Industry Seeks Time, Flexibility to Comply With Safe Connections Act Rules

Industry and advocacy organizations sought time and flexibility to comply with new rules for the FCC's implementation of the Safe Connections Act and improving access to communications services for survivors of domestic violence. Comments on the NPRM posted Thursday in docket 22-238 showed broad support for the commission's proposals and sought minor clarifications (see 2303130007).

Commenters welcomed the commission's proposal to establish a centralized database for providers to rely on when omitting calls or texts made to a hotline from consumer-facing call logs. Doing so "promotes consistency, predictability, and efficiency," said USTelecom. The group asked that providers be required to come into compliance "after the database is established" so providers can finish developing their systems. The database should also be "updated and maintained with regularity," said the National Domestic Violence Hotline. The group noted it "maintains one of the nation’s most robust databases" that "could provide the foundation for a central database."

The FCC should "provide as much clarity as possible regarding its expectations," said the Competitive Carriers Association. The group noted carriers will need "clarity" about customer proprietary network information as they develop their systems. CCA also sought a compliance date for line-separation requests and omitting calls or texts to domestic abuse hotlines of no sooner than 24 months from the rules' effective date at least for smaller carriers.

Wireless providers will need to make "significant changes to their existing and unique operational systems," said CTIA. The group asked the FCC to clarify that any rules on call log omissions and line separations "supersede any conflicting provisions of the commission’s rules or state requirements." The FCC should also "consider a provider’s ability to identify consumer-facing logs in the first instance and to omit certain data, as well as law enforcement’s ongoing need for access to such information," said Verizon. The carrier sought a "more flexible, outcome-oriented approach" for wireless providers to perform line separation requests.

Let providers process line separation requests for account holders canceling an abuser's line and requests made by "anyone other than the account holder" by moving that person's line to a new account, said NCTA. The FCC shouldn't establish any "expectation or requirement" that providers confirm the authenticity of documents on alleged abuse, the group said. NCTA backed the proposal that providers must agree to separate a line "without regard to the rate plan the account holder may have chosen." It also asked that providers be allowed to remove "covered hotlines" from all call logs rather than requiring individuals to make a request.

Don't adopt "overly burdensome requirements" for survivors seeking a line separation, said the New York State Public Service Commission. The PSC asked the FCC to ensure calls or texts to a hotline are omitted "regardless of whether they are a survivor or have sought a line separation request." Colorado's Boulder Regional Emergency Telephone Service Authority (BRETSA) raised concerns about requiring survivors to provide financial documents to prove eligibility for Lifeline. "Accessing financial documents in the abuser’s possession may place the person fleeing the relationship in peril," BRETSA said.

The National Lifeline Association backed designating the Lifeline program instead of the affordable connectivity program to provide emergency communications support for survivors. "Given that Lifeline subscribers are also automatically eligible for ACP, expanding Lifeline eligibility will ensure that survivors gain access to both Lifeline and ACP benefits," NaLA said. A coalition of consumer organizations, led by the Electronic Privacy Information Center and National Network to End Domestic Violence, asked the FCC to let survivors self-certify their need for financial assistance rather than through third-party certification, saying it would otherwise be "both burdensome and counter-productive."