Trade Groups: 988 Georouting Is Fine Without Further FCC Action

Carriers are working on implementing 988 georouting and the FCC needn't interfere with mandates and rules, telecom trade groups said in docket 18-336 comments this week. Commissioners in April adopted an NPRM proposing the georouting requirement (see 2404250054).

With the 988 Suicide and Crisis Lifeline soon able to route most wireless 988 calls to a crisis center close to a caller's location, there's no reason for the FCC to adopt rules on that issue, CTIA said. If the FCC takes that route, its rules shouldn't undermine the georouting solutions already implemented, it said. If the FCC instituted a general obligation to provide georouting data to the 988 Lifeline with IP-based wireless 988 calls, that would be consistent with current implementation, it said. The Competitive Carriers Association said avoiding 988 rules would let nationwide providers proceed with 988 georouting solutions in progress. Any 988 rules the FCC implements should allow flexibility for carriers and provide at least 24 months for non-nationwide carriers to reach compliance, CCA said. Echoed T-Mobile, "no further regulatory action is needed at this stage because implantation of the solution is imminent."

Clearly there is support for "a tailored, measured approach" where 988 georouting isn't mandated for small, rural, non-nationwide commercial mobile radio service providers, the Rural Wireless Association said. If the commission wants a role, it should give those CMRS providers at least 36 months to comply, allocate funds to subsidize their efforts and be technology neutral when on routes providers take for georouting. The Alliance for Telecommunications Industry Solutions said the FCC should focus on identifying requirements and let providers deploy solutions that meet these requirements. The alliance said its Emergency Services Interconnection Forum is conducting a 988 georouting study that will include a technical description of necessary steps and the architecture and signaling needed to support 988 georouting.

Urging what it called "commonsense safeguards in place to prevent non-consensual use of 988 caller data," the Electronic Privacy Information Center said lacking such safeguards would have "a chilling effect for people who would otherwise seek support by calling 988." EPIC called for prohibiting the use of geolocation data, prohibiting carriers from sharing 988-related data even in cases when subscribers opted in to sharing their proprietary network information, and ensuring small carriers and vendors have adequate cybersecurity protections for 988 data.

Any route the FCC takes on georouting requirements should allow use of either legacy, digit-based technology that gives Lifeline a digit-based destination code representing a coarse geolocation or allow calls going directly to a designated, in-state, 988 IP point of interconnection, such as an emergency services IP network (ESNnet), said Intrado Life & Safety. Routing through state ESNnets won't undermine privacy expectations as the actual location wouldn't be transmitted, it said.