Week ending August 28, 2026

Inteliquent met the Wireline Competition Bureau on August 25 and filed the readout two days later. Its argument: more than 1,600 TDM tandems operate nationwide, and neither competing interconnection proposal in front of the Commission replaces them inside two years. Three ex partes out of the same National Association of Attorneys General panel landed in the robocall dockets the same week.

Inteliquent prices the tandem replacement and rules out both rivals

Richard Monto, Inteliquent’s general counsel, and Brett Scorza, its CTO, brought the National Transit Provider framework to six Wireline Competition Bureau staff — Deputy Bureau Chief Jodie Griffin, Competition Policy Division Chief Jamie Saloom, Deputy Chief Melissa Droller Kirkel, Assistant Division Chief Michele Berlove, and legal advisors Jesse Goodwin and Mason Shefa. Ron Del Sesto and Tamar Finn of Cooley signed the August 27 letter, cross-listed in all four all-IP dockets: WC 25-208, 25-209, 25-304 and 25-311.

Any new framework, Inteliquent argues, “must ensure that a reliable interconnection framework is fully established before any forbearance of legacy interconnection obligations becomes effective.” In exchange, NTP would “replace existing Section 251(c) interconnection, colocation, and tariffing obligations with a streamlined, ‘light-touch’ regulatory model.” The urgency comes from supply: TDM equipment vendors and service providers exiting the market have created an “acute risk that certain geographic regions will lose the physical interconnection capability necessary to reach the Public Switched Telephone Network,” and the letter names access to 911 as one of the things that fails when they do.

On price, Inteliquent wants a transitional regulated default rate cap: without one, “deregulated IP transit rates could face unsustainable escalations similar to those observed in other deregulated markets, such as Business Data Services.” The proposed structure is designed to recover transit costs as incurred while minimizing “arbitrage, traffic pumping, or predatory pricing.” Originating providers stay free to interconnect directly or use any other arrangement.

AT&T’s July 24 letter in WC 25-304 and 25-311, signed by Brian Benison and quoted at length in the Inteliquent filing, offered conditional forbearance inside a LATA where direct IP interconnection or an over-the-Internet alternative exists, with subtending carriers reaching IP through transit provided by the ILEC, an affiliate, or a third-party aggregator. Inteliquent’s response is that this “would only apply to a subset of LATAs nationwide. It is not a nationwide solution” — and that AT&T’s inclusion of a transit pathway “effectively demonstrates that the competing USTelecom model — which would require all carriers to establish direct logical or physical connections with all other carriers — cannot realistically be deployed or function within a two-year timeframe.”

Nine more individual comments arrived in WC 25-209 during the week, fifteen across the last two, nearly all opposing AT&T’s carrier-of-last-resort discontinuance. Adele Myers filed the only one with an attachment on August 24: “I live in a rural community. Due to topography, I have no cell signal.” Her point is that WiFi calling is not a substitute where the internet is the thing that fails — during “inclement weather or wildfire,” a household without a landline has “NO means to reach 911, receive evacuation notices.” She notes the CPUC twice denied AT&T’s COLR petitions, asking it to either find a replacement carrier or build a non-copper system, and that AT&T “escalated their petition to the Federal level.”

Three panelists from the same NAAG session filed the same ask

The “Utility of STIR/SHAKEN in Fraud” session at the NAAG 2026 Robocall Summit ran on August 20 in Asheville. On the panel: Adam Panagia of AT&T’s Global Fraud Management Organization, David Frankel of ZipDX, Alec Fenichel of TransNexus, Chris Oatway of Verizon, and Chris Laughlin, Deputy Division Chief of the Competition Policy Division at WCB. Erin Leahy, Senior Assistant AG in Ohio, moderated. Three of the five filed ex partes in the following week, all pointed at the Know Your Upstream Provider FNPRM, FCC 26-32, released May 21.

AT&T’s Cindy Manheim filed Panagia’s remarks on August 24 in WC 17-97 and CG 17-59. The framing: “we need to move beyond identifying bad numbers and start identifying the source of the fraudulent traffic.” Providers are combining signing data with complaints, analytics, traceback results and behavioral indicators to build “reputation profiles for signing carriers,” which turns the decision from binary into a score — “allow, label, or block, making common evasion tactics such as neighbor spoofing, official enterprise spoofing and rapid number rotation far less effective.” The ask is a safe harbor “for providers who utilize signed call information along with other information to identify and block the source of the fraudulent traffic even when it is not the directly connected upstream provider.”

