FCC Releases FNPRM on Applying the SCA to Connected Car Services

On April 8, 2024, the FCC released a Further Notice of Proposed Rulemaking (“FNPRM”) seeking comment on whether to extend the rules implementing the Safe Connections Act (“SCA”) to connected car services to further protect domestic violence survivors.  Specifically, the FCC seeks comment on the following:

  • The Connected Car Services Available Today:  The FCC seeks information on how connected car services are offered to consumers.  The FCC notes that responses to the Chairwoman’s inquiry to automotive manufacturers earlier this year suggest that the offerings generally consist of “(1) services offered directly to consumers or (2) wholesale connectivity services offered to auto manufacturers or to the manufacturer’s contracted third-party telematics service provider.”  The FCC seeks comment on this understanding and any additional information on how consumers purchase connected car service, control access to their data, and control tracking features that may be offered.
  • Applying the SCA and FCC’s Implementing Rules to Connected Car Services:  The FCC seeks comment on what, if any, changes to the rules implementing the SCA could help address the impact of connected car services on domestic violence survivors.  The FCC notes that “the FCC’s rules implementing the SCA . . . could apply to connected car services that involve a ‘shared mobile service contract’ offered by a ‘covered provider’ as defined under the rules and would require a provider to respond to a valid request for a line separation.”  The FCC seeks comment on this position, whether the FCC’s definitions need to be modified to adequately cover connected car services, to what extent auto manufacturers are “reselling mobile connectivity,” and how the SCA line separation requirements might apply in the connected car space.
  • Other Actions to Protect Survivors Using Connected Car Services:  The FCC seeks comment on other authority the Commission could use and other steps the Commission could take to help prevent the misuse of connected car services, including how it can encourage providers of such services to take steps to protect survivors, and other steps such providers should consider to protect survivors.
  • Promoting Digital Equity and Inclusion:  The FCC seeks comment on how its proposal may promote or inhibit advances in diversity, equity, inclusion, and accessibility, as well as the scope of the FCC’s relevant legal authority.

Comments will be due 30 days after the date of publication in the Federal Register.  Reply comments will be due 60 days after the date of publication in the Federal Register.

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