FCC changes immediate call blocking notification order
The FCC changed the rules that require immediate notification of call blocking starting January 1, 2022. There’s a lot going on here. This article will give you a quick overview of the essential facts.
For those already familiar with the issue, here is the outcome:
- Voice service providers may use SIP 603, 607, 608, TDM ISUP 21 for immediate call blocking notification.
- SIP 603 was not in the original order, but it will be allowed as an interim measure, as many petitioners requested.
- Immediate notification must be sent for analytics-based blocking.
- The original rule required notification for all blocking.
- The deadline date of January 1, 2022 is still in effect.
- Petitioners had asked for a six-month delay.
How did we get here? It all started with the Fourth Report and Order, issued about a year ago…
Fourth Report and Order
The Fourth Report and Order on Advanced Methods to Target and Eliminate Unlawful Robocalls started this whole thing. It was adopted December 29, 2020 and ordered the following:
- Immediate notification of call blocking and transmission of such notifications by all providers in the call path
- Use of SIP 607 or 608 in an IP network, ISUP code 21 in a TDM network to provide these notifications
- Compliance deadline date of January 1, 2022
Petitions, arguments for and against the order
USTelecom filed a petition on May 6, 2021, seeking reconsideration and clarification. A flurry of filings ensued throughout the year advocating for and against the rules and petition.
USTelecom argued that providers would not be ready to issue SIP 607 and 608. So, they would have to stop blocking illegal robocalls. They urged the Commission to allow providers to use SIP 603 instead, and to allow more flexibility. They also argued that blocking notification should only be required for blocking because of analytics, and should not be required for blocking calls at the subscriber’s request, calls that use invalid or Do Not Originate (DNO) calling numbers, etc.
Advocates for the rules argued that an effective redress mechanism for potential errors in blocking is essential and required by the TRACED Act. They said SIP 603 does not provide enough information for effective redress. They urged the Commission to keep the SIP 607/608 requirement, but with a delayed effective date, perhaps six months.
On December 10, 2021, the Commission adopted new orders, clarifications, a further notice of proposed rulemaking, and a waiver order. There are three parts to this document:
- Order on Reconsideration changes and clarifies rules in the Fourth Report and Order.
- Sixth Further Notice of Proposed Rulemaking seeks comment on next steps and timing.
- Waiver Order is a procedural matter to allow voice service providers to use SIP 603, 607, and 608 until the effective date of the changes in the Order on Reconsideration.
Order on Reconsideration
Here are the highlights of this order:
- Allows the use of SIP 603 as an alternative to SIP 607 and 608.
- Denies the request for general flexibility.
- Dismisses the request to stay the deadline on January 1, 2022. Since providers can use SIP 603, they don’t need an extension.
- Grants the request that immediate notification is only required for calls blocked by analytics.
- Clarified the requirement that terminating service providers must provide, upon request, a list of calls blocked. This requirement is narrowed to only include calls blocked by analytics.
Sixth Further Notice of Proposed Rulemaking (FNPRM)
The Sixth FNPRM explains that the Commission still believes that the use of SIP 607 and 608 present the best long-term solution for immediate notification. The FCC asks for comment on this view and how to transition away from SIP 603 toward full implementation of SIP 607 and 608.
Note: we provided a brief explanation of SIP 607 and 608 in a recent blog post, Will call blocking notification happen on January 1?
The Waiver Order is a procedural matter to deal with the legalities of changing the rules so close to the deadline.
The Order on Reconsideration described above becomes effective 30 days after it’s published in the Federal Register. This leaves a gap between the effective date of the original rules versus the updated rules. So, the Waiver Order allows voice service providers to use SIP 603, 607, or 608 from January 1 until the effective date of the rule change.
(Follow up note: The Order on Reconsideration was published on December 30, 2021 and will become effective on January 31, 2022. The Waiver Order is in effect from January 1, 2022 to January 31, 2022.)
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