Verizon’s Oatway filed the same day into CG 17-59, CG 02-278 and WC 24-213, and asks for the same capability through a different instrument: targeted clarification of the blocking “green light” in 47 C.F.R. § 64.1200(k)(4), so terminating providers can block on signer signature “including where terminating providers do not have direct interconnections with the problematic originating providers.” On KYC he repeated Verizon’s position from its June 26 comments — “risk-based programs as opposed to one-size-fits all requirements” — and warned about “the potential unintended consequences of overly-prescriptive KYC requirements on vulnerable and price-sensitive populations.”

Frankel’s ex parte came in on August 27 marked LATE FILED, restating ZipDX’s August 10 comments. He wants the decision handed to the subscriber: “Empowering consumers to divert calls based on signer reputation leverages the enormous investment that the Commission and the industry has made in STIR/SHAKEN technology.” He ranks it against the alternatives: “While numerous mitigation approaches deserve attention, signer reputation needs to be at the top of the FCC’s list.”

The three agree that the useful unit is the signer, not the number. They split on who acts: AT&T wants terminating carriers indemnified, Verizon wants the existing blocking authority read wider, Frankel wants consumers doing the diverting. Fenichel was on the panel and has not filed.

Three Phase 2 requests in two years, and still no definition of i3 conformance

Intrado counted the requests. Nearly two years into the NG911 transition framework, 911 Authorities have filed three Phase 2 requests for service, two withdrawn for lack of readiness, and the one still active “has surfaced significant unresolved questions about how 9-1-1 Authorities interpret NG9-1-1 readiness under the Commission’s framework.” The comment round in PS 21-479 and PS 13-75 closed on August 10 against that record. Replies close September 8.

Intrado’s comments, signed by Lauren Kravetz and Sean Ward, locate the hole. Commission rules require originating providers to deliver 911 traffic to an ESInet in conformance with “commonly accepted standards” — in practice, i3-conformant SIP — but the rules “do not address what it means for an ESInet/NGCS system to be i3-conformant for purposes of transferring a call, with the full complement of location, text, and multimedia data, to a different ESInet/NGCS system.” The Transition Order left that judgment to the certifying 911 Authority, on the reasoning that more detail “appears unnecessary and could cause confusion.” Intrado’s answer: “We think it’s the opposite.” Authorities pick their own i3 features, deployments still carry legacy elements, and “no two deployments have been alike,” so a testing mandate laid on that foundation “would result in testing for testing’s sake, rather than testing that validates meaningful interoperability.”

NENA agrees on the mandate and refuses the definition. It wants no rigid interoperability testing or readiness requirements now, a “light touch” framework deferring to standards organizations, and 911 Authorities driving testing in their own jurisdictions — a Commission-led framework without that flexibility is “premature and misguided,” with the Commission’s role “limited to oversight of the testing process and mediating any disputes.” It also objects to the FNPRM’s vocabulary: “connectivity testing,” “NG911 production testing” and “NG911 interoperability testing” do not match the industry’s terms of art, which iCERT settled in 2019 as conformance testing, interoperability testing and end-to-end testing. NENA’s counter-offer is an i3 Series project modeled on 3GPP’s annual release cadence, giving authorities stable published releases “instead of leaving 9-1-1 authorities and the market to independently determine what the best ‘current’ suite of standards should be.”

iCERT and NASNA — NASNA speaks for the 911 leadership of all fifty states and DC — filed jointly to say a stand-alone interstate testing mandate “would not produce meaningful interoperability implementation,” and to propose a request-based framework covering intrastate as well as interstate transfers with “a limited federal backstop.” VEA Systems, Valid8 and Circet USA want the Commission to “define the required evidence, not prescribe who must produce it.” Nobody in the round wants the testing rule the FNPRM proposed. What splits them is whether conformance gets defined first, and by whom.

The accessibility organizations want direct video calling to 911; NENA says the Commission cannot require it

TDIforAccess, Deaf Equality and the National Association of the Deaf filed jointly on the deadline. Direct video calling, they argue, “is the only currently available means by which a person whose primary language is American Sign Language (‘ASL’) can have a direct conversation with the 911 telecommunicator” — TTY, text-to-911, RTT, VRS, IP Relay and IP CTS all matter and none of them is that. Their feasibility evidence is the 988 Suicide & Crisis Lifeline, which “served approximately 30,000 DVC callers in the first ten months after making the service available.” They ask for a national framework for signaling readiness and routing DVC calls, a pilot program, and DOJ confirmation that DVC satisfies the effective-communication obligation without progress being made contingent on getting it. Their line on the accompanying order: “a 911 network can be reliable and interoperable and still fail to provide ASL users with reliable and equal access to 911.”

