On Friday, September 3, 2021, the Wireline Competition Bureau (“Bureau”) released a Public Notice that (1) seeks comment on STIR/SHAKEN undue hardship extensions, and (2) provides implementation verification certification filing instructions for the seven voice service providers that received a STIR/SHAKEN exemption.
STIR/SHAKEN Undue Hardship Extensions
The Commission granted three categorical extensions of the STIR/SHAKEN mandate based on undue hardship: (1) for small voice service providers who have 100,000 or fewer voice subscriber lines; (2) for voice service providers who were unable to obtain a Service Provider Code token necessary to participate in STIR/SHAKEN; and (3) for services scheduled for section 214 discontinuance as of June 30, 2021. The TRACED Act requires the Commission to annually assess burdens and barriers to implementation, to revise any prior extensions granted on the basis of hardship, explain why any such extensions remain necessary, and explain when the Commission expects to achieve full participation on caller ID authentication. In accordance with this mandate, the Bureau seeks comment on these three extensions, inquiring, among other things, whether the extension remains necessary, whether the extensions should be terminated or extended, whether subsequent Commission action has had an impact on the extensions, how the extension affects full participation, and how close various groups who have received an extension are to achieving full participation.
Note that the extension for portions of the network that rely on technology that cannot initiate, maintain, and terminate SIP calls was not granted on the basis of undue hardship and therefore is not included in this Public Notice.
Comments will be due 30 days after publication in the Federal Register.
Reply comments will be due 45 days after publication in the Federal Register.
Implementation Verification Certificates
The Commission also allowed providers to seek exemptions on the basis of their ability to implement STIR/SHAKEN, one for IP networks and one for non-IP networks, provided that the provider could demonstrate early implementation progress by December 30, 2021. Seven providers sought and were granted exemptions for their IP networks: AT&T Service Inc. (AT&T), Bandwidth Inc. (Bandwidth), Charter Communications, Inc. (Charter), Comcast Cable Communications, LLC (Comcast), Cox Communications, Inc. (Cox), Cellco Partnership, d/b/a Verizon Wireless (Verizon Wireless), and Vonage Holding Corp. (Vonage). In order to maintain this exemption, these providers must submit a certification, signed by an officer, stating that the company did in fact complete all necessary network upgrades to its network infrastructure by June 30, 2021. In addition, the company is required to submit an accompanying statement that explains in detail how the company achieved its implementation goals so the Commission can verify the accuracy of the certification. These certifications must be filed on or before October 4, 2021.
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