Week ending September 18, 2026

AT&T filed two pages on Tuesday on the question sitting at the top of the objections to agreement-less IP interconnection: what happens to 911. Its answer is that the question belongs to a different proceeding. Two economists filed the same week with a mechanism for the part of the transition nobody has costed. And in the robocall dockets, an app-based number provider and a video relay provider each told the Commission that the attestation rules turn on the wrong fact.

AT&T sends the 911 question to a different docket

Brian Benison, AT&T’s AVP for federal relations, wrote in WC 25-304 on September 15 that concerns about NG911 traffic under the ALIII model “are misplaced.” The argument is jurisdictional rather than technical: commenters “conflate two separate issues: the interconnection framework for ordinary voice traffic and the routing architecture applicable to NG911 traffic.” AT&T points to the Commission’s July 2024 order requiring originating service providers to deliver 911 traffic in SIP to a designated NG911 delivery point in each state, and cites Lumen’s July 15 ex parte for the same proposition. The conclusion is that no additional interconnection mandate is needed, because “IP-based 911 traffic would not be expected to traverse the Internet-based interconnection arrangements contemplated for ordinary voice traffic under the ALIII model.”

That is a direct answer to the first bullet in INCOMPAS’s September 1 letter, which said the workshop record contained no clear explanation of “whether 911 would be exempt from ‘over-the-internet’ interconnection, whether dedicated paths would be required, or how reliability and accountability would be maintained.” INCOMPAS had also noted that AT&T suggested dedicated paths at the workshop without explaining how such paths would work if voice traffic rides internet transit. AT&T’s answer is that 911 does not ride it.

Verizon refiled its September 11 letter into 25-311 on September 15, the same text backing AT&T’s LATA-by-LATA conditional forbearance proposal.

Rosston and Wallsten bring the money question to WC 25-304

Gregory Rosston of the Stanford Institute for Economic Policy Research and Scott Wallsten of the Technology Policy Institute met virtually with Evan Kwerel, Paul Lafontaine, Donald Stockdale and Jonathan Williams on September 10 and filed on September 14 in 25-304, 25-208 and 17-97. Their proposal is the Voluntary IP Service Transition Auction, or VISTA: an incumbent “would submit a sealed offer stating the payment it would accept to exit service and relinquish any claim to future high-cost support,” the Commission would separately solicit bids for the time-limited subsidy needed to serve the area, and the swap happens only where the two together cost less than the net present value of continued support. “The Commission would thereby replace an indefinite stream of payments with a defined one.”

The premise is that the NPRM leaves the bill unaddressed. The Commission said tariffing and access-charge issues “stem directly from the legacy TDM framework” and would be handled in separate future items; the comments argue that “the predictable outcome of using undetermined ‘separate future items’ is pressure to replace lost ICC revenues with permanent USF support.” The high-cost fund distributes over $4.5 billion a year. The NPRM’s own regulatory flexibility analysis counts 1,175 incumbent LECs filing Form 499A, 917 of them small entities.

Staff pushed on the design and the authors conceded the central point in the ex parte: because each area has a single incumbent, VISTA “lacks competition on the sell side and in that respect resembles a one-shot sealed offer more than a conventional auction.” They agreed that cross-area competition along RDOF lines would strengthen incentives, and that satellite and fixed wireless bidders can supply competition on the buy side. Their own comments list political opposition as an obstacle and say the mechanism has to stay voluntary to survive it. They asked for a small-scale test before any broader implementation.

Rural transition costs are already in this record — INCOMPAS’s September 1 letter said rural carriers cannot quantify transit costs under ALIII and described the combination of new transit obligations and lost CAF-ICC support as potentially destabilizing. What VISTA adds is an instrument. The ALIII and National Transit Provider camps are arguing about which architecture the Commission should mandate; Rosston and Wallsten are proposing a way to pay the carriers that have to live under either one, or to buy them out.

Two filers say the attestation gate is drawn around the wrong thing

Ronald Del Sesto and Robert McDowell of Cooley took Pinger CEO Greg Woock to Marcus Maher in Commissioner Trusty’s office on September 9 and to CGB and WCB staff on September 10, and filed the presentation on September 11 across eight dockets. Pinger provides numbers to consumers and small businesses through TextFree, Sideline and Index. It holds its own OCN and an SPC token it has had since 2022, was recertified in the Robocall Mitigation Database on February 17, and signs at A-level today. Every call “is initiated manually by an authenticated end user through a Pinger application and travels across Pinger-operated infrastructure,” and it offers “no bulk numbers, no origination interfaces, no SIP trunking, and no wholesale or reseller arrangements, so no other provider’s traffic can enter its platform.”

