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Before the
Federal Communications Commission
Washington, D.C. 20554
)
In the Matter of ) File No.: EB-11-IH-0734
VERMONT TELEPHONE COMPANY, INC. ) NAL/Acct. No.: 201232080004
Participant in Auction No. 86 ) FRN: 0005209374
)
NOTICE OF APPARENT LIABILITY FOR FORFEITURE
Adopted: October 14, 2011 Released: October 14, 2011
By the Chief, Enforcement Bureau:
I. INTRODUCTION
1. In this Notice of Apparent Liability for Forfeiture ("NAL"), we find
that Vermont Telephone Company, Inc. ("VTel"), apparently violated
sections 1.17 and 1.65 of the Commission's rules ("Rules") by
willfully and repeatedly failing to submit accurate revenue
information to the Commission and by failing to maintain the
continuing accuracy of its application in connection with its
participation in Auction No. 86. Based on our review of the facts and
circumstances surrounding this matter, and for the reasons discussed
below, we find that VTel is apparently liable for a forfeiture in the
total amount of $34,000.
II. BACKGROUND
2. In Auction No. 86, a bidder whose attributable average annual gross
revenues for the preceding three years exceeded $15 million, but did
not exceed $40 million, was designated as a "small business" and
entitled to receive a 15 percent discount on its winning bid(s).
Pursuant to section 1.2110 of the Rules, an applicant claiming status
as a small business entity in Auction No. 86 was required to disclose,
for each of the three years preceding the auction, the gross revenues
of each of the following entities: (1) the applicant, (2) its
affiliates, (3) its controlling interests, (4) the affiliates of its
controlling interests, and (5) the entities with which it has an
attributable material relationship. Successful small business auction
participants were required to provide the required detailed financial
information after the auction closed.
3. VTel is a family-owned telephone company that began serving rural
Vermont in 1890. According to its website, VTel is "one of the largest
owners of FCC wireless licenses in Vermont, New Hampshire, and Upstate
New York." On August 17, 2009, VTel filed an application on FCC Form
175 (commonly referred to as a pre-auction "short-form" application)
to participate in Auction No. 86. Therein, VTel claimed status as a
small business entity and sought a 15 percent bidding credit on any
licenses for which it was the high bidder. Auction No. 86 was held
from October 27, 2009 to October 30, 2009. VTel was a successful
bidder for three BRS licenses.
4. On November 20, 2009, VTel filed its post-auction "long-form"
application on FCC Form 601. In VTel's Ownership Report, J. Michel
Guite was identified as an officer, director, and an owner of VTel.
The Ownership Report also identified Walter Hewlett as one of VTel's
controlling interest holders based on his status as an individual
major shareholder of the company and his role as Trustee of the Guite
Family Trust, another major shareholder in VTel. In its long-form
application, as initially filed, VTel represented that Walter Hewlett
had no gross revenues for each of the three years preceding the
auction (2006, 2007, and 2008). Thereafter, staff from the Wireless
Telecommunications Bureau ("WTB"), the bureau responsible for
processing VTel's auction-related filings, contacted VTel and inquired
further about its ownership structure. In response, VTel twice amended
its long-form application - on February 18 and April 23, 2010 - each
time affirmatively representing Walter Hewlett's gross revenues as
zero.
5. While processing VTel's application materials, WTB staff asked VTel
whether Walter Hewlett was related in any way to the Hewletts of the
Hewlett-Packard Corporation family. VTel's counsel at the time
confirmed that Mr. Hewlett was so related. Given that the
Hewlett-Packard Corporation is a large, multi-national company with
considerable revenues, WTB staff requested that VTel verify the extent
of Mr. Hewlett's revenues during the relevant three-year period. On
August 9, 2010, VTel filed a third amendment to its long-form
application, disclosing for the first time to the Commission that Mr.
Hewlett's had substantial gross revenues for each of the three
relevant years.
