USTelecom Urges FCC to Reconsider Proposed Robocall Prevention Rules

On September 19, USTelecom – The Broadband Association (USTelecom), the main telecommunications industry organization, sent a letter to the Federal Communications Commission (FCC) expressing its concerns about proposed improvements to anti-robach calling regulations. USTelecom’s core contention is that the proposed regulations, which seek to expand the “do not transmit” (DNO) requirement, could unintentionally block legitimate communications, including emergency communications. The association argues that current industry practices already effectively block calls from invalid, unassigned and unused numbers, as well as numbers on the DNO list managed by the Industry Traceback Group (ITG) led by USTelecom.

The proposed rules described in the fact sheet would require all providers of a given call path to block calls based on a comprehensive list of DNOs. This list will include unused, unallocated and invalid numbers, as well as numbers that subscribers have requested to be blocked. Additionally, original wireless providers would be required to block text messages from sources deemed illegal by the FCC, and email-to-text services would only be allowed with opt-in. The proposed regulations include an $11,000 penalty for providers who fail to take “positive, effective measures to prevent new and renewing customers from using their networks to initiate illicit calls.”

USTelecom highlighted several specific issues, including the dynamic nature of number assignment, which can lead to the blocking of numbers that were previously unassigned but are now being used by legitimate callers. The association also cited potential problems with emergency call routing, citing real-world experiences in which calls to invalid “911” or “988” numbers experienced difficulty in routing.

In closing, USTelecom emphasizes that “flexibility allows providers to adapt to these scenarios in ways that broad authority would not,” urging the FCC to reconsider the proposed rules to avoid unintended consequences that could disrupt legitimate communications.