FCC Releases FNPRM on Shielding PSAPs From Robocalls

On October 1, 2021, the FCC released the Further Notice of Proposed Rulemaking (“FNPRM”) proposing and seeking comment on rules that would require voice service providers to block autodialed calls made to PSAP telephone numbers registered on the PSAP Do-Not-Call Registry (“Registry”), which was adopted at the September Open Meeting.  The FNPRM seeks comment on the following:

  • Its proposal to require voice service providers to block autodialed calls made to PSAP telephone numbers on the Registry.  Specifically, the FCC proposes to grant voice service providers access to the Registry, which contains both outbound autodialer telephone numbers and PSAP telephone numbers.  Voice service providers would then use the numbers in the Registry to block autodialed outbound calls that are made to registered PSAP numbers.  The FNPRM seeks comment on who should be the responsible voice service provider (i.e., originating, intermediate or terminating provider), whether to limit the blocking requirement only to non-emergency autodialed calls, how to prevent disclosure of registered numbers, how to prevent erroneous blocking, how to verify and update the registry, and what security risks are incumbent in the proposal, among other things.
  • The extent of the problem that the Registry is intended to address, such as the frequency of autodialer-initiated calls to PSAP telephone lines, the extent of the disruption, and what harms these calls are causing.
  • The seriousness of the security risks associated with housing registered PSAP telephone numbers in a centralized database and granting access to those numbers to callers purporting to need them to comply with rules, as was initially proposed in 2012.
  • Whether alternative solutions exist to address these problems, such as enhanced caller vetting or implementing improved data security requirements.  In addition, the FNPRM asks whether there are alternative technological and regulatory schemes that could be imposed, beyond the call blocking proposal, which would help address these concerns.
  • Whether there are additional security threats to PSAPs and how these threats can be addressed.

On September 9, 2021, the FCC released a Draft Further Notice of Proposed Rulemaking (“Draft FNPRM”). The following changes were made from the Draft FNPRM:

  • ¶ 38 – adding a request for comment on whether the FCC could expand use of the FCC’s Reassigned Numbers Database (“RND”) as a means to prevent unwanted calls to PSAPs.  The FCC proposes to add registered PSAP telephone numbers to the RND along with reassigned numbers and require autodialers to query the RND prior to placing any calls.  The FCC seeks comment on whether this would prevent unwanted calls to PSAPS, whether this better protects the security of sensitive PSAP numbers, and whether this aligns with Congress’s intent when it instructed the FCC to create a PSAP Do-Not-Call Registry.

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