at 11238.
See id. at 11232; see also OET Clarifies Use of Revised Wireless Phone
Hearing Aid Compatibility Standard Measurement Procedures and Rating
Nomenclature, Public Notice, 20 FCC Rcd 8188 (OET 2005).
Tier II carriers are non-nationwide wireless radio service providers with
more than 500,000 subscribers. Tier III carriers are non-nationwide
wireless radio service providers with 500,000 or fewer subscribers. See
Revision of the Commission's Rules to Ensure Compatibility with Enhanced
911 Emergency Calling Systems, Phase II Compliance Deadlines for
Non-Nationwide CMRS Carriers, Order to Stay, 17 FCC Rcd 14841, 14847
(2002).
See 47 C.F.R. S: 20.19(c)(2)(i).
Section 68.4(a) of the Commission's Rules Governing Hearing Aid-Compatible
Telephones, Petitions for Waiver of Section 20.19 of the Commission's
Rules, Memorandum Opinion and Order, 22 FCC Rcd 7171 (2007) ("Wireless
Hearing Aid-Compatible Waiver Order").
South Central Petition at 1.
Id. at 4 (asserting that the basis for the waiver request "is starkly
simple and can be concisely stated: There are no [hearing aid-compatible]
compliant digital wireless telephones available for purchase by Tier III
wireless carriers, such as South Central Utah, that meet a U3 rating under
the ANSI Standard C63.19 for radio frequency interference").
Wireless Hearing Aid-Compatible Waiver Order, 22 FCC Rcd at 7188, P: 35.
Id. at 7188, P: 37.
Id.
Id. at 7188-7189, P: 38.
Id. at 7189, P: 38.
Id.
Id. at 7188-7189, P: 38.
Id.
Id. at 7189, P: 39. See also 47 C.F.R. S: 20.19(a) (requirements of
Section 20.19 apply both to providers of public mobile services and to
manufacturers of handsets used in the delivery of those services.).
Id.
Id. South Central filed a petition for partial reconsideration of the
Wireless Hearing Aid-Compatible Waiver Order on May 11, 2007. See South
Central Utah Telephone Association, Inc. Petition for Partial
Reconsideration, WTB Docket No. 01-309 (May 11, 2007). That petition
remains pending.
Section 312(f)(1) of the Act defines "willful" as "the conscious and
deliberate commission or omission of [any] act, irrespective of any intent
to violate" the law. 47 U.S.C. S: 312(f)(1). The legislative history of
Section 312(f)(1) of the Act clarifies that this definition of willful
applies to both Sections 312 and 503(b) of the Act, H.R. Rep. No. 97-765,
97th Cong. 2d Sess. 51 (1982), and the Commission has so interpreted the
term in the Section 503(b) context. See Southern California Broadcasting
Co., Memorandum Opinion and Order, 6 FCC Rcd 4387, 4388 (1991), recon.
denied, 7 FCC Rcd 3454 (1992) ("Southern California").
Section 312(f)(2) of the Act, which also applies to forfeitures assessed
pursuant to Section 503(b) of the Act, provides that "[t]he term
`repeated,' ... means the commission or omission of such act more than
once or, if such commission or omission is continuous, for more than one
day." 47 U.S.C. S: 312(f)(2). See Callais Cablevision, Inc., Notice of
Apparent Liability for Forfeiture, 16 FCC Rcd 1359, 1362 (2001); Southern
California, 6 FCC Rcd at 4388.
47 U.S.C. S: 503(b)(1)(B); 47 C.F.R. S: 1.80(a)(1).
47 U.S.C. S: 503(b); 47 C.F.R. S: 1.80(f).
See, e.g., SBC Communications, Inc., Forfeiture Order, 17 FCC Rcd 7589,
7591 (2002).
