PITTSBURGH, August 16, 2017 – The American Cable Association commended the Federal Communications Commission’s efforts designed to combat illegal robocalling but cautioned that the leading authentication solution for IP network telephone calls and accompanying standards have not been reviewed by small business providers to determine, among other things, technical feasibility and whether the costs are manageable.
“ACA supports the FCC’s goal to establish inclusive and comprehensive authentication standards that will protect customers from illegal robocallers. To do so most effectively, however, the FCC should take into account the role that small facilities-based VoIP providers play in the communications ecosystem, and minimize the challenges that such providers might face in implementing any new technical standards,” ACA President and CEO Matthew M. Polka said.
ACA’s Aug. 14 comments (attached) came in response to the FCC’s Notice of Inquiry (NOI) to further efforts with industry to combat the growing problem of illegal robocalling. The FCC sought comment on an authentication solution for IP network telephone calls, and in particular standards developed by Internet Engineering Task Force (IETF), Alliance for Telecommunications Industry Solutions (ATIS), and the SIP Forum, known as “SHAKEN/STIR,” that uses a digital certificate scheme to “verify and authenticate caller identification for calls carried over an Internet Protocol (IP) network based on the Session Initiation Protocol (SIP).”
Although ACA believes that the SHAKEN/STIR call authentication framework could serve as the foundation for an effective industry-led partial solution to the problem of illegal robocalls, small and mid-sized VoIP providers have not been involved in the development of the proposed authentication protocols, and thus cannot address key issues such as the technical feasibility of implementing the protocols or the potential costs involved.
Before taking any steps to endorse formally or adopt the SHAKEN/STIR framework, the FCC should seek broader industry input, including from small interconnected VoIP providers, to ensure that the SHAKEN/STIR standards are feasible and cost-effective for all facilities-based VoIP providers, ACA said.
This approach, ACA said, would allow the FCC the opportunity to examine and fully consider the costs and burdens that small providers may face in implementing this or other call authentication solutions, look for ways in which those costs can be mitigated, and could help the FCC establish an appropriate glide path for the implementation by smaller VoIP providers of any approved call authentication framework following implementation by larger VoIP providers.
Robocalling continues to menace consumers and frustrate technological interdiction. Despite more widely available call-blocking technology, and more robust FCC enforcement of abusive, illegal robocalling and call spoofing, U.S. consumers, some of them the voice customers of ACA member companies, are receiving more robocalls in 2017 than they did in 2016. Just last month, Americans reportedly received nearly 2.6 billion robocalls, as compared to 2.4 billion monthly robocalls in 2016.
ACA members take their customer service obligations seriously, which includes ensuring that their voice customers are not harassed or burdened by illegal and unwanted robocalls. Robocalling is a continuing problem for which there is no “silver bullet,” demanding multifaceted solutions and the concerted attention of all industry segments and regulators. That is why the ACA supports the FCC’s efforts to establish inclusive and comprehensive authentication standards that will protect customers from illegal robocallers.
About the American Cable Association: Based in Pittsburgh, the American Cable Association is a trade organization representing about 750 smaller and medium-sized, independent cable companies who provide broadband services for nearly 7 million cable subscribers primarily located in rural and smaller suburban markets across America. Through active participation in the regulatory and legislative process in Washington, D.C., ACA’s members work together to advance the interests of their customers and ensure the future competitiveness and viability of their business. For more information, visit http://www.americancable.org/