Re: [stir] The Canadian Regulator has issued a Notice of Consultation on robocalls spoofing STIR/SHAKEN

[Richard Shockey <[e-mail]>]

<sigh>  I guess I need to chime in here again since I posted the original message. 

 

From: stir <[e-mail]> on behalf of Tony Rutkowski <[e-mail]>
Organization: Yaana Ltd
Reply-To: <[e-mail]>
Date: Saturday, February 4, 2017 at 8:50 AM
To: Alex Bobotek <[e-mail]>, Dave Crocker <[e-mail]>, "[e-mail]" <[e-mail]>, "[e-mail]" <[e-mail]>
Subject: Re: [stir] The Canadian Regulator has issued a Notice of Consultation on robocalls spoofing STIR/SHAKEN

 

Alex,

Thanks for the reflective note.  My remarks were directed at the CRTC Call for comments which was circulated on this list.  I had four points to make: 1) the incorporation into law of technical specifications such as the STIR/SHAKEN by designated standards bodies is ill advised, 2) the FCC's recent activism in this regard seem likely to change, 3) there are alternative platforms emerging that seem more promising, and 4) the adoption of STIR/SHAKEN is unlikely to be useful in dealing with what is basically a traffic management issue among carriers and customers.

 

RS>  Fair point but NRA’s incorporate highly specific technical specifications into regulation all the time. And in the US this is clearly Title II related so Authority to Act is not in question. I do not suggest STIR/SHAKEN is perfect but it is a clear improvement over nothing.  

Having been in an out of local, national, and international regulatory bodies over the past 50 years, there is one maxim that served those bodies well - avoid incorporating specific technical "fixes" proffered by standards bodies into regulations.  Anointing those bodies gives them de facto regulatory authority and they tend to become more closed, ossified, and manipulated over time, and innovation gets stifled as a result. 

 

RS> Next thing you are going to suggest is phone numbers are stupid. <sigh> J  

Regarding the FCC, one has only to turn on the news or visit its site to realize that its role and activities are significantly changing, heading in the other direction of regulatory intervention into the industry management of its own affairs.  The telecom industry would be now foolish to paradoxically argue against own interests to "regulate me."

 

RS>  The level of frustration among the NRA’s is at a boiling point. The CRTC consultation is only one of many underway or may be underway.  Film at 11.  

 

As for Chairman Pai he has made it abundantly clear what constitutes a reason for regulatory intervention.

 

A.  Clear evidence of Market Failure  

B.  Clear Public Safety interest. 

C.  Compelling Consumer Protection interest.

 

Check Check Check  I think we have met those tests.

 

You should go back and play the FCC strike force and listen to Pai’s remarks.  He came to the mtg late. Don’t presume the way some Conservatives might behave. 

 

https://www.fcc.gov/news-events/events/2016/10/second-meeting-industry-led-robocall-strike-force



New innovative platforms can in part or whole serve as more efficient and more flexible alternatives to STIR/SHAKEN. These include not only blockchain, but also AI techniques pioneered by GeorgiaTech and spun out as Pindrop and apparently now nine other competitors.  CRTC should not stifle the innovation that has emerged in this sector.

 

RS> Well that may be true but this position could have been useful 2 years ago but not now. 



Even if STIR/SHAKEN were able to be imposed at the national level by regulatory fiat, it is unlikely to be a global solution, nor one that even addresses and adapts to the changing network management demands faced by carriers among their diverse customer sets. They are entirely capable of devising and implementing their own solutions and coordinating them through global industry bodies such as the GSMA.  To the extent some kind of local national support centre is needed, the UK NICC model might be useful.

 

 

RS> GSMA you have to be kidding. After they screwed up VoLTE?   God help us.  If we were to wait for a global solution or what you propose we all be six feet under.  I sort of know what NICC and OFCOM is generally thinking.  Beyond my personal presentation in London take a careful look at what Huw Saunders of OFCOM presented before me.  

 

http://www.niccstandards.org.uk/meetings/forum-2016.cfm

 

In any event, I want the IETF to wrap up the STIR documents now …and that means you Mr. Peterson. Get busy …

 

Jon if you want to proceed with out of band STIR solutions, be my guest. Have at it. Have a ball. Good luck with that. Two thumbs up.   I just don’t think it will be relevant to North America. 

 



best,
tony
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