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Follow the 911 Georouting Model?

Wireless Industry: FCC Should Hold Off on 988 Text Georouting Mandates

Pointing to its work with the 988 Suicide & Crisis Lifeline on evaluating technological approaches to georouting text messages, the wireless industry is advising that the FCC wait to implement georouting rules. That view was contained in docket 18-36 comments Monday and last week. Meanwhile, mental health and related interests strongly supported a text georouting requirement. The commission's 988 georouting order approved unanimously at its October meeting included an NPRM about text georouting (see 2410170026).

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Georouting text message technology "remains in its infancy," with especially non-nationwide providers facing "significant technical and operational challenges," Competitive Carriers Association said in comments posted Monday. Additional time will prompt technological innovation and standardization and "is necessary before wireless providers can implement any solution," it said. In addition, CCA said, if the FCC adopts rules, they should be technology neutral, letting carriers pursue different approaches, similar to how the agency treated georouting calls to 988.

CTIA similarly advised that FCC intervention isn't needed and that if the agency acts, it should consider requirements "with consensus-based solutions developed by wireless providers and the Lifeline." That approach has resulted in technology-neutral regulations that let providers and Lifeline use current technology and network configurations while georouting mobile calls to 988, CTIA said. Lifeline, wireless providers and suicide prevention experts are hammering out formatting location information needed for routing texts to the appropriate local crisis center. CTIA said the course location information, such as cell ID and cell sector, used for routing texts to 911 so they're delivered to the appropriate public safety answering point could be used for Lifeline's needs while also avoiding disclosure of message senders' location data. It said the FCC should let wireless providers and Lifeline finish their collaborative efforts to identify consensus-based tech before imposing implementation timelines or regulatory obligations.

Rural Wireless Association said 988 text georouting requirements would disproportionately increase costs for small, rural, non-nationwide commercial mobile radio service providers. Such providers should be allowed to voluntarily implement georouting for 988 text messages, it added.

Some in emergency communications believe the technology is ready. Intrado Life & Safety said the record already shows georouting both voice and text "should be a basic expectation for 988." It said the 911 text georouting "success story ... could easily be extended to text-to-988 with minor modifications to carrier networks and [text control center] configurations and with reasonable development work by the 988 Lifeline Administrator, all while protecting a 988 texter’s expectations of privacy."

Seventy-seven local crisis contact centers nationwide in the Lifeline network, in addition to the national chat and text backup network, provide support through text messaging, Lifeline administrator Vibrant Emotional Health said. That growing number of crisis centers able to respond to local tests is enough to enable wide georouting of text messages, it said.

The growing number of texts to 988 shows a need "to ensure accessibility across all mediums," said the American Foundation for Suicide Prevention. The Association for Behavioral Health and Wellness noted that georouting texts "will reduce suicide mortality for populations with an increased risk of suicide and outweigh any potential costs." The National Alliance on Mental Illness urged that the Substance Abuse and Mental Health Services Administration, along with Vibrant, lead the effort to determine the information requirements to route text messages to appropriate call centers. Such determinations should be done transparently to ensure that people understand their privacy is protected when they reach out to 988, NAMI said. It backed the FCC's proposed implementation timeline of six-12 months.