STATEMENT OF
COMMISSIONER GEOFFREY STARKS

Re: 	Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, Call Authentication Trust Anchor, WC Docket No. 17-97

In 1938, the Bell Telephone System ran a print advertisement that began with the following words: “This very hour, millions of words are being spoken by telephone.  Friend talks to friend and two lives are happier because of it.”  The ad concludes by saying: “[D]ay and night, the country over, these oft-repeated words reflect the value of the telephone . . . ‘I’m glad you called.’”

Some things change, and some things remain the same.  This very hour, the millions of words between friends and loved ones are being exchanged.  But we also know that at this very hour, millions of robocalls are bombarding consumers – 6.4 million per hour, to be exact.  In large part, these calls are not making lives happier.  Far from it.  The calls range from being a nuisance or disruptive to being deceptive and dangerous, and causing unwitting consumers to be defrauded out of real money.  Typically, these calls do not “reflect the value” of phone service but, more likely, devalue the service to the point that consumers are dropping phone service at an alarming rate.  And I think it is safe to say that “glad” is not the four-letter word most likely to conclude one of these calls.

I’ve said it before and I’ll say it again, robocalls have changed the fabric of our culture – if you get a call and don’t recognize the number, you don’t pick it up.  Often, calls are spoofed to look like they are coming from a local business or neighbor.  This pernicious practice makes it so we can’t differentiate these unwanted robocalls from calls from our doctors or our kids’ schools.  Put simply, by allowing these calls to proliferate, we’ve broken phone service in this country.

I believe that we need to take a holistic approach to combating robocalls, by combining technological tools, policy fixes, and strong enforcement.  Stemming the tide of illegal robocalls should be one of the Commission’s top priorities and we should consider any and all ideas, new or old, to try to put a real dent in this growing problem.  We must target illegal robocalls throughout their lifecycle - from preventing scam calls from originating on the network in the first instance to empowering consumers to block unwanted calls from ever reaching their phones.

The Commission must take action.  Consumers demand it.  It is incumbent upon us to take positive steps to thwart illegal robocalls and empower consumers to take back control over their phones.  The American people are looking to us to lead and to act – aggressively, intentionally, and quickly.

I support today’s item.  I am hopeful that clarifying that providers may offer informed opt-out call blocking services will make these tools available to millions more consumers as soon as possible.  I appreciate that this item notes that these services should not negatively impact emergency calls or rural call completion obligations. And I am glad that we will now be positioned to act on mandating Caller ID authentication by the end of the year, if needed.

I was supportive of edits proposed by my colleagues to ensure that such blocking is offered in a competitively neutral and non-discriminatory way, to study the impact of blocking on 911 and public safety, and to empower consumers to gather additional information about the effectiveness of call blocking solutions.  I am also supportive of revisions proposed by my colleagues that provide callers with a mechanism to dispute blocked calls that may have been misidentified, provided that consumers remain in the driver’s seat throughout the process.

And I would like to extend my thanks to the Chairman and my colleagues for their support of a section that I proposed we add to the item requiring the Consumer and Governmental Affairs Bureau, in consultation with the Wireline Competition Bureau and the Public Safety and Homeland Security Bureau, to gather information from carriers and produce a series of comprehensive reports on the deployment and implementation of call blocking and Caller ID authentication.  As I have made clear in a number of recent items, it is imperative that in dealing with the most significant issues of telecommunications policy—such as who has access to broadband—the Commission must gather and rely on clear and accurate data.

Specifically, at my request, the item will give us critical feedback on how our tools are performing.  It will now study the availability of call blocking solutions; the fees charged, if any, for these services; the effectiveness of various categories of call blocking tools; and an assessment of the number of subscribers availing themselves of available call blocking tools.  The item also now asks that the reports assess the impact of previous Commission rule changes and, critically, include information on the state of deployment of Caller ID authentication through the implementation of the SHAKEN/STIR framework for the first time ever.

Data analysis will be critical to ensuring that we finish the job of protecting and empowering consumers.  I therefore successfully pushed to modify the item to explicitly delegate authority to CGB to collect any and all relevant information and data from voice service providers necessary to complete these reports, including authoritative data about the number of illegal robocalls transiting our phone system; the number of calls blocked, false positives or false negatives, and other relevant data points.  I will review these reports with great interest and expect that they will enable the Commission to take additional action quickly, if warranted.

 Finally, let me be very clear – I expect call blocking services should be offered to consumers for free.  I’d note that this item makes it abundantly clear that providers who implement these services will save billions of dollars as network capacity is freed up and customer service representatives field fewer complaints.  Moreover, making phone service usable again, I believe, will cause fewer consumers to cancel their phone service and, perhaps, some will come back.  Against this backdrop, in my view, I would have serious concerns with a carrier that includes a line item on consumers’ bills or otherwise charges them for these services.  The CGB reports will be critical here in informing our next steps.  If we see that carriers are, in fact, charging consumers for blocking services, I successfully added language requiring the Commission to propose rules prohibiting the carriers from doing so.  I will review the forthcoming reports on this topic closely.

 So, to take it back to the old Ma Bell ad, while it may seem quaint or even nostalgic, I do long for a day when I can use my phone again – fully and in the way that I want.  And I know from my travels across the county that I’m not alone.  Bringing phone service to every corner of our nation is one of our defining achievements and voice service still plays a critical role in our communications network.  As the old ad put it: “Greetings and best wishes are exchanged . . . affairs of business are transacted.  A doctor comes quickly in answer to a hurried call.”  I’m looking forward to, once again, uttering the words “I’m glad you called.”  I’m hopeful that our actions today bring us a step closer towards getting back to that place.  I vote to approve.

Many thanks to the teams in the Consumer and Governmental Affairs Bureau and the Wireline Competition Bureau, that have ably led the charge on this and other items to tackle these vexing issues.  And thank you, in advance, for undertaking the important work of measuring and reporting on the effectiveness of our efforts to combat robocalls.