988 Text Georouting Seeing Industry Pushback
The FCC's proposed requirement that covered text providers support the georouting of text messages made to the 988 Suicide & Crisis Lifeline to the appropriate local crisis center is receiving opposition. In docket 18-336 replies posted Friday, some communications industry interests and allies challenged the FCC's proposed implementation time frame and urged the agency to hold off for now on georouting requirements. Mental health interests didn't file reply comments but have urged the agency to act (see 2408080061). The 988 call georouting order approved unanimously at the FCC's October meeting included an NPRM about text georouting (see 2410170026).
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A georouting requirement isn't needed because wireless carriers are heading that way voluntarily, AT&T said, but if the FCC must impose 988 text georouting rules, it said, it should hold off for the moment. Work of the wireless industry, Lifeline and its vendors to assess 988 text georouting "is still in its infancy," the carrier said. Challenges to sending georouting data without compromising senders' privacy are still being identified, it said. AT&T said the FCC can help now by monitoring that collaboration. It said closer to the end of that process is a better time for talking about rules, including a compliance deadline.
AT&T said that if the agency imposes rules, they should closely follow those for georouting 988 calls, even if the calling and texting georouting technologies are dissimilar. It said any rules should be technology neutral and limited to the SMS format -- the only one Lifeline supports. The carrier said rules shouldn't apply to 988 text messages sent while roaming or when georouting data is unavailable. It said the text-to-911 framework isn't a good model for 988 rules.
Echoing the argument that rules aren't needed in light of wireless-Lifeline collaborations, CTIA said any texting requirement needs to retain Lifeline's central routing role. The record shows it's premature to set implementation deadlines, and the FCC should wait for further developments in evaluation of text-to-988 georouting technologies being done by Lifeline and wireless providers, it said.
Comtech said the FCC's proposed compliance time frame is too short. Agreeing, Intrado said it also believes georouting rules should be limited to SMS messaging.
Voice on the Net Coalition said location technology limits make it "infeasible" for covered text providers offering over-the-top text messages to implement georouting. It said the georouting of voice calls, being implemented now, should inform "if or when" a texting mandate makes sense. Holding off on rules also would give more crisis centers time to add texting capabilities, VON said.
Withdraw the 988 texting proposal altogether, given the big privacy concerns it poses, urged the Conservative Political Action Coalition Foundation's Center for Regulatory Freedom. CRF said a text georouting requirement seems to reflect the National Suicide Hotline Designation Act's intent, but actual implementation carries with it feasibility concerns and "would ultimately compromise the confidentiality of the 988 Lifeline," with the federal government having information on every SMS message sent to Lifeline. It also challenged the need for georouting texts, arguing that few calls made to 988 result in actual suicide attempts, and thus "it is unlikely that current 988 misrouting greatly exacerbates the current rate of suicide among 988 Lifeline users."