Don't Totally Mirror 911 Rules for Text-to-988, T-Mobile Says

The FCC's text-to-911 rules should help define which providers are subject to text-to-988 obligations, but 988 and 911 calling are fundamentally different and should be treated that way, T-Mobile said in docket 18-336 reply comments posted Wednesday. It said location-based routing isn't feasible or practical for 988 calling. It said bounce-back messages about the National Suicide Prevention Lifeline not being available by text should be originated by the Lifeline. It said since carriers don't have any control over whether Lifeline can accept those forms of texts or calls, an enhanced communications feature carrier mandate won't ensure those features are part of text-to-988. CTIA said the FCC should define “covered providers” and “covered services” for text-to-988 consistent with its text-to-911 rules, with “covered services” focusing on the existing capabilities of short message service (SMS), while leaving the record open to consider nascent and evolving messaging technologies. It said the agency should require covered providers to direct text-to-988 messages to the Lifeline just as voice calls to 988 are. Mitel Cloud Services urged exempting non-interconnected applications and services from the requirements. It said some non-interconnected applications can't use SMS, and many that include messaging only provide messaging to other subscribers to the application but don't allow messaging outside these groups. A coalition including the National Association of the Deaf, the American Council of the Blind, the Autistic Self Advocacy Network, the National Council on Independent Living and Paralyzed Veterans of America said the FCC should move toward making direct video communication an alternate means of reaching the Lifeline. It urged the FCC to consider including Real-time text and rich communication services formats in the definition of a text message. Crisis Text Line said the agency should use it to help provide texting service through 988, such as a nationwide backup or overflow support provider. There has been some telecom industry disagreement about the July 2022 deadline for a text-to-988 deadline (see 2107130064).