NTCA suggestions for FCC non-IP SHAKEN inquiry

NTCA – The Rural Broadband Association representative Brian Ford met with FCC staff to suggest improvements for the draft Notice of Inquiry (NOI) on non-IP call authentication. The Commission will discuss this NOI during their October open meeting. Here’s a recap of the NTCA’s suggested improvements.

In recent meetings with FCC staff, Mr. Ford made the following points related to the NOI:

1. The Commission faces a binary choice to fulfill its goal for widespread call authentication, either:
   1. Adopt non-IP call authentication standards, or
   2. Ensure effective IP interconnections across all voice networks.
2. The mere possibility of options for IP voice traffic exchange does not mean that they are effective options. Proposed options should be vetted for affordability and quality of service.
3. The Commission should ask if there are any existing rules that stand in the way of IP transition or any rules that the Commission could adopt to facilitate the transition.
4. Parties that raised security concerns with Out-of-Band should be specific. What are these concerns? Why would the ATIS NIPCA publish final standards without resolving such concerns?
5. The statement in the draft NOI that some commenters argue that industry lacks consensus on either of the non-IP standards misses the mark. After nearly two years of discussion, the standards were finalized and published, which indicates industry consensus.
   • Do parties’ objections stem from technical feasibility concerns or rather from a simple desire to avoid the costs of implementation?
6. In addition to asking about the range of costs to implement non-IP standards, the Commission should ask whether these costs can be avoided if the Commission adopts rules to facilitate IP transition.

Here’s one of the NTCA ex parte notices, which you can read for further information. We urge you to check this out to see how they framed these issues.

Our thoughts

We agree with the NTCA in raising these issues and for suggesting improvements to the NOI.

We are supportive of efforts to complete the IP transition. If we could wave a magic wand and, Poof!, the voice call network is all-IP, we’d do that in a heartbeat.

However, we are also realists. There are significant hurdles to overcome to facilitate this transition, including:

• Intercarrier compensation, meet points, transport costs
• Cost of replacing equipment
• Operational planning to manage and execute the transition while continuing to provide service.

These issues have slowed the transition to a crawl. If there were easy answers to these problems, where have they been hiding all this time?

The non-IP SHAKEN methods were developed, and standards were finalized and approved, in recognition of these hurdles and the slow pace of the IP transition. Industry and technical experts wouldn’t have spent all that time and effort if completion of the IP transition was imminent.

We’ve observed that some industry stakeholders have repeatedly made energetic efforts to slow down the IP transition and stall the adoption of non-IP SHAKEN extensions. Seems like they believe that it’s in their best interests to keep things as they are indefinitely.

If one wanted to slow things down, why not propose that we pause to figure out a solution to the IP transition problem. Perfect! That could drag on for years.

Meanwhile, subscribers continue to be bombarded with illegal robocalls, and piecemeal SHAKEN deployment is of little help in strengthening call analytics for robocall prevention.

It will be interesting to see if the Commission takes the NTCA’s suggestions on board.

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