Advocates Seek Local Engagement on Draft FCC NOI for Survivors of Violence

A draft FCC notice of inquiry aimed at improving access to communications services for survivors of domestic or sexual violence should include privacy concerns and encourage partnerships with entities at the local level, advocacy organizations told us (see 2206230069). Commissioners will consider the item Thursday, which would seek comment on obstacles survivors face to obtaining broadband services and ways to amend Lifeline or the affordable connectivity program to encourage enrollment among survivors.

The “first and most important obstacle” for survivors of violence is “simply having access to a phone,” said Aditi Bhattacharya, New York City Anti-Violence Project deputy director-client services. The phone should be “preferably a smartphone" with “enough minutes that they are able to use to make a call when it is safe for them,” Bhattacharya said.

The FCC should partner with local organizations that “have a very deep understanding of the needs and the realities of a community,” Bhattacharya said. That includes some “back-end integration” to ensure the commission’s efforts are “culturally and community relevant,” she said.

The agency could also work with telecom providers to “put practices in place that allow a survivor more safety and options when a survivor suspects they are being monitored, stalked, or watched using items such as parental controls, apps, or number tracking,” the Hotline spokesperson said. The FCC declined to comment.

"Access is in and of itself extremely important,” Bhattacharya said, but “the barrier to access is affordability” and knowing how or where to access technology offered through government programs. The draft NOI would seek comment on ways to increase access to Lifeline and the affordable connectivity program as proposed in the Safe Communications Act, which would modify the programs' rules to expand access to survivors.

Isolation and financial abuse are “some of the strongest tactics an abusive partner will use," emailed a National Domestic Violence Hotline spokesperson: “Equitable and affordable access to phone and internet services can be lifesaving for survivors.” It has “become even more important during the continued COVID-19 pandemic when many survivors are still in closer, or more frequent, proximity to the one causing harm,” she said.

The proposed Safe Connections Act would allow the FCC to expand access to Lifeline and ACP for survivors who are “suffering from financial hardship” and can verify through an official document that “an individual who uses a line under the shared mobile service contract has committed or allegedly committed a covered act against the survivor or an individual in the survivor’s care.” That may be challenging for some survivors, Bhattacharya said, so the FCC should expand the list of accepted forms of verification to organizations that assist survivors because "we are where our community will come."

The Hotline implemented a texting service on its toll-free number in 2021 “in which access to internet plays a vital role,” the spokesperson said. The Hotline projected an estimated demand of about 4,000 texts for the entire year, she said: “The Hotline has surpassed that by a factor of 10, answering 41,017 text messages in just the first seven months.”

The draft would seek comment on a proposed measure in the Safe Connections Act requiring the FCC to maintain a central database of covered hotlines that providers would omit from consumer call logs. A potential concern is that there are “multiple one-stop-shops" and “not every database had the most current information” during the pandemic, Bhattacharya said, adding she's "skeptical about to what extent a [transgender] person of color is going to call a national number to get access to a local number."