Letter to FCC Regarding Ex Parte Meeting on Petitions of Blackboard Inc. and Edison Electric Institute
On Friday, September 18, 2015, several representatives of consumer groups held several meetings with FCC staff regarding interpretations of the scope of consent to be called on a cellular phone. The primary purpose of the meetings was to discuss the consumer groups’ filings relating to the Petitions for a Declaratory Ruling filed by Blackboard, Inc., and Edison Electric Institute and American Gas Association (Edison). Both petitions ask the Federal Communications Commission (Commission) to allow automated and prerecorded calls and texts to cell phones without prior express consent under the broad rubric of emergency calls. The petitions also raise the issue of the “scope of consent.” This letter contains an analysis of these issues by CFA and allied consumer groups, as well as a clear set of guidelines for interpreting these issues.