6. The disclosure of Mr. Hewlett's revenues during the relevant
three-year period did not adversely affect VTel's entitlement to a
small business bidding credit. Accordingly, on May 19, 2011, WTB
granted VTel's long-form application, as amended. WTB then referred
the matter of VTel's conduct in Auction No. 86 to the Enforcement
Bureau ("EB") for investigation. On May 26, 2011, EB commenced an
investigation by sending a letter of inquiry ("LOI") to VTel
requesting information and documents about Mr. Hewlett's gross
revenues. VTel filed its response on June 27, 2011.
III. DISCUSSION
7. Under section 503(b)(1) 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. 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. The legislative
history to section 312(f)(1) of the Act clarifies that this definition
of willful applies to both sections 312 and 503(b) of the Act and the
Commission has so interpreted the term in the section 503(b) context.
The Commission may also assess a forfeiture for violations that are
merely repeated, and not willful. "Repeated" means that the act was
committed or omitted more than once, or lasts more than one day. To
impose such a forfeiture penalty, the Commission must first issue a
notice of apparent liability and the person against whom the 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, based on the evidence, that the person
has violated the Act, a Rule, or a Commission Order.
8. Section 1.17 of the Rules states that no person may provide, in any
written statement of fact, "material factual information that is
incorrect or omit material information that is necessary to prevent
any material factual statement that is made from being incorrect or
misleading without a reasonable basis for believing that any such
material factual statement is correct and not misleading." In 2003,
the Commission expanded the scope of section 1.17 of the Rules to
include written statements that are made without a reasonable basis
for believing the statement is correct and not misleading. At that
time, the Commission explained that this requirement was intended to
more clearly articulate the obligations of persons dealing with the
Commission, ensure that they exercise due diligence in preparing
written submissions, and enhance the effectiveness of the Commission's
enforcement efforts. Thus, even in the absence of an intent to
deceive, a false statement provided without a reasonable basis for
believing that the statement is correct and not misleading constitutes
an actionable violation of section 1.17 of the Rules.
9. In its LOI Response, VTel maintains that it had a reasonable basis for
believing that Mr. Hewlett had no reportable gross revenues during the
relevant three year period because it relied on advice of counsel.
Specifically, VTel contends that it was advised by counsel that the
FCC "was seeking information regarding relationships with other
entities that may be guiding or directly or indirectly controlling
VTel to determine if VTel was actually representing larger entities -
e.g., AT&T, Comcast, a private equity or other investment fund, or a
telecommunications manufacturer - in seeking a bidding credit in
Auction No. 86." VTel also argues that no unjust enrichment occurred
because Mr. Hewlett's revenues, even after they were disclosed, had no
adverse impact on VTel's entitlement to a small business bidding
credit. These arguments lack merit. First, the Commission's designated
entity rules require applicants to disclose revenues from all sources,
without qualification, during the relevant time frame. There are no
qualitative exceptions of the kind on which VTel claims to have
relied. Second, WTB issued a pre- and post-auction Public Notice for
Auction No. 86 setting forth the information that applicants were
required to disclose in support of a claim of designated entity
status. Thus, VTel had additional advance and ample notice, beyond the
Commission's rules, of the auction-related reporting requirements.
Finally, VTel provided revenue information for Four Winds Farms, Inc.
(Four Winds) in its initial long-form application. Four Winds' average
gross revenues for the reported three year time period was $5,900. In
addition, it appears that Four Winds does not appear to have a
relationship with the other entities identified on the VTel long-form
application that may be guiding, or directly or indirectly controlling
VTel. Therefore, it appears that VTel did not consistently apply the
advice it says it received from its counsel. By having provided
information about Four Winds, VTel essentially undermines its argument
about the advice it received from counsel and its understanding of
what our rules required.
10. As the Commission has stated, parties must "use due diligence in
providing information that is correct and not misleading to the
Commission, including taking appropriate affirmative steps to
determine the truthfulness of what is being submitted. A failure to
exercise such reasonable diligence would mean that the party did not
have a reasonable basis for believing in the truthfulness of the
information." In this case, rather than failing to mention Mr. Hewlett
at all, VTel repeatedly included Mr. Hewlett and listed his revenues
as zero, even after several inquiries by WTB staff. The statements
provided by VTel were false, and VTel had no reasonable basis for
believing that the statements were correct and not misleading. We
conclude, therefore, that VTel made these statements in apparent
willful and repeated violation of section 1.17(a)(1) of the
Commission's Rules.
