Joint Trades' Comment on USTelecom's Petition re: Call Blocking

INTRODUCTION AND SUMMARY

The Associations appreciate the opportunity to comment on the Petition for Reconsideration and Request for Clarification (Petition) submitted by USTelecom – The Broadband Coalition (USTelecom) in the above-captioned proceeding. In its Fourth Report and Order, the Federal Communications Commission (Commission) required telephone companies that block calls and their analytics engines (collectively, Voice Service Providers or Providers) to use specific Session Initiation Protocol (SIP) codes to notify the caller that its call has been blocked on an Internet Protocol (IP) network and a specific Integrated Services Digital Network User Part (ISUP) code to notify the caller that its call has been blocked on a time-division multiplexing (TDM) network. In the Petition, USTelecom requests that the Commission give Voice Service Providers the “flexibility to select the appropriate code or tool to notify callers that their calls have been blocked,” among other requests.

Consumers are harmed when lawful calls placed by the companies with whom they do business are blocked. These calls include, for example, safety alerts, fraud alerts, data security breach notifications, product safety recall notices, healthcare and prescription reminders, power outage updates, and other necessary account updates and reminders needed to maintain financial health and well-being.

For these reasons, Congress expressly required in the TRACED Act that the Commission “ensure [that] robocall blocking services . . . are provided with transparency and effective redress options for . . . callers.” Consistent with its mandate to provide “effective” redress, the Commission required Voice Service Providers to notify a caller immediately when its call has been blocked utilizing notification mechanisms specifically designed to address the call blocking that the Commission has authorized.

Although we appreciate the good-faith efforts of Voice Service Providers to design systems to provide notification of blocking, we oppose USTelecom’s request to eliminate the requirement to utilize the notification methods prescribed by the Commission. To ensure that notification is transparent and effective for callers, as required by the TRACED Act:

• The Commission should continue to require Voice Service Providers to use SIP Codes 607 and 608, and ISUP Code 21.
• Should the Commission conclude that Voice Service Providers need additional time to implement the SIP Codes and map them to ISUP Code 21, the Commission should identify one or more alternative standardized notification mechanisms that may be used pending implementation of the SIP Codes. The alternative mechanism should provide immediate notification and inform the caller which entity is blocking the call.

ARGUMENT

I. THE COMMISSION SHOULD CONTINUE TO REQUIRE USE OF SIP CODE 607 OR 608 AND ISUP CODE 21

In the Fourth Report and Order, the Commission directed Voice Service Providers and other entities that block calls to notify callers when their calls are blocked, by utilizing specifications approved by the Internet Engineering Task Force (IETF), which is the leading Internet standards body. Specifically, the Commission required Providers, by January 1, 2022, to use SIP Code 607 or 608 (for blocking on IP networks) or ISUP Code 21 (for blocking on TDM networks) to provide immediate notification. In the Petition, USTelecom states that the standard on which the Commission relied to require use of SIP Code 607 or 608 or ISUP Code 21 “was not fully vetted and had not been approved by the IP-NNI task force” (the task force established to promulgate standards to allow Voice Service Providers to provide interconnection between their networks).

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