47 U.S.C. S: 503(b)(2)(B). The Commission twice amended Section 1.80(b)(3)
of the Rules, 47 C.F.R. S: 1.80(b)(3), to increase the maxima forfeiture
amounts, in accordance with the inflation adjustment requirements
contained in the Debt Collection Improvement Act of 1996, 28 U.S.C. S:
2461. See Amendment of Section 1.80 of the Commission's Rules and
Adjustment of Forfeiture Maxima to Reflect Inflation, Order, 15 FCC Rcd
18221 (2000) (adjusting the maximum statutory amounts from
$100,000/$1,000,000 to $120,000/$1,200,000); Amendment of Section 1.80 of
the Commission's Rules and Adjustment of Forfeiture Maxima to Reflect
Inflation, Order, 19 FCC Rcd 10945 (2004) (adjusting the maximum statutory
amounts from $120,000/$1,200,000 to $130,000/$1,325,000); see also 47
C.F.R. S: 1.80(c).
47 U.S.C. S: 503(b)(2)(E). See also 47 C.F.R. S: 1.80(b)(4), Note to
paragraph (b)(4): Section II. Adjustment Criteria for Section 503
Forfeitures.
See The Commission's Forfeiture Policy Statement and Amendment of Section
1.80 of the Rules to Incorporate the Forfeiture Guidelines, 12 FCC Rcd
17087, 17115 (1997), recon. denied, 15 FCC Rcd 303 (1999) ("Forfeiture
Policy Statement").
The fact that the Forfeiture Policy Statement does not specify a base
amount does not indicate that no forfeiture should be imposed. The
Forfeiture Policy Statement states that "... any omission of a specific
rule violation from the ... [forfeiture guidelines] ... should not signal
that the Commission considers any unlisted violation as nonexistent or
unimportant. Forfeiture Policy Statement, 12 FCC Rcd at 17099. The
Commission retains the discretion, moreover, to depart from the Forfeiture
Policy Statement and issue forfeitures on a case-by-case basis, under its
general forfeiture authority contained in Section 503 of the Act. Id.
Hearing Aid Compatibility Order, 18 FCC Rcd at 16785, aff'd, 20 FCC Rcd
at 11238-39.
Id. at 16786.
See Fox Television Stations, Inc., Notice of Apparent Liability for
Forfeiture, 20 FCC Rcd 9847, 9852 (Enf. Bur., 2005); NBC Telemundo License
Co., Notice of Apparent Liability for Forfeiture, 20 FCC Rcd 9839, 9845
(Enf. Bur., 2005); Midwest Television, Inc., Notice of Apparent Liability
for Forfeiture, 20 FCC Rcd 3959, 3966 (Enf. Bur., 2005), consent decree
issued, 22 FCC Rcd 4405 (Enf. Bur., 2007).
See supra n. 4.
See IT&E Overseas, Inc., Notice of Apparent Liability for Forfeiture, 22
FCC Rcd 7660 (Enf. Bur., Spectrum Enf. Div. 2007).
Under Section 503(b)(6) of the Act, 47 U.S.C. S: 503(b)(6), we are
prohibited from assessing a forfeiture for a violation that occurred more
than a year before the issuance of a NAL. See also 47 C.F.R. S:
1.80(b)(4). Section 503(b)(6) does not, however, bar us from considering
South Central's prior conduct in determining the appropriate forfeiture
amount for violations that occurred within the one-year statutory period.
See Behringer USA, Inc., Forfeiture Order, 22 FCC Rcd 10451, 10453-10454
(2007); Globcom, Inc. d/b/a Globcom Global Communications, Notice of
Apparent Liability for Forfeiture, 18 FCC Rcd 19893, 19903 (2003),
forfeiture ordered, 21 FCC Rcd 4710 (2006); Roadrunner Transportation,
Inc., Forfeiture Order, 15 FCC Rcd 9669, 9671-71 (2000); Cate
Communications Corp., Memorandum Opinion and Order, 60 RR 2d 1386, 1388
(1986); Eastern Broadcasting Corp., Memorandum Opinion and Order, 10 FCC
2d 37, 37-38 (1967) recon. denied, 11 FCC 2d 193, 195 (1967). Accordingly,
while we take into account the continuous nature of the violations in
determining the appropriate forfeiture amount, our proposed forfeiture
relates only to South Central's apparent violations that have occurred
within the past year.
See 47 C.F.R. S: 1.1914.
(Continued from previous page)
(continued....)
Federal Communications Commission DA 07-4481
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Federal Communications Commission DA 07-4481