On September 28, 2023, the Wireline Competition Bureau (“Bureau”) released a Public Notice seeking comment for its annual reevaluation of the STIR/SHAKEN implementation extensions granted by the FCC on the basis of undue hardship for implementation of the STIR/SHAKEN caller ID authentication framework. The Notice seeks comment on the following extensions:
- The Extension for Small Satellite Providers Originating Calls Using NANP Numbers: The Notice seeks comment on the FCC’s extension for small voice service providers that originate calls via satellite using NANP numbers. The FCC concluded that an indefinite implementation extension was appropriate for such providers because the cost of satellite services makes the high-volume calling necessary for robocallers uneconomical, there was little evidence that satellite providers or their users were responsible for illegal robocalls, and the number of satellite subscribers using NANP resources was miniscule. The Notice seeks comment on the benefits, burdens, and barriers to STIR/SHAKEN implementation by these providers, whether the burdens and benefits have changed, whether there are any abuses likely to result from the extension, the impact the extension has on the FCC’s goal of ubiquitous deployment of STIR/SHAKEN, and if it is necessary for the extension to remain indefinite.
- Extension for Voice Service Providers That Cannot Obtain a SPC Token: The Notice seeks comment on the FCC’s extension for voice service providers that cannot obtain a SPC token. The FCC granted providers that are incapable of obtaining a SPC token due to Governance Authority policy an extension until they are capable of obtaining a token, which is necessary for STIR/SHAKEN participation. The policy was revised in May 2021, and the Bureau subsequently concluded that token access was no longer a significant barrier to full participation in STIR/SHAKEN, but nevertheless declined to revise the extension. In its March 2023 Sixth Caller ID Authentication Further Notice, the FCC sought comment on whether to eliminate the extension. The Notice seeks comment on whether to revise the extension, recommend to the FCC that the extension be terminated, and if so what the appropriate end date should be, whether there are remaining providers unable to obtain a token, whether there are new burdens on providers that cannot obtain a token, and how the FCC’s recent notice should inform or impact the Bureau’s review of the extension.
Comments are due on or before October 18, 2023.
Reply Comments are due on or before November 2, 2023.
Please Contact Us if you have any questions.