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'A Hobson's Choice'

Most Comments Oppose FCC Proposals for Closing Stir/Shaken 'Gap'

Industry groups pressed the FCC to avoid imposing new rules designed to close a “gap” in the commission’s Stir/Shaken authentication rules, making it harder for scammers to hide their identities. Some said the wrong rules could slow the IP transition. Commissioners in April approved an NPRM (see 2504280038) addressing the issue. Reply comments were due Friday in docket 17-97.

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Verizon warned of major barriers, “both practical and legal,” that make the FCC's proposed rules “unworkable for large providers.” Barriers include state rules requiring the continuing provision of time-division multiplexing-based legacy telephone service, which are “holding back the IP transition,” Verizon said. Mandating non-IP solutions would mean “major security flaws by which bad actors can hijack STIR/SHAKEN to more convincingly scam consumers or gain insight into customers’ private call data.”

Carriers would have to invest in aging TDM technology “with a short remaining life,” Verizon added. “Consumers will benefit far more if the Commission zooms out to focus overall on facilitating a swift and orderly nationwide transition to IP and removing impediments to that process.”

The FCC’s proposal to require providers to either implement a non-IP call authentication framework within two years or convert their networks fully to IP wouldn’t curb robocalls, CTIA said. The proposal “presents a Hobson’s Choice, with neither option ultimately furthering the Commission’s and CTIA’s shared goals of protecting consumers from illegal and unwanted robocalls and promoting the IP transition,” the wireless association said. “Commenters agree that this proposal would divert resources from ongoing efforts to transition to IP and would risk harming the existing protections in the voice ecosystem.”

USTelecom cautioned against proposals in the NPRM. These proposals, “particularly the mandate of specific in-band or out-of-band authentication technologies,” wouldn’t advance the FCC's goals of more reliable communications, USTelecom said. “Instead, they risk diverting resources away from more effective, scalable, and future-oriented solutions.” USTelecom added that “the lack of security associated with the proposed solutions … would undermine, rather than enhance, consumer protection.”

The Competitive Carriers Association said many commenters share its concerns about needing to avoid imposing “unduly burdensome costs on providers and … mandates that would have the effect of delaying the completion of the IP transition.”

In addition, CCA warned of problems smaller carriers face dealing with large LECs. “CCA echoes the issues previously presented by NTCA, detailing the difficulties that smaller providers face in the IP transition due to demands placed by larger providers” including “onerous terms and costs on smaller carriers for upstream TDM tandems.” CCA said it raised those issues in response to a 2022 notice of inquiry and “the issue has only gotten worse over the past three years.”

The Voice on the Net Coalition (VON) said the lack of a consensus means the FCC should adopt its proposal that the agency mandate that all voice service providers transition to IP networks by Dec. 31, 2028, “or two years after the effective date of rules adopted in this proceeding, whichever is later.” Absent that, “the full benefits of the STIR/SHAKEN approach will remain unrealized,” VON said. Moving to all-IP networks “was the FCC's original goal when it established STIR/SHAKEN implementation requirements, and should continue to be, because that is the best way to secure all networks, reduce illegal robocalls and provide cost savings for those providers who have spent significant resources deploying IP networks,” the coalition said.

But WTA, which represents small providers, questioned whether the FCC can avoid allowing providers to opt for a non-IP framework. Given the Telephone Robocall Abuse Criminal Enforcement and Deterrence (Traced) Act’s “explicit recognition of the use of non-IP solutions, the Commission cannot simply mandate that all carriers transition to IP networks,” WTA said.

Audioconference calling platform ZipDX said the FCC needs a better understanding of the market before moving forward on rules. “The Commission continues to operate with virtually no quantification of the scope of the problem, nor is there any specificity as to the magnitude of the contribution attributable to particular technical or regulatory issues,” ZipDX said. “This lack of data makes any rulemaking indefensible and must be addressed before the Commission can move forward.”

Meanwhile, an order designed to strengthen FCC caller ID authentication rules by authorizing the use of third parties in the authentication process will take effect Sept. 18, said a notice for Tuesday’s Federal Register. Commissioners approved the order in November (see 2411210006).