Agency Should Give Small Providers More Time To Deploy STIR/SHAKEN, Take Other Steps To Facilitate Their Participation
PITTSBURGH, May 18, 2019 – ACA Connects members are eager to deploy the STIR/SHAKEN call authentication protocol in their IP networks like the country’s largest voice providers, yet they will face considerable challenges in doing so on the exact same timeline. The FCC should adopt its proposed one-year implementation extension for small providers, and it should be prepared to extend the deadline further if circumstances warrant. The agency should also take further steps to enable small providers and their customers to reap the benefits of this technology.
ACA Connects made these points in comments filed with the agency on Friday, May 15. The trade association noted that it has actively participated in the industry’s work to get STIR/SHAKEN off the ground, and its members are eager to deploy the technology in their networks.
“STIR/SHAKEN is a powerful weapon to have in the arsenal in the industry’s fight against robocalls,” ACA Connects President and CEO Matthew M. Polka said. “The technology will build on steps our members are already taking, such as offering free blocking tools, to deliver their customers relief from the robocalls scourge.”
Yet we are still in the early stages of development of STIR/SHAKEN vendor solutions that are suitable and cost-effective for smaller providers, ACA Connects noted. Those larger ACA Connects members that have made progress implementing available solutions describe a time-consuming process to “work out the kinks” and ensure that the technology works compatibly with the provider’s existing network. There also remains uncertainty among smaller providers about the appropriate costs of vendor solutions and the relative advantages of various offerings.
The FCC has proposed giving smaller providers – those with 100,000 voice lines or fewer – an extra year, i.e., until June 30, 2022, to implement the STIR/SHAKEN.
“Under the circumstances, the FCC is justified in granting the extension and should do so without delay,” Polka said. “The FCC shouldn’t force smaller providers to make expensive decisions regarding emerging technologies in haste. In fact, it should be ready to go further, if needed. The FCC should review and decide within one year of the smaller provider deadline whether a further extension is warranted. This will ensure that small providers have adequate time to factor the FCC’s decision into their planning.”
In its comments, ACA Connects also observed that STIR/SHAKEN relies on end-to-end IP connectivity for voice calls, so the technology choices of one provider in a call path can affect the ability of others to deliver the benefits of STIR/SHAKEN to their customers. ACA Connects proposed measures the FCC can take to address the impact of these interdependencies on smaller providers.
First, ACA Connects proposed that IP voice providers be given an extra year from their STIR/SHAKEN implementation deadline to upgrade interconnection agreements so that IP voice traffic exchanged today in TDM is exchanged in IP, but only where such upgrades are “technically feasible.”
ACA Connects shared its hope that, during this period of delay, many of its members would be able to secure IP interconnection on reasonable terms in the open marketplace, but it recognized this may not be the case for all providers. Accordingly, ACA Connects suggested that the FCC may need to take steps to help providers participate in STIR/SHAKEN even where they exchange traffic in TDM, such as by pressuring the industry to implement “out of band STIR” or other workarounds.
Second, ACA Connects encouraged the FCC to require intermediate providers in the call path to pass through STIR/SHAKEN authentication information to the next provider. This mandate is necessary to avoid major gaps in the deployment of STIR/SHAKEN.
About ACA Connects: America’s Communications Association – Based in Pittsburgh, ACA Connects is a trade organization representing more than 700 smaller and medium-sized, independent companies that provide broadband, phone and video services to nearly 8 million customers primarily located in rural and smaller suburban markets across America. Through active participation in the regulatory and legislative process in Washington, D.C., ACA Connects’ members work together to advance the interests of their customers and ensure the future competitiveness and viability of their businesses. For more information, visit: http://www.ACAConnects.org