11. In addition, section 1.65 of the Rules provides that "[e]ach applicant
is responsible for the continuing accuracy and completeness of
information furnished in a pending application or in Commission
proceedings involving a pending application." Section 1.65 also
requires that applicants amend their applications within 30 days,
unless good cause is shown, of any substantial change in information
provided to the Commission.
12. In the instant case, VTel failed to maintain the continuing accuracy
of its pending long-form application, in apparent willful and repeated
violation of section 1.65. VTel initially filed its long-form
application in November 2009. In its long-form application, VTel
affirmatively represented to the Commission that Mr. Hewlett had no
gross revenues for each of the three relevant years. In addition, VTel
subsequently filed two amendments to its long-form application in
which it provided identical gross revenue information for Mr. Hewlett
that was later revealed to be inaccurate. In fact, it was not until
the Commission staff questioned the veracity of the information
because of Mr. Hewlett's familial relations that VTel finally
disclosed the extent of Mr. Hewlett's gross revenues, almost a full
year after the filing its long-form application. VTel was, at all
relevant times, required under section 1.65 to maintain the accuracy
of the information it provided to the Commission about the extent of
Mr. Hewlett's revenues, and EB's investigation reveals that on no
fewer than three separate and distinct occasions, VTel failed to do so
in its long-form application. VTel's derelictions in this matter are
significant because the Commission relied on the information provided
by VTel to assess the merits of the company's claimed entitlement to a
bidding credit. The fact that VTel remained qualified to receive the
bidding credit after subsequently attributing Mr. Hewlett's revenues
to VTel is of no consequence to EB's determination here that VTel
apparently willfully and repeatedly violated section 1.65 of the
Rules. Indeed, the relevant issue is that Mr. Hewlett's revenues could
have prevented VTel from obtaining a bidding credit, which in turn,
could have impacted the Auction No. 86 results. Thus, the Commission
was unable to determine both the actual amount owed by VTel, and
whether VTel was still entitled to the small business bidding credit,
until after Mr. Hewlett's full income was disclosed.
13. In determining the amount of a forfeiture penalty, section
503(b)(2)(E) of the Act and section 1.80(a)(4) of the Rules direct the
Commission to take into account "the nature, circumstances, extent,
and gravity of the violation . . . and the degree of culpability, any
history of prior offenses, ability to pay, and such other matters as
justice may require." Consistent with Commission precedent, we find
that a base forfeiture in the amount of $25,000 is appropriate for
VTel's violation of section 1.17 of the Rules. In addition, the
Commission's Forfeiture Policy Statement and implementing Rules
prescribe a base forfeiture of $3,000 for each failure to file
required forms or information. Accordingly, we find that the base
forfeiture of $3,000 is appropriate for each one of the three Form
601s that VTel submitted listing Mr. Hewlett's gross revenues as zero.
Therefore, we conclude that a proposed base forfeiture of $9,000
against VTel is warranted for VTel's repeated failure to file required
forms or information. Thus, based on the facts and circumstances
presented, we conclude that a proposed forfeiture of $34,000 against
VTel is warranted.
IV. ORDERING CLAUSES
14. Accordingly, IT IS ORDERED that, pursuant to section 503(b) of the
Communications Act of 1934, as amended, 47 U.S.C. S: 503(b), and
section 1.80 of the Commission's rules, 47 C.F.R. S: 1.80, that
Vermont Telephone Company, Inc. is hereby NOTIFIED of its APPARENT
LIABILITY FOR A FORFEITURE in the amount of $34,000 for willfully and
repeatedly violating sections 1.17 and 1.65 of the Commission's Rules.
15. IT IS FURTHER ORDERED THAT, pursuant to section 1.80 of the
Commission's Rules, within thirty days of the release date of this
Notice of Apparent Liability for Forfeiture, VTel SHALL PAY the full
amount of the proposed forfeiture or SHALL FILE a written statement
seeking reduction or cancellation of the proposed forfeiture.
