988 Implementation Will Take Longer, Be Costlier Than FCC Thinks, Telecom Interests Say

The FCC "vastly underestimates the costs, complexity, and implementation timeline" 988 will require, USTelecom said. A dialing delay as a solution to 988's use in some areas as a central office code (NXX) won't work, with either too-long or too-short delays, it said. Coordinating a 10-digit dialing plan in those NXX areas will push the 988 implementation deadline out longer than 18 months, it said, saying 211 doesn't have those technical problems. It said carriers need more than 18 months to replace multiple legacy switches, and the FCC gave longer timelines for N11 implementation that didn't require all the switch work. It resisted carriers having to bear their own costs for implementing a three-digit code, saying the agency in the past let states regulate cost recovery for telecom providers, and those providers already "are undertaking other massive changes to their networks" such as deployment of secure handling of asserted information using tokens and secure telephone identity revisited technology.

Having callers face a dialing delay in area codes where seven-digit dialing exists could lead to confusion and such a delay can't be implemented on some switches, Verizon said. It said the FCC instead should require 10-digit dialing where 988 is used as an NXX code, with "an appropriate transition period." It said hotline call centers appear to need more than 18 months before they can receive and deal with the potential volume of 988 calls. It said implementation deadlines coming before the hotline and call centers are capable of handling that volume could cause user confusion about whether 988 is genuinely available. The carrier said it likely could implement 988 across its wireless footprint, interconnected VoIP services and a lot of its local service territory in the 18-to-24-month period the agency typically allowed for implementing new N11 codes, but many models of legacy wireline switches, including many in Verizon’s network, can't support any three-digit code other than an N11 code.

Also calling that 18-month deadline feasible at least for its wireless and VoIP networks is AT&T, though it said implementation for its legacy wireline network "would take substantially longer." It said one bottleneck is the limited number of technicians who can upgrade or replace many of the legacy switches and do the extensive switch translations. A way to avoid those technical hurdles, switch upgrades and conversions to mandatory 10-digit dialing is to go instead with expanded use of 211 instead of 988, it said. Establishing 988 for a nationwide three-digit suicide prevention hotline when it's in use in some areas a central office code or NXX code "is not an insurmountable problem" but will require careful consideration by the FCC, NCTA said.

Also suggesting 211 over 988, ATIS said implementing it in unserved areas would be quicker than implementing 988 nationwide. If the FCC goes with 988, implementation would warrant a phased approach rather than a nationwide flash cut, it said. Telecom industry experience has been that implementing 10-digit dialing with one area-code overlay typically takes 13 months, so implementing 10-digit dialing in all affected area codes would easily take more than 18 months because providers don't have the resources to do all those implementations simultaneously, it said.

CTIA backs use of 988 but said the FCC should look at an implementation deadline that's feasible for all telecom providers, not just wireless, and indicated 18 months might be too little time. Before creating texting-based mandates, the agency should be sure the hotline centers receiving 988 calls have the technical and operational ability to also handle texts, it said. Also backing 988, a variety of deaf and hard-of-hearing advocacy groups including the National Association of the Deaf, the Hearing Loss Association of America and the National Technical Institute for the Deaf said the FCC needs to make sure their populations can use the hotline, such as via a video relay service. Entercom said with texting being an increasingly dominant mode of communication, the FCC should look at texting capabilities for this "Lifeline."

Multiple crisis and mental health organizations also commented, generally in support of a three-digit dialing code. The National Association of Crisis Organization Directors said implementation of the FCC’s plan needs to include a funding mechanism guaranteeing crisis center sustainability and expanded capacity.