The proposed rules attach attestation eligibility, implementation duties and “a forfeiture-backed public self-classification” to whether a provider originates calls “using the provider’s own facilities,” and, as Pinger puts it, “they never define facilities, facilities-based provider, or non-facilities-based provider in the rule text.” Its ask is to let the attestation decision follow the provider that serves the end user, and to bar downstream downgrade: a provider “shall apply, and shall not unilaterally downgrade, a compliant decision by a counterparty that maintains a current Database certification and holds its own Service Provider Code token.”

The second half of the presentation takes up the traceback apparatus. The Industry Traceback Group’s August 7 letter describes Traceback Insights, the ITG Community and a traceback-derived risk score, all of which inform the provider evaluating an upstream counterparty. “None of them warns the provider whose own customer is generating unlawful traffic, the provider that can stop it within minutes, and the letter describes only preliminary exploration of a controlled risk-information sharing mechanism.” Pinger wants that notification built, reaching the responsible provider whether or not it participates in any industry program, with published participation criteria, a process to correct factual error, and no output serving as “the sole basis for blocking, labeling, or terminating a provider.” It also states the limit of what it is asking for: “An attestation establishes provenance and number authorization, not lawful purpose.”

ZP Better Together ran the other version of the same complaint through all three commissioners’ offices. Jeff Cordell and Greg Hlibok, with Kevin Rupy of Wiley Rein and Nicholas Degani of Reticulated Strategies, met Trusty’s and Gomez’s offices on September 14 and Carr’s office and CGB on September 15, and filed on September 16 across six dockets. Their point is that “strictures in the implementation of the STIR/SHAKEN framework have all too often caused carriers to label calls from TRS users who are deaf, hard of hearing, deafblind or who have speech disabilities as spam—and that a mandated A-level attestation for such calls is a narrowly tailored solution that would advance functional equivalence.” The relay providers made that argument in reply comments on September 8; ZP took it to the commissioners six days later.

Pinger wants the attestation decision assigned to the provider that holds the customer relationship. ZP wants a rule that assigns A-level to relay traffic outright. Both are aimed at the same feature of the framework — that eligibility turns on what a provider owns rather than on what it knows about the caller — and neither filing cites the other.

TelSwitch pulled in the opposite direction. Aaron Woolfson filed comments in the Robocall Mitigation Database proceeding on September 14 and refiled with exhibits the next day, asking that every provider in the call path carry its RMD registration ID and OCN “within informational portions of the SIP headers,” on the model of email Received headers; that RMD registration require a surety bond of no less than $100,000 held by the Commission and available to satisfy forfeitures and judgments; and that registrants maintain a Washington DC registered agent, verified quarterly. The exhibit is a state-by-state table of telemarketer bond requirements ranging from nothing to $500,000.

The 02-278 petition pile answers back

The Bureau’s August 19 public notice proposing to dismiss twenty-four stale TCPA petitions (DA 26-864) drew an objection. Vincent Lucas wrote on September 12 that his 2014 petition is neither moot nor outdated. It asks the Commission to hold that a person is vicariously or contributorily liable for providing “substantial assistance or support to any seller or telemarketer when that person knows or consciously avoids knowing” the telemarketer is violating §227(b) or (c) — the FCC analogue of the FTC’s assisting-and-facilitating provision at 16 C.F.R. 310.3(b). A federal district court referred the question to the Commission in 2014 and urged it to “ACT PROMPTLY UPON THE CONCLUSION OF THE COMMENT PERIOD, AS THE ISSUE HAS WIDESPREAD IMPLICATIONS.” Twelve years on, Lucas argues, “the FCC’s regulations are silent on the issue of whether it is unlawful to assist or facilitate the violation of the TCPA.”

Mark Dobronski went the other way and added to the pile, filing a new 32-page declaratory ruling petition on September 14 about consent manufactured during a call the telemarketer had no right to place. The requested holding is that “purported consent procured during a solicitation that was unlawful when initiated is void for resulting future solicitations,” that an alternate number given during such a call creates no consent, inquiry or established business relationship, and that asking for an alternate number after reaching a registry-listed number establishes the caller’s actual knowledge. The petition leans on the 2003 TCPA Order, which held that letting telemarketers call listed numbers to request permission “would circumvent the purpose” of the exemption.