16. Payment of the forfeiture must be made by check or similar instrument,
payable to the order of the Federal Communications Commission. The
payment must include the NAL/Acct. No. and FRN referenced above.
Payment by check or money order may be mailed to Federal
Communications Commission, P.O. Box 979088, St. Louis, MO 63197-9000.
Payment by overnight mail may be sent to U.S. Bank - Government
Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO
63101. Payment by wire transfer may be made to ABA Number 021030004,
receiving bank Federal Reserve Bank of New York, and account number
27000001. For payment by credit card, an FCC Form 159 (Remittance
Advice) must be submitted. When completing the FCC Form 159, enter
the NAL/Account number in block number 23A (call sign/other ID), and
enter the letters "FORF" in block number 24A (payment type code). VTel
will also send electronic notification within forty-eight (48) hours
of the date said payment is made to Terry.Cavanaugh@fcc.gov,
Gary.Schonman@fcc.gov and Pam.Slipakoff@fcc.gov.
17. The written statement seeking reduction or cancellation of the
proposed forfeitures, if any, must include a detailed factual
statement supported by appropriate documentation and affidavits
pursuant to sections 1.80(f)(3) and 1.16 of the Commission's rules.
The written statement must be mailed to Theresa Z. Cavanaugh, Acting
Chief, Investigations and Hearings Division, Enforcement Bureau,
Federal Communications Commission, 445 12th Street, S.W., Room 4-C330,
Washington, D.C. 20554 and must include the NAL/Acct. No. referenced
above. The written statement should also be emailed to Terry Cavanaugh
at Terry.Cavanaugh@fcc.gov, Gary Schonman at Gary.Schonman@fcc.gov and
Pam Slipakoff at Pam.Slipakoff@fcc.gov.
18. 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 (GAAP); 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.
19. Requests for payment of the full amount of this Notice of Apparent
Liability for Forfeiture under an installment plan should be sent to:
Chief Financial Officer -- Financial Operations, Federal
Communications Commission, 445 12th Street, S.W., Room 1-A625,
Washington, D.C. 20554. For answers to questions regarding payment
procedures, please contact the Financial Operations Group Help Desk at
1-877-480-3201 or Email: ARINQUIRIES@fcc.gov.
20. IT IS FURTHER ORDERED that a copy of this Notice of Apparent Liability
for Forfeiture shall be sent by certified mail, return receipt
requested, to counsel for VTel: Bennett L. Ross, Esq., Wiley Rein
LLP., 1776 K Street, N.W., Washington, D.C. 20006.
FEDERAL COMMUNICATIONS COMMISSION
P. Michele Ellison
Chief, Enforcement Bureau
47 C.F.R. S:S: 1.17, 1.65.
The spectrum associated with licenses auctioned in Auction No. 86 was
previously allocated and made available under the Multipoint Distribution
Services ("MDS") and Multichannel Multipoint Distribution Service
("MMDS"), the predecessor services to Broadband Radio Service ("BRS"). The
licenses offered in Auction No. 86 consisted of the available spectrum in
78 BRS service areas. BRS service areas are BTAs or additional service
areas similar to BTAs adopted by the Commission. See Auction of Broadband
Service (BRS) Licenses Scheduled for October 27, 2009, AU Docket No. 09-56
Notice and Filing Requirement, Minimum Up Front Payment, and Other
Procedure for Auction 86, Public Notice, 24 FCC Rcd 8277 (WTB 2009)
(Auction No. 86 June 26, 2009 Public Notice).
We note that VTel has now fully disclosed all information required under
our rules; as a result, this Notice of Apparent Liability addresses VTel's
initial failures to timely submit complete and accurate information.
See 47 C.F.R. S:S: 1.2110(f)(2)(iii), 27.1218; Auction No. 86 June 26,
2009 Public Notice, 24 FCC Rcd at 8296.
47 C.F.R. S:S: 1.2110(b)(1)(i), 1.2110(b)(3)(iv)(B). See also Order on
Reconsideration of the Third Report and Order, Fifth Report and Order, and
Fourth Further Notice of Proposed Rule Making, FCC 00-274, 15 FCC Rcd
15,293, 15323-27 (2000) (modified by Erratum, DA 00-2475, 15 FCC Rcd
24,501).
