Number Administration Oversight Working Group (NAOWG)

1. Number Administration Oversight Working Group(NAOWG) Report to the NANC on Feasibility of Establishing a 3-Digit Code for a National Suicide Prevention and Mental Health Crisis Hotline System February 14, 2019 Commissioner Paul Kjellander/Carolee Hall

2. Scope of Report On November 8, 2018, the FCC directed the NANC (through the NAOWG), by February 11, 2019, to prepare a report and recommendation on the feasibility of establishing a 3-digit dialing code for a national suicide prevention and mental health crisis hotline system. Specifically, the NANC was to: • Consider the feasibility of using each of the currently-designated 3-digit dialing codes to be used for a national suicide prevention and mental health crisis hotline system, including codes the FCC has established for other purposes; • Consider the feasibility of using a new easy-to-remember, 3-digit dialing code for such a system, including, for example, digits preceded by a star or number sign; • Outline the logistics of using a currently-designated or newly-designated 3-digit dialing code, including but not limited to the need for translations changes in the network and cell site analysis and reprogramming by wireless carriers;

3. Scope of Report (continued) • Estimate the costs associated with using a currently-designated or newly-designated dialing code, including costs incurred by service providers to carry out the above logistics, and any costs the federal government, states and localities may incur to implement the dialing code; • Recommend whether the FCC should designate a 3-digit dialing code for a national suicide prevention and mental health crisis hotline system and, if so, what 3-digit code it should designate; • Provide a proposed cost-benefit analysis comparing use of a 3-digit dialing code with the current use of a toll-free number to operate the National Suicide Prevention Lifeline; and • Provide any additional recommendations on the topic to assist the FCC with its report.

4. Assumptions The NAOWG made the following assumptions to establish a framework for its evaluation: • Any 3-digit code designated, whether an N11 code or a newly-designated code, should have ubiquitous reachability, i.e., it can be dialed the same from any type of phone, whether wireline, wireless or Voice over Internet Protocol (VoIP). • Any 3-digit code designated, whether an N11 code or a newly-designated code, will not start with a “0” or “1” to avoid costly network upgrades for the entire industry. • Any 3-digit code designated, whether an N11 code or a newly-designated code, may be reached at no charge to the caller, like the existing toll-free numbers for the National Suicide Prevention Lifeline are today. • Any 3-digit code designated, whether an N11 code or a newly-designated code, will be routed the same as calls to the existing toll-free numbers for the National Suicide Prevention Lifeline are routed today. • Any newly-designated non-N11 code cannot correspond to an already assigned area code (e.g., 202 cannot be designated as a new 3-digit code because the 202 area code is already assigned and in use).

5. Analysis of Alternatives The NAOWG analyzed four possible sets of alternatives for a 3-digit dialing code to be used for a national suicide prevention and mental health crisis hotline system: • repurposing of or expanding use of each of the existing N11 codes • a newly-designated non-N11 3-digit dialing code • a newly-designated non-N11 3-digit dialing code using Number Sign (#) or Star (*) • enhancing awareness of the existing toll-free numbers that provide access to suicide prevention and mental health crisis hotlines today

6. N11 Codes There are eight N11 codes, the scarcest NANP resource, and all appear to be widely used today: • 211 – FCC established to provide essential community service • 311 – FCC established to access non-emergency police and other government services • 411 – widely used for local directory assistance since 1930s • 511 – FCC established to be used for traveler information services • 611 – widely used by service providers for calls to customer repair and customer service • 711 – FCC reserved for Telecommunications Relay Service (TRS), for consumers with hearing and speech disabilities) • 811 – FCC established for states and localities to operate ‘One Call Notification’ to call before digging underground • 911 – FCC established for emergency services

7. Common Attributes of N11 Codes Below are highlights of the common attributes of the N11 codes: • The N11 architecture is an established abbreviated dialing plan. • Expanded or shared use has been considered in past regulatory proceedings, but was rejected. • Each N11 code is already in use today. • The use of each N11 code is well-known by the public already, making it difficult if not impossible to “scrub” references of existing uses. • Repurposing any N11 code introduces the risk that the national suicide prevention and mental health crisis hotline may receive unrelated calls. • Except for 211 and 911, the N11 codes’ current uses are completely unrelated to a national suicide prevention and mental health crisis hotline. • Repurposing the use of an existing N11 code would require resources to be directed to educating the public. • Repurposing or expanding the use of an existing N11 code creates the possibility that state and/or local governments may need to initiate a proceeding for implementation purposes.

8. Recommendation The results of the NAOWG’s analyses and recommendations is based entirely on data that are currently available, and focuses on the technical and operational implications of the different approaches. • The report documents the advantages and disadvantages of repurposing or expanding each specific N11 code. • The NAOWG does not recommend use of a new 3-digit dialing code at this time, due to the significant network and other operational changes that would be needed to establish such a code, and the absence of information indicating that such an approach will be more effective than, for example, improving awareness and usability of existing suicide prevention and mental health crisis hotlines. • The NAOWG does not support repurposing any N11 code, particularly the 911 and 611 codes. All remaining N11 codes are in use and are likely similarly well known by the general public. • The NAOWG recommends that the FCC issue a request for comments on its Report before providing it to Congress, or a Notice of Proposed Rulemaking before any final order establishing any 3-digit dialing code (N11 or otherwise). • The NAOWG ranked the alternative solutions, from least to most effort required, from a typical voice service provider implementation perspective (see next slide).

9. