Week ending September 11, 2026

Reply comments on the KYUP FNPRM closed Tuesday, and the record that came in is not split the way these records usually split. The trade associations and the consumer groups disagree about almost everything, and they agree that the Secure Telephone Identity Governance Authority should not be the body deciding who gets to stay on the voice network. The STI-GA agrees too. Two days later the Commission circulated drafts for its September 30 meeting that open a blank-slate inquiry into the 911 framework and loosen the TCPA revocation rules.

Nobody wants the STI-GA to be the cop

The May 21 FNPRM (FCC 26-32) asked whether the STI-GA should evaluate SPC token holders that are “unlikely to comply” with STIR/SHAKEN. The answer came back no from every direction.

CTIA’s reply put the objection in antitrust terms: the proposal “raises antitrust considerations by placing an industry-led body in charge of making subjective determinations that could result in the exclusion of competitors from the voice network.” The STI-GA itself, filing through ATIS general counsel Thomas Goode, asked the Commission to “retain responsibility for investigating and enforcing its rules” and called the unlikely-to-comply proposal speculative. Goode also filed separately for ATIS’s IP-NNI Task Force and the Industry Numbering Committee, which is three filings from one general counsel in one afternoon on adjacent pieces of the same framework.

CTIA’s alternative is to move the fight to a different docket. It argued the Robocall Mitigation Database proceeding “presents the most promising opportunity for the FCC to strengthen gatekeeping of the domestic voice network,” more so than KYUP obligations, and tied robocall mitigation to the IP transition on the theory that closing TDM authentication gaps does more than new upstream duties would. USTelecom asked for flexible, risk-based obligations, industry-led best practices paired with a safe harbor, and enforcement turning “on culpability, not strict liability.”

The 49 state attorneys general drew a narrower line than the usual all-or-nothing. They support a safe harbor for providers making “objectively reasonabl[e] decisions to refuse or discontinue service” — protection for cutting someone off. They oppose a safe harbor for providers whose upstream partner merely holds an SPC token, because “such a safe harbor would erode accountability.” NCLC, the National Consumers League, EPIC and Consumer Action went further and asked for no safe harbors at all.

Somos proposed attaching the safe harbor to the call rather than to the relationship: “where a call arrives carrying a valid right-to-use credential for the number it presents, the provider handling that call should have a safe harbor from Commission enforcement of the KYUP requirements as to that call.” It covers credentialed calls and nothing else — traffic arriving on the same interconnection without one stays subject to KYUP in full. The case against a process-based harbor is that it “can only be evaluated after the fact, by reconstructing what the provider did,” and that “a provider that does nothing can describe what it did in the language of the practices.” Against the version the Commission floated, keyed to the upstream provider holding an SPC token, the objection is that it “leaves the provider holding nothing it can check.”

The filing also takes up TransUnion’s objection that carrying verification forward is “vet-once-trust-always,” agreeing with the diagnosis and rejecting the remedy: it asks that calls carry “a short-lived and revocable credential,” so that what arrives is “a current signal, not a record of a past vetting.” And it would attach the underlying obligation at number assignment, to assigning providers and Resp Orgs, because that “requires no private body to exercise discretion over who may participate” — the same objection CTIA and the STI-GA raised, routed to a different answer. (Disclosure: I am VP of Systems Engineering at Somos.)

ZipDX, as usual, went at it from the data side, arguing for signer reputation and quoting Verizon’s own reply back at the Commission: Verizon’s analytics engine “takes into account the data-determined reputation of each carrier signing calls.”

The relay providers showed up in the robocall docket

Tuesday’s filings also brought in a set of filers who do not normally appear in this docket. Sorenson and CaptionCall, Hamilton Relay, ClearCaptions and ZP Better Together all filed replies in 17-97 and 17-59, joined by InnoCaption in the opening round.

Their argument is that the attestation framework does not know what to do with relay traffic. Sorenson’s filing says the record “confirms that the current STIR/SHAKEN framework disadvantages TRS users, undermining functional equivalence,” and asks the Commission to let internet-based TRS providers with direct end-user relationships make binding attestation determinations, conveyed by delegate certificate. Hamilton, which provides TTY TRS, speech-to-speech and captioned telephone service over the PSTN, argued that for PSTN-TRS calls “a default A-level attestation directive may be the only workable way to preserve functional equivalence,” and that the Commission should not force “all relay providers into a single rule.” ClearCaptions lined up behind Hamilton, InnoCaption, Sorenson and ZP on the A-level point. ZP’s ask is narrower: keep VRS providers from being “unintentionally and unnecessarily swept into” the new obligations.

The concrete failure they are describing is a relay call getting downgraded, mislabeled as spam, or blocked downstream.

Somos answers that argument in a section of its reply on call retargeting, and treats a relay call as an instance of the general case rather than a special one. It grants Hamilton’s technical objection, which it summarizes as: carrying the inbound SIP header onto the outbound call would mean preserving the caller ID and attestation while changing the timestamp and terminating number, and that alteration would break the chain of trust on the PASSporT. Somos’s response is that this “is the reason the diversion extension exists.” Redirection is already specified — the “div” PASSporT extension in RFC 8946, and SHAKEN support for it in ATIS-1000085. The caller is authenticated for the number it presents; the party performing the redirection “signs a separate assertion recording that the destination number was changed and by whom,” and leaves the calling number alone, “because the calling number has not changed.” On that reading a div PASSporT “alters nothing,” so the original assertion survives the second leg. Somos takes Sorenson’s own point — that the components of an A-level attestation can be performed by different parties — as describing the same division of labor.

