T-Mobile Pushing Against Any 988 Text Georouting Mandate for Now
T-Mobile is urging the FCC to hold off on instituting a text-to-988 georouting requirement, saying it could disrupt collaborations between wireless providers and the 988 Suicide & Crisis Lifeline administrator. That view was expressed in docket 18-336 comments posted Friday, as the FCC is seeking input on 988 text georouting privacy issues (see 2503030002). The 988 call georouting order, which FCC commissioners approved in October, included an NPRM about text georouting (see 2410170026).
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The wireless industry and the 988 Lifeline are working on identifying 988 text georouting options that maintain the privacy of those seeking help, CTIA said. Lifeline administrator Vibrant Emotional Health has indicated it would need six to 12 months to identify key collaborators, define requirements, consider solutions, and develop and verify a proof of concept, CTIA added.
Pointing to the wireless industry's work with Vibrant and the federal Substance Abuse and Mental Health Services Administration, T-Mobile said regulatory action "could complicate or hinder" the development of solutions. In addition, the FCC's proposed six months for developing and implementing a solution "is unrealistic." It will take at least 18 months to develop, test and deploy "a thoughtful, privacy-forward solution."
CX360 said the FCC should allow covered text providers at least 12 months from the finalization of text-to-988 georouting requirements to comply. Both it and Intrado Life & Safety told the FCC about how their routing offerings would meet 988 text georouting needs.
A coalition of mental health organizations and allies -- including the National Alliance on Mental Illness, American College of Emergency Physicians, National Association of Counties and the Police, Treatment, and Community Collaborative -- said ensuring the privacy of people contacting 988 "is of paramount importance to the long-term success of 988, and to the wellness of our country." The coalition didn't discuss policy specifics. The Association for Behavioral Health and Wellness called for following national best practices concerning data security. It said text-to-988 georouting should use only county-level data, not the texter's specific location, as a way of minimizing user-specific data collection.
Text georouting can't involve non-consensual geolocation of people in distress, the Electronic Privacy Information Center and the mental health advocacy group Wildflower Alliance said. They said people needing 988’s support would be more likely to use it if there were an explicit prohibition on geolocation by 988 providers and a clear explanation of the process for getting the texter’s precise location. Inviting but not requiring the texter to manually provide a location "may be the most cost-efficient and generally efficient method for georouting." They urged the FCC to create "heightened protocols" to safeguard data that gets collected, such as ensuring providers and vendors meet basic cybersecurity requirements. In addition, they said the FCC should recommend that providers direct texters to use encrypted communication channels when possible.
EPIC and Wildflower said the Wireline Bureau should expect arguments that Section 222 of the Communications Act -- which governs customer data privacy -- doesn't apply to text messages. While EPIC has argued that Section 222 authority applies beyond voice service, "the stakes are too high to rely on this authority alone."