The Law Office of Anthony Paul Diehl filed against the revocation item circulated for the September 30 meeting. Its objection is operational: category-specific revocation cannot run off a single do-not-call flag, so callers have to build consumer-level consent matrices and then defend their category boundaries. “A payment-due notice, an autopay-failure notice, and an escrow notice may constitute one account-servicing category or three separate categories.” On exclusive opt-out methods, the filing points out that a consumer who never answers never learns the designated method — “undiscoverable cannot be conspicuous.” Its summary: “The Commission presents these amendments as flexibility for callers. In practice, they create greater regulation, expense, uncertainty, and liability.”

Monument Advocacy came in for Mobility Global on the IHS Markit emergency petition to allow automated texting for NHTSA safety recalls, meeting Ed Bartholme, Mark Stone, Zac Champ, Richard Smith and Aaron Garza on September 10. The petitioner has changed identity twice while the petition has been pending: IHS Markit merged into S&P Global in February 2022, and S&P separated its Mobility division into Mobility Global on July 1 of this year. The requested exception is still limited to NHTSA recalls.

NG911 reliability filings stop while the new rules wait on OMB

The Public Safety and Homeland Security Bureau reminded covered 911 service providers on September 14 that the 2013 reliability benchmarks for physical diversity, operational integrity and network monitoring still bind them during the phase-in of the June order (FCC 26-39). The annual reliability certification is gone now rather than in eighteen months: “no reporting is required for 2026 or going forward until the conclusion of 18-month phase-in period.” The clock on the new certifications does not start until the Commission issues the public notice announcing OMB approval. Cessation notices remain due within 60 days, to [email protected].

iCERT and NASNA met David Furth, Rachel Waxman, Christopher Fedeli and five other PSHSB staff on September 16 and filed a seven-slide deck on the interoperability framework. It proposes a request-based model in which a valid joint request from the participating 911 Authorities triggers a twelve-month implementation period, gated by six readiness criteria — both jurisdictions through Phase 2, connectivity in place, an agreed technical approach including protocol and profile versions, an agreed cost allocation, contractual authority over the NGCS and ESInet providers, and a named list of the capabilities requested. The deck’s technical argument is that certification against the standard does not answer the interconnection question: “General conformance with the NENA i3 standard does not eliminate the need to identify the particular standards-based methods and functions that will be used to interconnect the participating NG911 systems.” The worked example is location — whether civic location travels by value or by reference, how references get authenticated and retrieved, and what happens when dereferencing fails. From there the deck asks the Commission not to adopt “baseline requirements” or conformance obligations at all, quoting the NG911 Transition Order’s refusal to name i3 in the codified definition.

Honorable mentions

Three more rip-and-replace extension requests landed in WC 18-89. Point Broadband asked for its sixth, covering five SCRP applications it says pertain to a single unified network infrastructure, against a November 8 removal deadline; it has committed about $34 million and been reimbursed $24.68 million. Pine Telephone petitioned through David LaFuria, with its tower locations under a confidentiality request. Bristol Bay Cellular Partnership filed as well.

In the same docket, Shoaib Rehman filed comments as a transmission engineer with no stake in the program, reading the Bureau’s September 3 grants of RRD term extensions to four recipients as ordinary integration risk rather than recipient delay. Copper Valley needed an IP addressing scheme agreed across the carrier, a hosted-core provider and a vendor: “That is a coordination problem, not an installation problem.” NfinityLink found its selected replacement equipment did not support the required software protocols and had to requalify a second vendor. Velocity’s extension turned on scarcity of cells-on-wheels.

Five people filed express comments in WC 25-209 this week.

Looking ahead

The Commission meets September 30 with the TCPA revocation item and the 911 framework NOI on the agenda; Diehl’s filing is unlikely to be the only comment on the circulated draft before then. CSRIC X meets September 23. Watch for whether anyone in 25-304 contests AT&T’s separation of NG911 routing from ALIII interconnection, or concedes it — INCOMPAS and the rural coalitions have that argument in front of them now, and AT&T has already claimed Lumen’s July 15 ex parte for its side of it. And watch the Bureau’s disposition of DA 26-864: Lucas has objected, Dobronski has filed a fresh petition into the same docket, and the notice’s premise was that these petitions are outdated or moot.