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Federal Register / Vol. 86, No. 208 / Monday, November 1, 2021 / Proposed Rules used by callers making telephone solicitations rather than callers making autodialed calls. See 47 U.S.C. 227c. It might also include harmonizing the statutory monetary penalties associated with calling PSAP telephone numbers with those for violations of the TCPA.
Alternatively, could the Commission work in conjunction with public safety organizations or their representatives to utilize any existing or planned databases of public safety numbers, rather than creating a new registry, to satisfy our obligations under the statute?
If it is deemed not possible to implement section 6507 without creating significant new security risks to PSAPs, what should be done at that point?
25. Expanded Use of the Reassigned Numbers Database. Could the Commission expand use of the Commissions Reassigned Numbers Database RND as a means to prevent unwanted calls to PSAPs? The RND is designed to prevent a consumer from getting unwanted calls intended for someone who previously held their telephone number. Callers wishing to avail themselves of certain TCPA
liability safe harbor provisions can query the database to determine whether a telephone number may have been reassigned since the most recent date of consent so they can avoid calling consumers who do not want to receive the calls. See 47 CFR 64.1200m. To achieve its goal of avoiding robocalls to registered PSAP numbers, should the Commission expand the RND to include registered PSAP telephone numbers as well as reassigned telephone numbers, and require autodialer operators to query the RND before placing calls?
Would the inclusion of PSAP numbers, coupled with a requirement for autodialers to query the RND, effectively prevent unwanted calls to PSAPs?
Would this alternative adequately protect the security of the sensitive PSAP telephone numbers while fulfilling the statutory obligation to create a PSAP Do-Not-Call registry? The Commission notes that the cost to operate the RND is recovered through usage charges collected from callers that choose to use the database. Does such a fee-based database align with Congress intent in instructing the Commission to create the PSAP Do-Not-Call registry?
26. The Commission seeks comment on these and any other potential solutions that allow the Commission to protect registered PSAP numbers from unauthorized dissemination in a timely and cost-effective manner, while fulfilling Congress goal of stopping unwanted calls to PSAPs, including the costs and benefits of each approach.

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F. Other Security Threats to PSAPs 27. Cybersecurity events continue to affect the ability of PSAPs to respond to 911 calls, locate 911 callers, and dispatch assistance. How can the Commission aid in securing PSAPs against these types of attacks? As 911
services evolve, the ability to reach PSAPs by text, video, and data transmissions create additional vulnerabilities that may be exploited. As states and local jurisdictions have deployed text-to-911 capabilities, have PSAPs experienced attacks using text messaging as an attack vector? Have PSAPs transitioning to Next Generation 911 NG911 systems experienced an increase in such incidents? If so, are those risks specific to NG911s technical implementation? Can the proposed DoNot-Call registry for PSAPs mitigate risks associated with NG911 services?
Can solutions used to prevent cyberattacks through the PSAPs administrative broadband connections also prevent attacks through NG911?
What is needed to ensure NG911
communications with PSAPs are legitimate traffic?
28. In 2020, the Communications Security, Reliability, and Interoperability Council CSRIC
submitted a report to the Commission regarding security risks and best practices for mitigation in 911 systems.
See Communications Security, Reliability, And Interoperability Council VII, Report on Security Risks and Best Practices for Mitigation in 911 in Legacy, Transitional, and NG 911
Implementations September 16, 2020.
Is the report complete in its identification of security risks and best practices? What challenges, in addition to those discussed in the report, do PSAPs face in securing their operations?
Are there additional best practices that PSAPs should consider adopting? What steps should the Commission take to aid in implementing best practices for PSAPs or otherwise promote cybersecurity in the PSAP environment?
29. Should the Commission consider caller ID authentication methods such as STIR/SHAKEN as a means to enhance the security of PSAP operations or promote greater trust for calls to PSAPs and those associated with 911?
Providers using STIR/SHAKEN assign calls an attestation level that signifies what they know about the calling party and its right to use the number shown in the caller ID. Does STIR/SHAKEN
sufficiently mitigate the robocall threat to PSAPs by allowing service providers to screen illegitimate 911 calls, including 911 calls to PSAPs from callers seeking to disguise their phone
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number or location information, more effectively? Can PSAPs use existing analytics, such as caller ID
authentication, to help evaluate the trustworthiness of a call and caller? Do such analytics help PSAPs combat robocalling attacks better than a centralized database of PSAP numbers?
If not, could additional STIR/SHAKEN
standards, such as a unique attestation level, help distinguish between legitimate 911 calls and illegitimate calls from bad actors? Should the Commission encourage standards bodies to define such standards to be deployed by providers? Should such an attestation framework distinguish 911
calls originated by non-service initialized devices, which bypass the typical authorization conducted by originating providers, from serviceinitialized 911 calls? Can STIR/
SHAKEN standards account for this issue and ensure that PSAPs using caller ID authentication do not negatively impact legitimate calls? Are there other technology developments or regulatory changes that would be required to facilitate the use of caller ID
authentication technologies to support PSAP operations?
30. Digital Equity and Inclusion. The Commission, as part of its continuing effort to advance digital equity for all, including people of color, persons with disabilities, persons who live in rural or Tribal areas, and others who are or have been historically underserved, marginalized, or adversely affected by persistent poverty or inequality, invites comment on any equity-related considerations and benefits if any that may be associated with the proposals and issues discussed herein. See 47
U.S.C. 151; Executive Order No. 13985, published at 86 FR 7009, Executive Order on Advancing Racial Equity and Support for Underserved Communities Through the Federal Government January 20, 2021. Specifically, the Commission seeks comment on how its proposals may promote or inhibit advances in diversity, equity, inclusion, and accessibility, as well as the scope of the Commissions relevant legal authority.
Initial Regulatory Flexibility Analysis 31. As required by the Regulatory Flexibility Act of 1980, as amended RFA, the Commission has prepared the Initial Regulatory Flexibility Analysis IRFA of the possible significant economic impact on a substantial number of small entities by the policies and rules proposed in the FNPRM.
Written public comments are requested on the IRFA. Comments must be identified as responses to the IRFA and
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