August 23, 2019
In the Matter of:
Advanced Methods to Target and Eliminate Unlawful Robocalls, Call Authentication Trust Anchor
CG Docket No. 17-59 | WC Docket No. 17-97
USTelecom and its members are strongly committed to taking all possible steps to shield consumers from illegal robocalls.
There is strong support for providing voice service providers greater flexibility to address the problem of illegal and unwanted robocalls. To achieve the Commission’s objectives, a broad and robust safe harbor based on reasonable analytics should be established for voice service providers. The Commission should allow for continued industry-led implementation of SHAKEN/STIR, rather than an inflexible mandate.
To the extent that such a mandate is adopted, it must account for the limitations of a protocol designed for IP network for those voice service providers with TDM components in their networks. It should also consider flexibility for smaller voice service providers who may experience unique implementation challenges.
Finally, the Commission should spend more time evaluating the implementation of SHAKEN/STIR and call blocking tools before requiring the establishment of a Critical Calls List. However, if such a list is created, it should be centrally and securely maintained.