Week ending October 23, 2026

Replies on Club for Growth’s request to send AI-voiced political robocalls to cell phones without consent were due Monday, October 19, fifteen days before the November 3 election. The same week, NTCA and Inteliquent each told Wireline Competition Bureau staff what has to be in place before the TDM interconnection rules go, and the new discontinuance docket picked up objections to Frontier’s copper retirement in Connecticut.

Club for Growth’s AI-voice waiver: the reply round

The petition, filed August 31, asks for a waiver of §64.1200(a)(1)(iii) and a §227(b)(2)(C) exemption so noncommercial political callers can place artificial or prerecorded voice calls, including AI-generated voice, to wireless numbers without prior express consent. In exchange it offers the residential-line conditions: three calls per caller per 30 days, an automated opt-out, a company-specific do-not-call list, and no charge to the called party. CGB put it out for comment in DA 26-940 alongside Joe Shields’s petition on peer-to-peer texting platforms.

Club for Growth’s reply, signed by COO and general counsel Michael P. Donnelly, swaps “AI” for “Super Intelligence” throughout, citing Executive Order 14434. On the no-charge condition it says “the Club plans to work, as needed, with wireless carriers and third-party service providers to ensure that recipients of any calls under the requested exemption are not charged for those calls,” and leans on the 2014 Cargo Airline Association order for the idea that third-party solutions satisfy it. Deception concerns get one sentence: “Although such concerns are beyond the scope of this limited and targeted petition, the FCC and other agencies already leverage enforcement tools to address abuses of SI and the voice network by bad actors.” It cites the Lingo Telecom consent decree and the FTC’s Air AI order.

The American Association of Political Consultants, the respondent in Barr, wants it granted with one addition: an order stating “the exemption applies to calls placed by vendors acting on behalf of political organizations,” since the vendor is usually the party that initiates the call. AAPC’s answer on deepfakes: “The exemption the petition seeks removes a consent requirement; it does not authorize deception.” AAPC also asked the Commission to deny the Shields petition under Duguid. We The People Convention, an Ohio grassroots group, asked for a grant before November 3 and a follow-on rulemaking.

ITIF (Joe Kane) used Barr against the petitioner: “The rule of Barr, therefore, is that a content-based exemption from the TCPA will likely be unconstitutional.” EPIC (Alan Butler) made the same First Amendment point and added that “no workable definition for a ‘political call’ exists that could provide such certainty.” Senate Democratic Leader Charles Schumer filed a letter built around two cloned-candidate scenarios and the 2024 New Hampshire calls: “Those conditions address frequency and future contact, not whether a voice is authentic or a message is truthful.” CDT noted the timing: “Conveniently, the comment period for the petition ends with just 10 business days remaining before Election Day.” Campaign Legal Center (Erin Chlopak and three colleagues) argued Purcell and pointed to the FCC’s own October 8 Supreme Court filing in FCC v. Brown, where the Solicitor General called it “entirely reasonable” for the FCC to hold off on campaign-finance rules mid-election.

The Synthetic Outlaw Observatory Foundation (Jonathan Gropper) took up caller identity directly, separating who placed the call from whether the voice is synthetic and whether the person it sounds like authorized it. “A voice that sounds authentic is not authentication. Caller-number authentication likewise should not be treated as proof that a voice belongs to the person it resembles or that the person authorized its use.” If the Commission considers relief anyway, the Foundation wants a further record first, with conditions including “machine-readable, verifiable provenance linking the call to the responsible entity” and counting rules for calls made by related parties. Seattle resident Barbara Sage made the per-caller-cap point from her own phone: “I have logged 211 of these calls and filed 102 reports with the FTC,” and she has received campaign texts from “at least sixteen different numbers.” Shields filed replies on his own petition and on Club’s, both of which answer AAPC.

CG 02-278 took 39 filings in the window; 22 were express comments with no attachment. No Bureau action on either petition appeared in the docket this week.

IP interconnection: what NTCA and Inteliquent want before forbearance

On October 15, NTCA (Justin Faulb, Brian Ford, Lorna Gilmore) met Jodie Griffin, Allison Baker, Jamie Saloom and Competition Policy Division staff on the FCC 25-73 interconnection NPRM and the FCC 26-11 legacy-rules NPRM. The ex parte (cross-listed in WC 25-304, 25-208, 17-97, 25-311) says about 88 percent of NTCA members are “all-IP” inside their own networks, and that the problem is larger carriers that have not upgraded TDM at the exchange point. NTCA’s conditions: no forbearance “until all technical standards body work – particularly for the Agreement-less IP Interconnection using the Internet (‘ALII’) model – is completed and full-scale testing between providers of all sizes is complete,” a limit on larger carriers’ ability to make RLECs pay for transport to distant POIs, and a gradual CAF ICC phase-down as USTelecom proposed. It also asks the Commission to define “the numbering databases that will be used, as well as what regulatory body (if any) will serve as a ‘cop on the beat’” for call-completion problems.

