FCC PSAP Robocall FNPRM Gets Mixed Reaction

An FCC Further NPRM on curbing illegal robocalls to public safety answering points and improving the PSAP Do-Not-Call registry got mixed reaction from public safety organizations and industry in comments posted Thursday in docket 12-129 (see 2110010065). Commissioners approved the item in September. Comments were due Wednesday.

The extent of the problem "varies," said APCO, partly due to varying state laws. Autodialed calls “may constitute ten percent or more of total call volume” for some emergency call centers (ECCs), APCO said, saying PSAPs "should have discretion over which of its phone numbers should be included in the Do-Not-Call registry."

Require service providers to report how many autodialed calls are blocked, said APCO. Doing so "will provide a greater understanding of the efficacy of call blocking mechanisms." Let PSAPs include 10-digit phone numbers associated with their administrative lines in the registry, said Colorado’s Boulder Regional Emergency Telephone Service Authority (BRETSA).

Commenters disagreed whether providers should be required to block calls from autodialers to PSAP numbers in the registry. Service providers "are equipped to provide the call blocking function and safeguard sensitive ECC information," APCO said. BRETSA backed the proposal and said requiring autodialers to register their originating phone numbers and caller IDs with the commission would "enable service providers to prevent delivery of such calls to PSAP numbers" in the registry. The FCC didn’t comment Thursday.

NCTA disagreed, saying the proposed requirement would "at best ... be ineffective at protecting PSAPs" because it's "impossible for a voice provider to determine whether any particular call traversing its network was autodialed" under the Telephone Consumer Protection Act. The group suggested requiring voice providers to "block calls from numbers that callers affirmatively register" to the registry as "being used to place outbound autodialed calls."

It's "unlikely that the proposals ... would achieve their aim to better protect PSAPs from robocalls," said USTelecom, saying deployment of the proposed solution would be “extremely complex.” Providers "have no reliable way" to distinguish between legitimate calls using an autodialer from those using autodialing "for other purposes," USTelecom said, and they would need to "block every call made from the autodialer list to every registered PSAP number." Lumen agreed the proposal is "not feasible.” It “fails to mitigate the security risks of the original proposal since sensitive PSAP numbers would be distributed to a large community and, as a result, could still be compromised,” Lumen said.

The proposal "depends on the willingness of autodialers to register in the database" and raises security concerns, said ATIS. Requiring autodialers to identify themselves as such in the caller ID information would "allow PSAPs to block these calls more effectively" and alleviate many security concerns, ATIS said.

Using the reassigned numbers database "may encourage more participation from the autodialer community than the proposed registry because use of the RND would reduce autodialers’ potential TCPA liability,” ATIS said. USTelecom and Lumen backed using the RND. That “avoids the security issues triggered by turning over sensitive PSAP numbers to large numbers of third parties,” Lumen said.