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Federal Register / Vol. 86, No. 111 / Friday, June 11, 2021 / Proposed Rules
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switched telephone network PSTN or not. For purposes of the Commissions text-to-911 rules, interconnected text messaging applications enable consumers to send text messages to all or substantially all text-capable U.S.
telephone numbers and receive text messages from the same, while noninterconnected applications only support communication with a defined set of users of compatible applications but do not support general communication with text-capable telephone numbers. The Commissions text-to-911 rules include interconnected text messaging services but exclude non-interconnected applications because they do not provide the ability to communicate with text-capable U.S.
telephone numbers.
21. As in the text-to-911 rules, we propose to apply our text-to-988
requirements to interconnected text messaging services, thereby excluding non-interconnected applications from the requirements. We seek comment on this approach. This approach is also analogous to the Commissions decision in the 988 Report and Order to apply to providers that access the PSTN on an interconnected basis to reach all Americans and any providers that access the PSTN on an interconnected basis to reach all Americans. We note that the Commissions Truth in Caller ID
rules provide an exemption for messages sent over an IP-enabled messaging service to another user of the same messaging service, except for an SMS or MMS message, which similarly operates to exclude noninterconnected text messaging services.
Since the services provided by the Lifeline require two-way communication and, by definition, noninterconnected text messaging applications cannot support two-way texting with all or substantially all text-capable U.S. telephone numbers, we believe it is unlikely that these services would be technically capable of supporting text-to-988 functionality. We seek comment on this view. Are there any tools available to the Commission to mitigate the potential for consumer confusion regarding the availability of text-to-988 across different text messaging platforms and technologies, particularly with respect to noninterconnected text messaging applications?
2. Routing Texts to 988
22. We propose to require that covered text providers route covered 988 text messages to the Lifelines current 10-digit number, 1800273
8255 TALK, and we seek comment on this proposal. This proposal is
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consistent with the Commissions decision for routing calls to 988 in the 988 Report and Order. In the 988 Report and Order, the Commission required that service providers transmit all calls initiated by an end user dialing 988 to the current toll free access number for the Lifeline, finding that a centralized routing solution will allow for faster implementation of the 988 3-digit dialing code, lower costs to maintain 988 routing, and provide continued easy access to Lifeline by callers with disabilities. We preliminarily believe that there are similar benefits to routing texts to 988 to a single, centralized number and seek comment on this view.
23. There is support in the record thus far for routing to the Lifeline. CTIA
supports directing texts sent to 988 to the Lifeline as a central point for receiving such communications, consistent with the Commissions mandate for routing 988 voice calls.
Vibrant Emotional Health, the administrator of the Lifeline, argues in support of text-to-988 functionality integrated into the current Lifeline structure for routing voice and chat services, with oversight squarely within the role of the Lifelines administrator.
We seek comment on these assessments.
24. We anticipate that requiring covered text providers to route to a single destination provides SAMHSA
and the VA with flexibility to develop their own routing solutions among the local crisis centers, including adding new crisis centers in the future, as compared to requiring covered text providers to implement additional updates or routing changes as more centers are added. Callers to 1800
2738255 TALK can reach the Veterans Crisis Line by pressing option 1 to connect with one of three linked call centers in New York, Georgia, or Kansas. For other calls, calls to the Lifeline from anywhere in the United States are routed to the closest certified local crisis center according to the callers area code or, should the closest center be overwhelmed by call volume, experience a disruption of service, or if the call is placed from part of a state not covered by Lifelines network, the system automatically routes calls to a backup center. We seek comment on this preliminary analysis. Do the current obligations to route voice calls to 988 to the Lifeline 10-digit number offer any opportunities for streamlining implementation or reducing costs associated with routing texts to 988 to the same number?
25. In the alternative, we seek comment on whether instead to follow a model more comparable to the text-to911 architecture, whereby covered text
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providers route directly to a PSAP by requiring routing directly to a Lifeline local crisis center or to a Veterans Crisis Line crisis center. We anticipate that this approach would be significantly more costly than centralized routing and seek comment on this preliminary view.
Is it easier to route texts to a single number than to individual crisis centers? As the Veterans Crisis Line is not currently set up for geographic distribution, would this architecture be appropriate for messages by Veterans or Service Members? Are covered text providers able to leverage existing textto-911 systems to reduce costs if required to route texts to 988 directly to local crisis centers? In the 988 Report and Order, the Commission recognized that some commenters expressed there may be benefits to routing voice calls to individual crisis centers, such as familiarity with a callers area and potentially easier coordination with local emergency services, but ultimately concluded that the advantages associated with routing to a single number outweighed the benefits of localized routing. Does that rationale apply here? Are there benefits to routing texts to the individual crisis centers that are unique to text messages, such as providing localized support to the public in the vicinity of the crisis center? What are the costs or drawbacks to covered text providers to route texts to the Lifeline 10-digit number versus the local crisis centers? Which approach will lead to speedier implementation, and how should that impact our analysis? Is there another alternative approach, other than centralized routing or routing by crisis center, that we should consider?
26. Currently, Veterans and Service Members may dial the Lifeline to reach the Veterans Crisis Line via voice call, but the Lifeline texting service and the VAs short code texting service require contacting separate numbers. How should we account for this distinction in evaluating what rules to adopt to ensure that Veterans, Service Members, and their families are able to reach the Veterans Crisis Line directly and promptly? We seek comment on whether and how we can act to facilitate integration of the Veterans Crisis Lines separate short code-based texting service into text-to-988 routing. Are there specific actions that the Commission should take to allow users to text 988 and reach both the Lifeline and Veteran-specific assistance? For instance, should we require covered text providers to provide an automated inquiry as to whether the texter is a Veteran or Service Member and route
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