See http://www.vermontel.com/about.
Id.
See Form 175, File No. 0003937211 (filed Aug. 17, 2009).
Id.
See http://wireless.fcc.gov/services/index.htm?job=service_home&id=ebs_brs
("BRS formerly known as the Multipoint Distribution Service
(MDS)/Multichannel Multipoint Distribution Service (MMDS), is a commercial
service. In the past, it was generally used for the transmission of data
and video programming to subscribers using high-powered systems, also
known as wireless cable. However, over the years, the uses have evolved to
include digital two-way systems capable of providing high-speed,
high-capacity broadband service, including two-way Internet service via
cellularized communication systems. Such services provide consumers
integrated access to voice, high-speed data, video-on-demand, and
interactive delivery services from a wireless device.").
See Form 601, File No. 0004040603 (filed Nov. 20, 2009).
See Form 602, File No. 0003937211 (filed Mar. 31, 2009).
See id. VTel submitted an additional Ownership Report after the close of
Auction No. 86. See Form 602, File No. 0004129864 (filed Feb. 18, 2010).
See Amended Form 601, File No. 0004040603 (filed Feb. 18, 2010); Amended
Form 601, File No. 0004040603 (filed Apr. 23, 2010).
See Amended Form 601, File No. 0004040603 (filed Aug. 9, 2010). VTel
subsequently amended its long form two more times and further refined Mr.
Hewlett's gross revenues for 2007 and 2008.
Once Mr. Hewlett's gross revenues were included, VTel's total average
gross revenues were $28,369,000, $28,925,000 and $29,260,000 for 2006,
2007, and 2008, respectively. See Amended Form 601, File No. 0004040603
(filed Mar. 30, 2011). Thus, VTel's average revenues for the reported
years were $28,851,333.33, which was still under the $40,000,000 maximum
to be eligible for the small business bidding credit.
See Wireless Telecommunications Bureau Grants Broadband Radio Service
Licenses, Report No. AUC-86 (Auction 86), Public Notice, 26 FCC Rcd 6990
(WTB 2011).
See Letter from Gary Schonman, Special Counsel, Investigations & Hearings
Division, Enforcement Bureau, FCC, to Dr. J. Michael Guite, Chairman,
Vermont Telephone Company, Inc., dated May 26, 2011 ("LOI").
See Letter from Bennett L. Ross, Esq., Wiley Rein, Counsel for Vermont
Telephone Company, to Pam Slipakoff, Attorney Advisor, Investigations &
Hearings Division, Enforcement Bureau, FCC, dated June 27, 2011 ("LOI
Response").
47 U.S.C. S: 503(b)(1)(B); 47 C.F.R. S: 1.80(a)(1); see also 47 U.S.C. S:
503(b)(1)(D) (forfeitures for violation of 14 U.S.C. S: 1464).
47 U.S.C. S: 312(f)(1).
H.R. Rep. No. 97-765, 97th Cong. 2d Sess. 51 (1982).
See, e.g., Application for Review of Southern California Broadcasting Co.,
Memorandum Opinion and Order, 6 FCC Rcd 4387, 4388 (1991) ("Southern
California Broadcasting Co.").
See, e.g., Callais Cablevision, Inc., Grand Isle, Louisiana, Notice of
Apparent Liability for Monetary Forfeiture, 16 FCC Rcd 1359, 1362, P: 10
(2001) ("Callais Cablevision") (issuing a Notice of Apparent Liability
for, inter alia, a cable television operator's repeated signal leakage).
Southern California Broadcasting Co., 6 FCC Rcd at 4388, P: 5; Callais
Cablevision, Inc., 16 FCC Rcd at 1362, P: 9.
47 U.S.C. S: 503(b); 47 C.F.R. S: 1.80(f).
See, e.g., SBC Communications, Inc., Apparent Liability for Forfeiture,
Forfeiture Order, 17 FCC Rcd 7589, 7591, P: 4 (2002) (forfeiture paid).
