As we noted in a prior post,  on June 24, 2016, the Federal Communications Commission (Commission) adopted new mandatory network outage reporting requirements for submarine cable licensees.  The Commission’s Submarine Cable Network Outage Reporting Order (Order), released Tuesday, identifies Commission expectations and provides exact rule language for the reporting requirements which had been described at only a high-level during the Commission’s June Open Meeting.  The reporting requirements apply to all submarine cable licensees and will become effective six months after Office of Management and Budget (OMB) approval.  While the OMB approval process could extend for several months or more, affected submarine cable licensees should familiarize themselves with the reporting rules and begin developing internal mechanisms and procedures to ensure compliance once the rules become effective.

Continue Reading Details of Mandatory Network Outage Obligations for Submarine Cable Operators Released

World Global ConnectionsThe Federal Communications Commission (Commission) today adopted  mandatory network outage reporting requirements for submarine cable licensees less than a year after proposing to do so.  This mandatory reporting reflects a significant change from the voluntary submarine cable outage reporting system currently in place.  The new rules will apply to all submarine cable licensees, regardless

In August, the FCC adopted consent decrees with three companies (Border Media Business TrustTime Warner Cable, and ASUSTeK Computer Inc.) to resolve investigations into potential violations by each company of the Commission’s rules.  What makes these consent decrees noteworthy is the inclusion of new language and provisions not seen in settlements from prior years.  All three consent decrees include an admission of liability by the company and refer to the monetary payments the company will make as “civil fines” or “civil penalties” rather than “voluntary contributions.”  These changes may indicate a potentially significant shift in the Enforcement Bureau’s policy in resolving allegations of FCC rule violations.  If this indeed becomes Enforcement Bureau policy, it could make it significantly harder to resolve investigations through consent decrees, where often the primary benefit obtained by the regulated entity is a resolution without any findings of liability.
Continue Reading Do Recent Consent Decrees Indicate a Shift in FCC Enforcement Policy?

In several earlier posts, we informed you the FCC had adopted mandatory outage reporting regulations for both facilities-based and non-facilities-based interconnected Voice over Internet Protocol (VoIP) service providers.  The FCC has now established those rules will take effect before the end of the year.  For more details on the VoIP outage reporting regulations, see

This post was co-written by Randy Sifers.

In February, the FCC adopted new outage reporting rules for interconnected VoIP providers.  Our story and our advisory on the new rules are available at this link.  At the time, we told you that the rules would become effective 90 days after OMB approved the new

Randy Sifers contributed to this blog post.

On March 14, 2012, the FCC released two consent decrees settling investigations into Verizon’s and Verizon Wireless’s outage reporting practices. Collectively, the two affiliates will pay $200,000 to resolve a Notice of Apparent Liability for filing inaccurate outage reports and possibly other violations. The release of these two settlements confirms that the Enforcement Bureau views the filing of inaccurate or incomplete network outage reports, not just the failure to file outage reports, as significant violations of the Communications Act.

Continue Reading Verizon and Verizon Wireless Pay $200,000 to Settle Outage Reporting Investigations

As we’ve discussed, today the FCC adopted rules to require interconnected VoIP providers to report network outages to the FCC.  The text of the FCC’s order has not been released, but the order adopts a much narrower outage reporting requirement than originally proposed.  Under the new rules, interconnected VoIP providers will be required to report "hard" outages — inabilities to complete calls — that meet thresholds also applicable to traditional telecom services.  This decision continues the trend to treat interconnected VoIP the same as traditional TDM voice services, at least with respect to its obligations.

Continue Reading Interconnected VoIP Providers Required to Report Outages

VoIP providers, prepare to report outages to the FCC.  Since early in 2010, the FCC has been on a path to impose new outage reporting obligations on providers of interconnected VoIP services, despite industry opposition to the new requirements.  Today, the FCC released its "Sunshine Notice" confirming that it will vote on an order to adopt

Yesterday, the FCC held its "Workshop/Webinar" on the pending proposal to extend the outage reporting requirements to interconnected VoIP and to broadband service providers.  We’ve noted several times that the FCC staff appears to be in favor of extending these rules.  At yesterday’s workshop, two FCC Commissioners made statements that also signal their support.

Continue Reading Two FCC Commissioners Signal Support for Extension of Outage Reporting to VoIP

Interconnected VoIP provider Ooma suffered a three-hour outage late last week.  Ooma identified the cause of the outage as "an extremely rare power failure at a portion of our data center," but the effect of the outage may have a much broader impact.  The outage comes only two weeks after VoIP providers opposed extension of the FCC’s outage