FR 2021-03043

Summary of the Document

The document in question is a proposal from the Federal Communications Commission (FCC) concerning the oversight of certificate revocation decisions within the STIR/SHAKEN governance system. STIR/SHAKEN is a technology developed to prevent illegal robocalls by ensuring the authenticity of caller IDs. This proposed rule aims to give the FCC a supervisory role in situations where a voice service provider's certificate is revoked, putting them at risk of noncompliance with existing regulations. The document not only outlines procedures for service providers to appeal revocation decisions but also seeks public feedback on these proposed regulations.

Significant Issues and Concerns

One of the main challenges presented by the document is its use of complex legal language and references to multiple legislative acts, such as the TRACED Act and the Communications Act of 1934. This can potentially make it difficult for individuals without a legal or regulatory background to fully grasp the implications.

The document details a potentially burdensome process for filing comments and reply comments, which could benefit from simplification. Furthermore, while the proposed procedures for appealing Governance Authority decisions are thorough, they might be challenging for smaller entities to navigate due to their complexity.

Importantly, the document does not clearly assess the potential costs associated with the FCC's new oversight role, nor does it provide detailed information on how these changes might financially impact small businesses. By not addressing these aspects, there is a risk that small businesses could bear disproportionate burdens compared to larger organizations.

Impact on the Public

Broadly speaking, if implemented, these rules could increase the reliability of caller ID information, potentially reducing the number of fraudulent or misleading calls received by the general public. This aligns with ongoing efforts to protect consumers from scams that often rely on caller ID spoofing.

However, the complexity of the proposed rules and procedures may lead to challenges for smaller telecom companies, who may find it more difficult to cope with the bureaucratic and legal demands compared to larger industry players.

Impact on Specific Stakeholders

For large telecommunications companies, these rules may not significantly alter day-to-day operations. They are more likely to have the resources to deal with the added legal and regulatory complexities. Moreover, they could benefit from increased consumer trust in their services due to enhanced caller ID authenticity.

Conversely, small businesses and local service providers may find the new rules burdensome. The document lacks clear guidance on reducing paperwork and compliance costs for small entities, which could lead to these businesses facing financial strain. These smaller stakeholders may also struggle to manage the legal proceedings involved in appealing token revocations, potentially affecting their ability to remain competitive.

In conclusion, while the FCC's effort to enhance caller ID reliability is well-intentioned, the proposed rules come with complexities that could pose significant challenges, particularly for smaller businesses. There is a crucial need for careful consideration of the administrative and financial impact these rules might have on various stakeholders within the telecommunications industry.

In the document from the Federal Communications Commission (FCC), several financial references concern small business size standards and annual revenue criteria, particularly concerning the cable system operators and telecommunications services sector.

The document specifies that under the Communications Act of 1934, a small cable system operator is defined as one that serves fewer than 1% of all subscribers in the United States and is not linked with entities having gross annual revenues exceeding $250,000,000. An operator with under 505,046 subscribers and annual combined revenues not exceeding $250 million qualifies as small. These criteria are significant because they determine which businesses are considered small and therefore potentially eligible for certain regulatory considerations or benefits.

Moreover, the Small Business Administration (SBA) has developed a size standard for businesses in various telecommunications sectors. Specifically, for the "All Other Telecommunications" category, a small business is defined as one with annual receipts of $35 million or less. The document further details that out of all firms surveyed in 2012, a total of 1,400 firms had annual receipts of less than $25 million, and 15 firms had receipts between $25 million and $49,999,999. These figures help illustrate the scale of businesses and could influence discussions on regulatory impact assessments.

These financial references link with some identified issues in the document. One issue noted is that the document does not address how small businesses might be financially impacted by the proposed changes in regulations. The financial thresholds provide a critical framework for defining which businesses might face obstacles due to their size and revenue, underlining the importance of considering these impacts in regulatory decision-making.

However, the document lacks a detailed assessment of the potential costs associated with the new oversight role for the FCC, which could influence budget planning for both the Commission and the affected entities. The absence of a clear financial impact assessment means it is harder for stakeholders to evaluate how significant these changes might be financially, particularly for smaller entities that might be disproportionately affected by increased regulatory compliance costs.

The reference to financial criteria may also highlight a potential imbalance in how these regulations could affect businesses of varying sizes. Larger companies with more financial resources might find it easier to navigate and absorb the costs associated with these changes, potentially creating challenges for smaller businesses who might struggle with the additional financial burden. This necessitates a more nuanced approach in handling the implications of these financial classifications within the proposed regulatory framework.