47 C.F.R. S: 1.17(a)(2).
See Amendment of Section 1.17 of the Commission's Rules Concerning
Truthful Statements to the Commission, Report and Order, 18 FCC Rcd 4016,
4021 (2003), recon. denied, Memorandum Opinion and Order, 19 FCC Rcd 5790,
further recon. denied, Memorandum Opinion and Order, 20 FCC Rcd 1250
(2004) ("Amendment of Section 1.17").
Id.
See id. at 4017 (stating that the revision to Section 1.17 of the Rules is
intended to "prohibit incorrect statements of omissions that are the
results of negligence, as well as an intent to deceive").
See LOI Response at 2.
Id.
See Id. at 1.
47 C.F.R. S: 1.2110(b).
See Auction No. 86 June 26, 2009 Public Notice, 25 FCC Rcd 8277, 8297-99,
8323-24; Auction of Broadband Radio Service Licenses Closes Winning Bidder
Announced for Auction 86, Public Notice, 24 FCC Rcd 13572, Attachment E
(WTB 2009)
See Form 601, File No. 0004040603 (filed Nov. 20, 2009).
See id.
See Cricket Communications, Inc., Order and Notice of Apparent Liability
for Forfeiture, 26 FCC Rcd 989, 991 (Enf. Bur 2011) ("Cricket
Communications")
Amendment of Section 1.17, 18 FCC Rcd at 4021; Cricket Communications,
Inc., 26 FCC Rcd at 991.
47 C.F.R. 1.17(a)(1); See, e.g Cricket Communications, Inc., 26 FCC Rcd at
992.
47 C.F.R. S: 1.65(a).
See 47 C.F.R. S: 1.65.
See Form 601, File No. 0004040603 (filed Nov. 20, 2009).
See Amended Form 601, File No. 0004040603 (filed Feb. 18, 2010); Amended
Form 601, File No. 0004040603 (filed Apr. 23, 2010).
See Form 601, File No. 0004040603 (filed Nov. 20, 2009); Amended Form 601;
Amended Form 601, File No. 0004040603 (filed Feb. 18, 2010); and Amended
Form 601, File No. 0004040603 (filed Apr. 23, 2010).
The Commission's small business bidding credits are designed to enhance
access to telecommunications services by encouraging broad participation
in the provision of spectrum-based services and ensuring that
spectrum-based services are available to a wide range of consumers. See
Implementation of Section 309(j) of the Communications Act - Competitive
Bidding, Second Report and Order, PP Docket No. 93-253, 9 FCC Rcd
2348, 2350 Para. 6 (1993). They also implement Congress' directive to
"promot[e] economic opportunity and competition and ensur[e] that new and
innovative technologies are readily available to the American people by
avoiding excessive concentration of licenses and by disseminating licenses
among a wide variety of applicants, including small businesses..." See 47
U.S.C. Sec. 309(j)(3)(B).
47 U.S.C. S: 503(b)(2)(E).
47 C.F.R. S: 1.80(a)(4).
See, e.g Cricket Communications, Inc., 26 FCC Rcd at 993-94 (proposing a
$20,000 forfeiture for Cricket's failure to file the correct construction
date for station WQJE535. The proposed forfeiture reflects a downward
adjustment from $25,000 as a result of Cricket's voluntary disclosures to
Commission staff); Cardinal Broadband LLC, Notice of Apparent Liability
for Forfeiture, 23 FCC Rcd 12233 (Enf. Bur. 2008) (proposing a $25,000
forfeiture against an interconnected VoIP provider and common carrier for
its violation of 1.17(a)(2) of the Commission's Rules).
See 47 C.F.R. S: 1.80; Forfeiture Policy Statement, 12 FCC Rcd 17087,
17113 (1997).
See 47 C.F.R. S:S: 1.17, 1.65(a).
See 47 C.F.R. S: 1.1914.
See 47 C.F.R. S:S: 1.80(f)(3), 1.16.
See 47 C.F.R. S: 1.1914.
Federal Communications Commission DA 11-1536
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Federal Communications Commission DA 11-1536