CSD argues the plumbing already exists. DVC and VRS “use the same open, interoperable protocols and standards,” the same VRS registration databases, the same emergency address records and the same NG911 location routing, so “DVC can be made available to VRS users with no additional software or configuration,” and every device that can place a VRS call can place a DVC one. Its proposal is a flag: ASL-fluent callers pre-designate DVC or VRS in their VRS caller profile, and providers route on it. Sorenson, which handles nearly 50,000 VRS calls to 911 a year and is an approved DVC entity, backs the request and adds the constraint: ASL-fluent call takers who know the local geography are the right answer and “will not be practically available for many PSAPs” on cost and interpreter supply, so VRS stays the widely available path. Intrado, which has spent about two years developing DVC pilot concepts with CSD, wants a Commission-sponsored structured pilot.

NENA’s objection is jurisdictional. Congress, it argues, limited the Commission’s 911 authority under the Wireless Communications and Public Safety Act of 1999 to carriers rather than state and local government, and the legislative history “expressly states that the legislation did not enable the Commission to mandate state and local governments to make any changes to their emergency numbering systems.” Citing West Virginia v. EPA, it concludes there is “no clear direction nor authorization from Congress that would suggest the Commission is empowered to impose any operational requirements upon 9-1-1 authorities and PSAPs to accept DVC to 9-1-1.” On the operational side it says there are no DVC-to-911 operational standards, that developing them “could take as long as two years,” and that the number of ASL-trained telecommunicators is “extremely low” and will stay scarce. And it names the funding: “true equitable nationwide emergency response will only be possible with federal funding to implement Next Generation 9-1-1,” absent which “it is unreasonable for the Commission to assume PSAPs, 9-1-1 Authorities, and other 9-1-1 entities are prepared.”

The Commission subtracted an accessibility mandate in the same fortnight. FCC 26-56, adopted August 21 and released August 25 in CG 03-123 and GN 25-133 with a statement from Chairman Carr, eliminates 47 CFR § 64.604(b)(1), the requirement that TTY-based relay be capable of communicating in ASCII. The rule dates to 2000, when TTYs ran Baudot and the Commission required ASCII too because it believed ASCII “was ‘a superior technology’ that would eventually supplant Baudot.” T-Mobile argued that dropping it frees providers to spend on “modern, widely used relay technologies, such as Real-Time Text (RTT), IP Relay, and VRS.” NENA holds the ANSI-approved joint TTY standard with APCO.

Honorable mentions

FCC 26-59, the FY2026 regulatory fees Report and Order released August 27, holds the toll-free fee at $0.10 per number against a calculated 0.098298 — 40 million payment units, $4 million in revenue. RespOrgs pay on all working, assigned and reserved numbers plus any other status under § 52.103, counted as of about December 31, 2025. CMRS fees continue to run off NRUF Form 502 assigned-number data collected by NANPA, netted for Type 0 ports.

FCC 26-60, released August 28, proposes $188,491 against Hytera and ZTE for failing to file “the full names of, and identifying information for” their associated entities producing covered equipment, under 47 CFR § 2.903(d) — either no complete filing by the March 8, 2023 deadline or no notice of changes within 30 days.

DA 26-906 reminds rip-and-replace recipients that the next 90-day status update is due September 28, and that Priority 1 recipients holding RRD extensions past May 8 must include a remediation timeline and a completion date.

At the FTC, 2027 Do Not Call Registry access fees go to $85 per area code and $23,425 for nationwide access from October 1, and the Commission finalized orders with Cox Media Group and two other firms over claims made for an “Active Listening” AI marketing service.

Looking ahead

Reply comments in PS 21-479 and PS 13-75 close September 8, and the two questions to watch are whether anyone answers NENA’s authority argument on DVC and whether Intrado picks up support for defining i3 conformance ahead of any testing rule. Bandwidth filed an ex parte late on August 28 cross-listing WC 25-304 into 21-479, putting IP interconnection and NG911 in one caption. USTelecom has not answered the National Transit Provider proposal on the record, and AT&T’s most recent word in 25-304 and 25-311 is still the July 24 letter Inteliquent just used against it. TransNexus is the one NAAG panelist yet to file. Rip-and-replace status updates are due September 28.