It is the only filing in the round that cites RFC 8946 or ATIS-1000085.

Interoperability testing splits the 911 record

Replies on the NG911 Second FNPRM (FCC 26-39) closed the same day in PS 21-479 and PS 13-75, and the split there is vendors and carriers against public safety.

The proposal would require NGCS and ESInet providers to test transfers of 911 traffic to facilities in at least two other states and with three “similar but different” providers chosen by a 911 Authority. Intrado said the record reflects broad agreement that a stand-alone testing requirement “would not yield meaningful results.” iCERT and NASNA, filing jointly, reframed the question: “the key question, however, is not whether interoperability should be tested; it is how the Commission can ensure that interoperability is actually implemented when requested by prepared 911 Authorities.” T-Mobile asked for a request-based framework and no fixed nationwide deadline.

The Public Safety Next Generation 9-1-1 Coalition, filing with APCO, wants a substantive interoperability requirement and a certification requirement, and argued that “further delay risks entrenching incompatibilities.” USTelecom and CTIA filed on the carrier side, and Verizon supplemented its Massachusetts NG911 waiver petition.

The accessibility organizations filed as a bloc on a different question. TDIforAccess, the National Association of the Deaf, Deaf Equality, the Hearing Loss Association of America, accesSOS, Deaf Seniors of America and the Rehabilitation Engineering Research Center on Technology for the Deaf and Hard of Hearing asked the Commission to “move from continued inquiry to real-world testing” on direct video calling to 911, with VRS kept as a fallback and relay-mediated communication explicitly not treated “as equivalent to direct ASL communication where a direct connection can be achieved.” Communication Service for the Deaf filed alongside them. Sorenson and TDIforAccess were filing in the robocall docket and the 911 docket on the same day, about the same underlying problem.

Eleven individual commenters also filed express comments in 21-479 without attachments.

Verizon backs AT&T’s forbearance proposal; INCOMPAS says ALIII is not ready

On Friday Verizon filed in 25-304 and 25-311 endorsing AT&T’s July 24 proposal to grant ILECs conditional forbearance from Section 251(c)(2) on a LATA-by-LATA basis, available where subtending carriers have an adequate IP-based alternative. Verizon also backed USTelecom’s Agreement-Less IP Interconnection using the Internet — ALIII — as “an efficient default mechanism for exchanging IP voice traffic over the internet on a bill-and-keep basis,” calling it a way to “eliminate the bilateral negotiation bottleneck for the industry’s long tail.” The forbearance ask is the interim: a path to retire TDM switches before ALIII is actually built.

A day earlier INCOMPAS had met with Commission staff, bringing Greg Rogers and Karina Bohorquez of Bandwidth, Jill Sandford of FirstLight Fiber and Bill Greenlaw of Sonic. Their reading of the July IP-transition workshops is that “ALIII remains conceptual and that the technical underpinnings are not mature enough to support a safe or competitively neutral transition.” They are pushing the National Transit Provider model instead. Both sides are arguing from the same workshop record and disagree about whether ALIII exists yet.

Honorable mentions

The Commission circulated the TCPA item for September 30 (FCC-CIRC 2609-05, CG 02-278). The Report and Order would let callers read a revocation request as applying “only to the specific category of informational robocalls to which the revocation was directed,” let callers “designate an exclusive means to revoke consent,” and loosen the financial-institution fraud-alert exemption. The FNPRM asks about requiring two-way texting so consumers can revoke by reply. It landed two days after the consumer groups and the state AGs asked for tighter rules in the docket next door.

The Enforcement Bureau cited Derycom Certification Services (DA-26-970) for falsely claiming US-based status to obtain Telecommunication Certification Body recognition. Derycom’s 99 percent owner is a Chinese citizen, and its Quality Manager, Managing Director and reviewers are in China; no mutual recognition agreement permits recognition of TCBs in China. Derycom is no longer recognized as a TCB.

The FTC settled with Humboldt Merchant Services for $12 million on Tuesday, with a permanent ban on processing for merchants at heightened risk of fraud — the second payment-processor screening case in a week, and the same intermediary-diligence question the FCC is asking about upstream voice providers.

Viaero Wireless petitioned for an extension in WC 18-89.

Looking ahead

CSRIC X holds its second meeting on Tuesday September 23 at FCC headquarters (DA-26-944). The September 30 open meeting carries both the 911 Notice of Inquiry and the TCPA item; the NOI opens PS Docket 26-197 with comments due November 16 and replies December 15, and it proposes to revisit the “911 scope” analysis used to decide which services fall inside the 911 framework at all — which is the question underneath the interoperability fight. Watch for ex partes in 17-97 and 17-59 now that the reply round has closed, and for whether the Commission takes CTIA’s invitation to move the gatekeeping question into the Robocall Mitigation Database proceeding in WC 24-213.