STATEMENT OF
COMMISSIONER JESSICA ROSENWORCEL

Re:	Toll Free Assignment Modernization; Toll Free Service Access Codes, WC Docket No. 17-192, CC Docket No. 95-155, Report and Order (September 26, 2018)

	Today we begin a grand experiment with toll free numbers.  To understand why this experiment matters requires a bit of explanation.  So let’s back up.  Under the law, the Federal Communications Commission has a duty to ensure that the distribution of toll free numbers is equitable.  For decades, equitable has meant that this agency managed distribution of 800 numbers and their brethren through a command and control system.  It worked like this: toll free numbers were provided on a first-come, first-served basis and a secondary market for these numbers was prohibited.  But a quick online search will tell you all you need to know about the deficiencies with this approach.  On the internet you will find that there is a vibrant marketplace where anyone can “buy” a toll free number from entities that openly flout our rules.  

	It is fair to ask if there is a better way.  Here we do just that.  We set up a sandbox experiment.  We depart from our command and control past and announce an auction for the distribution of the 833 area code—our newest toll free number.  We also liberalize policies with respect to secondary market transactions for numbers that are auctioned.

	This is a smart undertaking.  But as with any experiment, we have a lot to learn.  It is imperative that the FCC study our 833 effort—how it operates and the outcomes that result—and then carefully consider whether or not it works better than our traditional means of toll free number distribution.  I know I will be paying close attention, especially to the audit that will follow this auction—one that my colleagues have agreed to at my request.

	There is one other request I had that my colleagues worked with me on—and for that I am grateful.  The rulemaking that preceded this decision asked questions about how to ensure public entities that may not have the resources to meaningfully participate in an auction should be treated when toll free numbers are expanded—as they will be here, with 833.  These include government authorities and non-profits providing essential health and safety services.  

	Today, non-profits operate a number of toll free hotlines that are a critical part of public safety.  These include the National Capital Poison Control Hotline, which helps manage poison emergencies, frequently with children.  They include the National Child Abuse Hotline, which needs no explanation.  The National Center for Missing and Exploited Children runs a hotline to prevent childhood victimization and leads the fight against abduction, abuse, and exploitation of our youngest.  In fact, last year alone the center responded to more than 10,000 reports of child sex trafficking.  The National Runaway hotline is also a non-profit that provides public benefit—as does the National Sexual Assault Telephone hotline, which reported a 42 percent increase in calls just last weekend.  

	The initial draft of today’s decision left all of these hotlines—and many non-profit public health and safety organizations just like them—out in the cold.  Without the financial resources to compete, they were effectively shut out from the auction and precluded from preserving their numbers in any toll free expansion.  This has been fixed—and I believe the decision now serves the public interest.  As a result, this experiment with toll free area code 833 has my full support.