Inteliquent took its National Transit Provider proposal to Keelin Ferris in Chairman Carr’s office on October 19 and to WCB staff on October 20. The ex parte, filed by Tamar Finn and Ron Del Sesto of Cooley, with general counsel Richard Monto and Sinch CTO Brett Scorza in the meetings, frames NTP as a bridge: “fully deployed within two years,” against USTelecom’s agreement-less internet model (“ALIIIs” in Inteliquent’s spelling), “which Inteliquent estimates will take up to six years to implement.” NTPs would volunteer for rate caps; the Commission could solicit rate proposals as it did for 8YY tandem rates. Without default rules, the letter argues, the terminating provider is a bottleneck, and “a traffic-pumping terminating VSP could partner with an unregulated IP aggregator charging $200 per minute to route traffic to chat lines.”

Inteliquent also raised 911. Until NG911 is live in a region, carriers delivering IP traffic still need §251 collocation and ILEC TDM service to reach the selective router. Citing the August workshop transcript, Inteliquent says ILECs have raised the price of DS1 cross connects to “$46,000 for a cross connect that used to cost $300,” and asks the Commission not to allow “market” pricing for the collocation and TDM services used to deliver 911 calls. A footnote says Inteliquent will file a separate ex parte answering USTelecom’s “caricatures” of NTP.

Frontier’s copper retirement and 911 at the customer end

WC 26-214, the discontinuance and network-change docket under FCC 26-19, took 14 filings in the window, 12 of them express comments. The two with documents are Frontier customers. Susan Kessler, filed as a complaint, writes that her rural Connecticut home has no cell service, that WiFi calling fails when power goes out upstream, and: “My husband suffered a recent stroke and, in emergency situations, without the landline, we have no ability to call 911 from our home.” She adds that local burglar alarms run their weekly test over the copper line. Leo Colgan, president of Northeast Contractors Supply in Hartford, says the business POTS line Frontier is discontinuing carries both his phones and his internet, and that no sales rep will guarantee a fiber hookup “unless I’m willing to give out an exorbitant amount of money.”

An October 14 filing in the same docket from James Kikkert of Hall, New York, attaches the customer notice from Frontier Communications of Seneca-Gorham, “a Verizon Company”: “On or after November 30, 2026, subject to Federal Communications Commission (FCC) approval, Frontier will have the authority to discontinue traditional copper-based home phone service.”

Early comments are also arriving on the 911 framework NOI (FCC 26-63, PS 26-197; comments due November 16). FailSafe Communications (Eddie M. Pope) wants the Commission to recognize failed 911 attempts as a known gap and examine signaling data as a way to detect them: “Even the most reliable 911 system cannot respond to an emergency call that it never receives.” Its T911 product is built on patents held by founder Leo Wrobel, who filed separately proposing signaling data as an input to AI platforms.

Honorable mentions

On October 22 the FTC sued GovAssist, Entry and Scott Zuckerman, alleging paid Google search ads and landing pages that impersonated the State Department for passport services. The same day it announced a $106.8 million default judgment, entered October 14, against the Accelerated Debt Settlement operators, with bans on impersonation and telemarketing. A University of Miami law student, Raymond Kayal, filed on the FCC 26-67 FNPRM, opposing the proposed cut in the consent-revocation deadline from ten business days to seven for callers that process opt-outs manually. In CG 17-59, Jonathan Hoag filed three comments, two with documents, listing 14 toll-free callback numbers he says front an SSN-harvesting loan-robocall IVR. He names 46 Labs/Hypercube as the upstream RespOrg and the downstream carriers he says 46 Labs identified. One filer, Kevin Mottus of the California Brain Tumor Association, accounted for 328 RF-exposure comments cross-listed into PS 26-197 and 19 other dockets.

Looking ahead

The October 29 open meeting carries the international §214 Report and Order and FNPRM (IB 23-119), the accessibility modernization NPRM (CG 10-213, 03-123, GN 21-140), the Rural Broadband Protection Act vetting NPRM (WC 26-96, 26-288) and an unnamed Enforcement Bureau action. A Bureau decision on Club for Growth’s petition before November 3 is the open question in 02-278. Watch for Inteliquent’s promised rebuttal to USTelecom on NTP, and for Frontier’s discontinuance filings ahead of its November 30 date. RMD FNPRM replies are due November 9; comments on the FTC’s impersonation rule docket (FTC-2026-1552) close November 30.