FCC	Consumer	Advisory	Committee	
Recommendation	regarding	unwanted	call	blocking
The	Federal	Communications	Commission	(FCC)	has	demonstrated	that	addressing	
unwanted	calls,	including	illegal	robocalls,	remains	a	priority	issue	for	the	agency,	
industry	and	consumer	groups.		As	noted	by	FCC	Chairman	Ajit	Pai,	“Robocalls	are	
the	number	one	consumer	complaint	to	the	FCC	from	the	public,”	with	over	four	
million	complaints	made	in	2016	to	the	FCC	and	the	Federal	Trade	Commission	
(FTC)	about	robocalls.	The	Consumer	Advisory	Committee	(CAC)	recognizes	the	
FCC’s	efforts,	and	applauds	the	agency	for	moving	forward	with	its	proposal	that	
would	facilitate	voice	service	providers’	blocking	of	illegal	robocalls.		
The	record	in	the	Robocall	Blocking	NPRM	and	NOI	underscores	the	FCC’s	
acknowledgement	of	the	robocall	problem,	and	comments	filed	by	a	broad	range	of	
interests	demonstrate	the	need	for	this	problem	to	be	addressed	on	multiple	fronts.		
Consumers	are	“overwhelmed	with	unwanted	robocalls,”	and	bad	actors	are	“lured	
by	the	promise	of	easy	money.”		In	light	of	the	prevalence	of	the	problem,	action	is	
urgently	needed	against	unwanted	and	illegal	robocalls.
The	CAC	agrees	with	the	FCC’s	acknowledgement	in	the	NPRM	that	it	should	ensure	
that	industry	has	sufficient flexibility	to	address	illegal	traffic,	while	also	protecting	
the	reliability	of	the	nation’s	communications	network	and	protecting	consumers	
from	provider-initiated	blocking	that	could	potentially	and	improperly	capture	legal	
calls	to	consumers.		In	balancing	these	competing	policy	considerations,	the	FCC	
should	strive	to	develop	an	approach	that	provides	voice	service	providers	with	
sufficient	flexibility	to	initiate	call	blocking	while	also	ensuring	that	consumers	are	
sufficiently	informed,	and	that	they	and	those	making	legitimate	robocalls	have	an	
effective	mechanism	for	re-establishing	their	numbers	should	their	legitimate	calls	
be	blocked.	
The	FCC’s	four	proposed	categories	for	robocall	blocking	differ	in	approach,	with	
varying	degrees	of	complexity	and	potential	consumer	harms	resident	in	each.		The	
FCC	should	therefore	recognize	that	individual	voice	providers	will	need	to	carefully	
consider,	for	each	category,	whether	to	deploy	blocking	of	calls	in	that	category.
With	the	goal	of	enabling	voice	providers	to	proactively	block	certain	specific	
categories	of	calls,	while	also	ensuring	that	appropriate	mechanisms	are	in	place	to	
protect	consumers	from	over-blocking,	the	CAC	recommends	that	the	FCC:	
1. Permit	and	encourage	voice	service	providers	to	block	robocalls	in	certain	
specified	circumstances	to	protect	subscribers	from	suspected	illegal	robocalls.	
2. Permit	and	encourage	voice	service	providers	to	block	calls	when	the	subscriber	
to	the	originating	number	has	requested	that	calls	be	blocked.
3. Permit	and	encourage	voice	service	providers	to	block	calls	(and	to	develop	any	
industry	practices	and	procedures	needed	to	facilitate	such	blocking)	in	the	
following	circumstances:	
a. calls	originating	from	invalid	numbers;
b. calls	originating	from	numbers	not	allocated	to	any	provider;	and
c. calls	originating	from	numbers	that	are	allocated	to	a	provider,	but	not	
assigned	to	a	subscriber.
4. Encourage	voice	service	providers	that	have	implemented	any	of	the	call	
blocking	services	described	in	2.,	3.	a,	b,	and	c,	to	inform	current	and	potential	
subscribers	through,	at	minimum,	their	published	terms	of	service.	
5. Encourage	stakeholders	from	consumer	and	industry	sectors	to	work	
collaboratively	to	develop	processes	and	solutions	whereby	unintended	blocking	
of	legitimate	callers	can	be	remedied in	a	timely	and	efficient	manner.		
6. Encourage	voice	providers	to	offer	consumers	optional	tools	to	block	robocalls	
beyond	the	four	categories	mentioned	in	the	NPRM	and	NOI	and	make	
information	about	those	options	easily	available	to	current	and	potential	
subscribers.		Voice	service	providers	(and	third-party	providers)	should	be	
afforded	sufficient	flexibility	to	establish	standards	that	can	be	utilized	to	meet	
this	goal.
7. Study	the	implementation	and	effectiveness	of	blocking	measures, within	two	
years	after	the	new	rule	is	finalized in	order	to	assess	the	impact	of	various	
blocking	measures. The	examination	could	include	the	availability	to	consumers	
of	call	blocking	solutions;	the	fees	charged,	if	any,	for	call	blocking	tools	available	
to	consumers;	the	proportion	of	subscribers	whose	providers	offer	and/or	
enable	call	blocking	tools;	the	effectiveness	of	various	categories	of	call	blocking	
tools;	and	an	assessment	of	the	number	of	subscribers	availing	themselves	of	
available	call blocking	tools.
Adopted:	September	18,	2017
Abstentions:	Americans	for	Tax	Reform;	National	Association	of	Broadcasters	
Respectfully	submitted:
Eduard	Bartholme,	Chairperson
FCC	Consumer	Advisory	Committee