In response to the July 17 FCC Further Notice of Proposed Rulemaking on combating illegal and unwanted robocalls, WTA filed comments stating that the key to the resolution of many of the robocall blocking issues raised in this proceeding “is the development and implementation as soon as possible of an efficient, effective and economic alternative caller ID authentication framework for calls originating on the forty percent or more of the voice service network where STIR/SHAKEN does not work due to the lack of a call path that is entirely IP from end-to-end.”

In addition to urging acceleration of the completion, approval and deployment of a cost- effective complement to STIR/SHAKEN, WTA:

  • opposes the blocking of alleged robocalls solely on the basis of caller ID authentication, at least until a STIR/SHAKEN alternative for non- all-IP call paths is in place;
  • opposes the blocking of alleged robocalls by intermediate voice service providers that have no relationship to the called parties who have the right to opt out of the blocking process;
  • supports a calling party verification process that begins with contacting the terminating voice service provider that is blocking calls;
  • requests further clarification of the ‘effective robocall mitigation programs’ contemplated by the Commission and seeks clear legal authority (such as warrants, subpoenas and safe harbors) to protect cooperating and participating service providers from legal liability for their blocking efforts;
  • suggests that the Commission develop a rapid response team to deal with fraudulent robocallers that cannot effectively be identified and deterred by formal processes;
  • requests that the Traceback Consortium be delegated specific powers as a Commission agent and that traceback requirements be limited to reasonable best efforts rather than being open-ended and subject to excessive effort and expense;
  • requests specific Commission-prescribed steps for dealing with bad traffic from both existing and new customers;
  • opposes network-based robocall blocking that would eliminate the right and ability of customers to opt out of the blocking of robocalls calls to them;
  • requests that notification and dispute resolution periods established for redress procedures take into consideration the small staffs of Rural LECs and other small voice service providers, and at least specify longer periods for small providers; and
  • opposes requirements for the periodic provision of free blocked call lists to requesting customers.