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Federal Register / Vol. 86, No. 109 / Wednesday, June 9, 2021 / Proposed Rules
providers. We seek comment on this view.
15. We specifically propose shortening the extension for small voice service providers that originate an especially large amount of traffic, and we seek comment on this proposal. We believe such providers are more likely to originate unlawful robocalls because, to originate large-scale robocall campaigns, it is necessary to originate a large number of calls. Further, we anticipate that rapid STIR/SHAKEN
implementation by those small voice service providers that originate the most traffic is likely to be more beneficial than faster implementation by small voice service providers that originate fewer calls because providers that originate more traffic will authenticate more calls. In addition, in our preliminary view it is appropriate to tailor our alteration of the extension as narrowly as possible to those small voice service providers most likely to originate unlawful robocalls to avoid unnecessarily burdening small providers. We seek comment on this initial analysis. Are there additional reasons to curtail the extension specifically for small voice service providers that originate an especially large amount of traffic? Are there reasons that shortening the extension for this specific subset of small voice service providers would be especially harmful? Should we curtail the extension for different or additional subsets of small voice service providers?
16. To what degree would hastening STIR/SHAKEN implementation reduce unlawful robocalls, and how much would Americans benefit? When the Commission adopted the STIR/SHAKEN
implementation mandate, it estimated the benefits would exceed $13.5 billion per year and noted a host of specific benefits to consumers, providers, and the government. The data above indicate that much of this benefit will not be realized if the subset of small voice service providers that are most likely to originate robocalls does not implement STIR/SHAKEN. We believe that such a significant public benefit justifies shortening the extension for this subset of small voice service providers under the TRACED Acts balancing test. We seek comment on the size of the benefit that will result from shortening the extension for such providers and our conclusion that the benefit justifies a shortened extension pursuant to the TRACED Act. We note that several third-party robocall monitoring and protection services believe there will be a substantial benefit to accelerating small voice service providers STIR/
SHAKEN implementation. For example,
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in its March 2021 report, Transaction Network Services argues that, given their disproportionate role originating robocalls, small voice service providers need to implement STIR/SHAKEN for the Commissions rules to have a significant impact. Similarly, Robokiller, a spam call and protection service, concluded in a February 2021
report that because smaller carriers have exemptions lasting . . . until 2023
. . . without a unified front from all carriers, STIR/SHAKEN cannot be completely effective. We seek comment on these assertions.
17. We also seek comment on the burdens and barriers of implementing STIR/SHAKEN for the subset of small voice service providers for which we propose shortening the extension. Do these small voice service providers face less hardship to implement STIR/
SHAKEN than other small voice service providers? Have implementation costs declined as more providers and vendors develop solutions to meet our June 30, 2021 deadline for larger voice service providers? Is accelerated implementation feasible? Are many small voice service providers already implementing STIR/SHAKEN even though the deadline is not until June 30, 2023? As of April 2021, 154 providers have obtained certificates from the Secure Telephone Identity Governance Authority STIGA, allowing them to participate in the exchange of authenticated traffic with other providers. Does this number of providers with certificates suggest that some small voice service providers have begun the process of STIR/SHAKEN
implementation? From 20142018, providers that make the initial longdistance call path choice for more than 100,000 domestic retail subscriber lines were obligated to file rural call completion reports, and 55 providers filed such reports in 2017, implying that approximately 100 providers with fewer than 100,000 lines have already obtained certificates from the STIGA.
To what extent did small voice service providers rely on a two-year extension in planning their network costs, and would shortening the extension unduly harm their reliance interests? Should we permit the full two year extension for any voice service provider in the subset who can document substantial reliance?
What specific actions might qualify as reliance that should factor into our decision? We anticipate that reliance interests may be minimal because small voice service providers were put on notice that we might revisit USTelecoms proposal at a later time, and we seek comment on this opinion.

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Do any identified burdens outweigh the benefits associated with requiring a subset of small voice service providers that is particularly likely to originate unlawful robocalls to implement STIR/
SHAKEN more rapidly?
18. What costs would small voice service providers generally, and those specifically that originate an especially large amount of traffic, incur by accelerating their deployment to meet a deadline prior to June 30, 2023?
USTelecom argues that small voice service providers that originate a disproportionate amount of traffic are unlikely to have the same resource constraints the Commission cited in adopting the two-year small voice service provider extension. We seek comment on this assertion. For example, do small voice service providers that originate an especially large amount of traffic have equipment that is generally newer and able to handle greater traffic volumes and, therefore, will likely require fewer resources to implement STIR/SHAKEN? Are their networks more streamlined and therefore do not require the time and effort to implement STIR/SHAKEN across multiple IP
architectures? Would such providers spread their STIR/SHAKEN
implementation costs over fewer pieces of equipment per dollar of revenue?
19. We propose curtailing only the small voice service provider extension for entities that originate a substantial amount of traffic and not shortening or eliminating any other extensions that the Commission adopted. We seek comment on this proposal. In our preliminary view, this approach is appropriate because it avoids imposing burdens on this subset of small voice service providers greater than the burdens we impose on the largest voice service providers. The TRACED Act directs that we shall grant an extension to a voice service provider that materially relies on a non-IP
network and the extension must extend until a call authentication protocol has been developed for calls delivered over non-internet protocol networks and is reasonably available. Because we have not yet made such a finding, we cannot curtail the non-IP network extension.
C. Defining Small Voice Service Providers That are Most Likely To Be the Source of Unlawful Robocalls 20. We seek comment on how to define small voice service providers that originate an especially large amount of calls and thus are at heightened risk of being a source of unlawful robocalls. In considering possible definitions, we seek to identify one or more definitional prongs that most accurately identify, in
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