FCC Releases Adopted 988 Georouting Item

On October 18, 2024, the FCC released the Report and Order and Further Notice of Proposed Rulemaking (“R&O” and “FNPRM” respectively) adopting a requirement for commercial mobile radio service (“CMRS”) providers to route wireless calls to the 988 Lifeline using georouting.  In addition, the FNPRM seeks comment on mandating georouting for text messages to 988.  The item was adopted at the October Open Commission Meeting.  Nationwide providers will be required to comply with the georouting requirements within 30 days after the effective date, and non-nationwide providers will have to comply within 24 months.  Comments on the FNPRM will be due 30 days after the date of publication in the Federal Register, and reply comments will be due 50 days after the date of publication.

The adopted item was largely consistent with the Draft item.  However, the FCC did add the following underlined language to paragraph 25 of the Order in connection with advocacy by CCA (as requested by GCI): “However, we recognize that current georouting solutions may rely on the IP-based capabilities of the Lifeline and wireless providers’ networks, which may impact wireless providers’ ability to transmit georouting data with wireless 988 calls over non-IP networks.  Therefore, the rules we adopt today require nationwide and non-nationwide providers to provide georouting data when available and offer flexibility for wireless providers to work with the Lifeline Administrator on a case-by-case basis to address any individualized network considerations.” The FCC also noted that “[t]he Commission will take further action, if necessary, to ensure that wireless providers are providing the Lifeline Administrator with georouting data when available to ensure the Administrator is capable of routing wireless 988 calls.”

Report and Order

The R&O adopts rules requiring CMRS providers to route calls to 988 based on the caller’s geographical location, while still protecting their privacy, as opposed to the current method of routing calls based on the caller’s area code.  Specifically, R&O adopts the following requirements:

  • Georouting Mandate for Wireless 988 Voice Calls – The FCC requires CMRS providers to (1) have the capability to provide georouting data with 988 calls to the Lifeline Administrator in a format compatible with the Lifeline’s routing platform; and (2) provide georouting data, when available, with 988 calls to the Lifeline Administrator sufficient to allow routing of the 988 calls by the Lifeline Administrator.
    • For the purposes of these rules, georouting is defined as “location data generated from cell-based location technology that is aggregated to a level that will not identify the location of the cell site or base station receiving the 988 call or otherwise identify the precise location of the handset.”
    • Calls using roaming are exempt from the georouting requirement and may continue to be routed using the caller’s area code and exchange, as they are today.
  • Compliance – The FCC requires nationwide providers to comply with the georouting requirement within 30 days of the effective date of the rules.  Non-nationwide providers must comply with the georouting mandate within 24 months of the effective date of the rule.
    • Nationwide CMRS providers are those providers whose service extends to a majority of the population and land area of the United States.  Non-nationwide CMRS providers include all CMRS providers other than a nationwide CMRS provider.
  • Routing to 988 Without Translation – The FCC modifies its rule to permit routing to the Lifeline without need for translation to the toll free access number and similarly codifies its 2022 waiver permitting covered text providers to do the same.

Further Notice of Proposed Rulemaking

The FNPRM proposes to require that covered text providers support georouting to the 988 Lifeline and tentatively concludes that, at a minimum, CMRS providers must support georouting for SMS text messages to 988.  The FCC tentatively concludes that a six-month compliance timeline would be appropriate for georouting of text messages.  The FCC seeks comment on this proposal, including technical issues providers may face in implementing georouting for text messages to 988.

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