FCC e911 Violation Fines

According to Mark Wigfield, Press contact, FCC Wireline Competition Bureau, here are the FCC fines for e911 violations.

For common carriers, the Commission may impose \$130,000 per violation or per day of a continuing violation to a maximum of \$1.325 million for a continuing violation.

For cable operators, the Commission may impose \$32,500 per violation or per day of a continuing violation to a maximum of \$325,000 for a continuing violation.

For non-cable operators, non-common carriers, the Commission may impose \$11,000 per violation or per day of a continuing violation to a maximum of \$97,500 for a continuing violation.

Hmmm, the big boy carriers get the sitffest fine, followed by a smaller fine for their arch-rival cable companies (which are generally smaller). The fines slide a bit further down for non-carrier and non-cable operators, such as Vonage, Packet8, etc. My take - the bigger/larger of a VoIP player you are, the bigger the fine per violation. (Good thing they don't "scale" speeding fines by how big your car engine is. With a near 500cc, 450HP engine Viper I'd be bankrupt!)

According to Mark Wigfield, "The total amount can vary depending on whether the Commission decides there are multiple violations, and the Commission has some discretion to do that (i.e., perhaps one could argue that each customer that does not receive E911 from a provider represents a separate violation by the provider rather than viewing the provider's general failure to provide E911 capability as one violation)."

Well there's a vague answer! "...perhaps one could argue"? You mean to tell me the FCC doesn't even know what is considered a single violation? I always thought laws were black & white? Well, they should be anyway.

Here's a hypothetical. What if for some reason some area of the country's e911 fails and word leaks out to the media. Then as a prank, a bunch of teenagers or other pranksters decide to dial 911 on their home e911 number knowing that it won't go through but will result in a huge fine to the VoIP provider. I will assume the FCC made provisions to only find for "actual" real 911 calls, but you catch my drift. There may be many "grey areas" to these new FCC e911 regulations. Should be interesting to see who the first VoIP e911 violator is. Place your bets now.