Industry Clashes on Expanding Certain Robocall Rules

Give providers at least six months to determine and implement the best call blocking option available to them, said ACA Connects. Flexibility in analytics-based blocking would allow providers to adopt a solution that "can be implemented efficiently within its network and that serves the needs of its customer base," the group said.

A coalition of consumer advocates urged the commission to consider a market-based approach and provide legal callers with the "information that they need to keep their calls separate from illegal calls." Electronic Privacy Information Center, National Consumer Law Center, and Public Knowledge in joint comments also backed requiring terminating providers to offer analytics-based call blocking to consumers on an opt-out basis and blocking based on DNO lists.

"Implementation of a reasonable DNO list should take weeks, not months," said Somos. The company urged the commission not to delay its implementation. It also asked the commission to consider a DNO list that is "far more comprehensive" than the Industry Traceback Group's registry, adding the lists should be "updated in real-time, or at least every 24 hours."

USTelecom said the FCC should reaffirm its ITG registry as meeting the criteria of "reasonable" and "ignore one commenter’s suggestion to dramatically change what is expected in a DNO list." ITG's list "intentionally balances prioritizing the largest protective impact for consumers with the fact that some equipment and switches have limits to the quantity of numbers they can add to a DNO list," said USTelecom. The group also noted the record lacked support for mandates regarding caller ID or rich call data.

Rich call data is "the best solution to enable consumers to not only know that a number is verified, but that the calling entity is accurately identified," said Twilio. The company noted that it "enriches" data carrying Stir/Shaken attestation credentials to provide more details about a calling party. CTIA asked the FCC to acknowledge that rich call data and "other branded calling solutions" are "distinct call authentication technologies." The group emphasized the need to ensure know-your-customer practices are part of call authentication solutions, which Numeracle echoed in similar comments.

The FCC should "continue to accord providers significant room to label and block suspicious traffic using the methods they deem best for protecting their own networks and customers," said Verizon. The carrier noted that rich call data is at "an early stage of development" and industry has yet to establish best practices for its authentication. Verizon also agreed with some commenters that session initiation protocol code 603+ should be used to notify consumers of blocked calls. The National Opinion Research Center disagreed, saying it "fails to offer the same type of actionable information." NORC also noted that the record shows that a "mandatory use of the flawed standard for analytics would result in many important legal calls being blocked."

A "significant" number of calls continue to be mislabeled, said the Voice on the Net Coalition. The group sought guidance on when calls may be labeled and practices carriers must use to address inaccurate labeling. VON cited disagreement on which SIP code should be adopted, adding it backed the use of SIP code 608 because it has "proven to be highly effective for originating providers due to its ease of identification and integration."

The proposals are "premature and overly onerous to implement, particularly for small and rural carriers," said the Competitive Carriers Association. The group agreed with other commenters that providers are better able to protect their customers "using the technologies and tools that best suit their network configurations and operations." Don't mandate any additional call blocking requirements "until the commission settles on a notification mechanism and has mandated its use by a date certain," said Incompas.

"The FCC should not alter its course now" on combating unwanted or illegal robocalls, said Transaction Network Services: "If labeling was not functioning properly or effectively, the Commission surely would have heard from consumers and consumer groups." TNS argued that none of the proposals offers "a better path forward than maintaining the status quo of allowing the industry to develop improvements on its own."