Commenters Say Wrong Moves by FCC on Call Authentication Could Slow IP Transition

Commissioners in April approved an NPRM (see 2504280038) addressing the issue and comments were due Wednesday in docket 17-97. In supporting a move to new rules, Chairman Brendan Carr described efforts to crack down on illegal robocalls as “game of Whac-A-Mole.” The commission tackles one challenge “and then another one pops up,” he said in April.

The NPRM’s proposed mandate that providers either implement non-IP call authentication within two years or convert their networks fully to IP “will actually divert resources from ongoing efforts to transition to IP,” CTIA warned. In proposing that carriers “either implement flawed non-IP call authentication standards or transition to fully IP networks in two years, the NPRM pushes providers toward the IP transition without accounting for the various complexities necessary to conduct the transition in a manner that does not impact connectivity and support for crucial legacy services,” CTIA said.

The Competitive Carriers Association also raised concerns. “A requirement that applies to every provider regardless of size, resources, or network circumstances would be overly burdensome, risk diverting critical resources away from the ongoing transition to all-IP networks, and fail to address the root causes of the IP authentication gap,” CCA said. Smaller carriers “face nearly insurmountable challenges in obtaining fair and reasonable TDM [time-division multiplexing] and IP interconnection terms from large LECs, which undermine both the IP transition and end-to-end non-IP call authentication efforts,” the group said.

A non-IP call authentication requirement would also “most likely involve the use of outside vendors for many CCA carriers, leading to costly vendor dependency and imposition of solutions that oftentimes require the loss of provider network autonomy,” which is “something that many providers wish to avoid,” CCA said. Carriers should instead invest in moving to IP-based networks, the group said.

USTelecom expressed concerns with several proposals in the NPRM, including for in-band and out-of-band authentication. Proposed rules “fall short of meeting both the Commission’s goals of protecting consumers from unlawful robocalls as well as unleashing the transition to IP” and won’t satisfy requirements in the Telephone Robocall Abuse Criminal Enforcement and Deterrence (Traced) Act, USTelecom said. Companies are developing alternate solutions, USTelecom explained. The group cited AT&T, which provides digital phone service via the AT&T mobile network or, where not available, via home broadband service. “This product allows customers to keep their current home phones, but smoothly transitions them to IP connection, allowing those calls to be authenticated under STIR/SHAKEN.”

NTCA said the FCC was right to address calls on non-IP networks. “It is not enough merely for a provider to upgrade its own network; for authentication and verification to be truly successful, consistent with the vision of the TRACED Act, the Commission must address the connections between networks as well,” NTCA said. For consumers, the consequences of a gap in caller ID authentication “are very real,” the group warned. “The absence of authentication information in the signaling of a call will increasingly cause such calls to be unanswered, at the very least, because they appear untrustworthy.”

The Cloud Communications Alliance and Incompas called on the FCC to require “TDM-in-the-middle” networks to move to IP by a given date. “Our member companies have expended substantial resources to implement STIR/SHAKEN on their IP networks,” the groups said. Those efforts are “effectively being squandered” by networks “that fail to undertake the work necessary to upgrade to IP.” Major providers that still operate TDM-based networks echo “the Commission’s own assessment that upgrading networks to IP is the most effective and efficient way to ensure end-to-end transmission of STIR/SHAKEN information,” the groups said.

NCTA said the continuing existence of TDM networks “prompted the Commission’s examination of non-IP call authentication standards.” The FCC “should continue to press ahead with the IP transition -- including by convening an industry working group to coordinate a process for completing that transition, specifically as it relates to network interconnection and traffic exchange,” cablers said. “Implementation of non-IP call authentication is an expensive band-aid solution that undermines the more important objective of completing the transition to a fully IP voice interconnection environment.”