988's 2022 Deadline Called Achievable, Despite Telco Claims
Despite telecom industry arguments it needs longer (see 2006230022), a 24-month nationwide implementation of the 988 suicide prevention hotline seems feasible, experts told us. Others see meeting that deadline being a big challenge, though everyone agrees the FCC isn't likely to budge further, having already compromised from an 18-month implementation deadline. The commission didn't comment. The draft order directing providers to have 988 operational by July 16, 2022, will be voted on at the July 16 commissioners' meeting.
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Many rural carriers already upgraded switching systems and can support 10-digit dialing, said Bridget Alexander White, JSI staff director. The difficulty involves ILECs with legacy switching systems in their networks, many at their end of life and no longer with vendor support, she said. They "will have what I call the 'heartburn'" of making 988 effective, she said. As long as service providers can start preparation now, two years "is a time frame the industry can work through," she said.
Telcos face legitimate issues of getting implementation done in two years, but "if the FCC doesn't hold your feet to the fire, nothing gets done," said Robert Jackson, Marashlian & Donahue lawyer. He said switch compatibility will be a challenge, but many should have been retired by now and 988 implementation is an opportune time for the tech upgrades that will be necessary in some cases.
Carriers may have an uphill climb making implementation happen in two years, and the draft order acknowledges some technology challenges but doesn't seem to understand them, said John Chiaramonte, consulting services president at 911 implementation consultancy Mission Critical Partners. Aside from the switches to be replaced and the testing to ensure calls are completed and go to the proper designation, lack of cost recovery is a hurdle, he said. "Can you do it in two years? I don't know." The FCC extended deadlines in the past on such issues as 911 location accuracy, but it's generally reticent to do so and carriers shouldn't count on one, he said.
The draft order's own analysis doesn't support a 24-month rollout, USTelecom told FCC officials, according to a docket 18-336 posting Tuesday. The group instead pushed for a staged implementation, which would cover 97% of homes in 18 months and "a moderately longer transition" for the remainder requiring more time. USTelecom said if the FCC proceeds with two years, prepare for the "distinct possibility" it won't be met. The association said the order should give more direction to the North American numbering plan administrator, and the FCC should monitor the number plan area (NPA) transitions and assess whether more time is needed: Consider making clear waivers might be available. The group had conversations with aides to all FCC members and with the Wireline Bureau. Multiple carriers either didn't comment or referred us to USTelecom.
JSI's Alexander White said it seems unlikely the FCC will compromise again, but if there's any wiggle room it would be on those areas still with seven-digit dialing: "I think 24 months is the compromise." Echoed Jackson, an extension would be surprising. He said it's more likely carriers making good-faith efforts but unable to make the deadline would get waivers or extensions.
The draft order language on dialing in specific geographic areas says waivers can be sought "for good cause" and state public utility commissions or others can file a waiver petition if they have evidence 10-digit dialing is inappropriate for a particular geographic area. There's no mention of waivers in the section covering the two years. Discussing a longer time frame, the order "refuse[s] ... to kick the proverbial can down the road or establish an effectively unenforceable rule when American lives are at stake."
The order estimates total cost of implementation at $367 million. It says carriers with big legacy infrastructure will have bigger costs than other voice service providers, but a cost recovery mechanism isn't the solution since costs will be proportional to size and quality of networks.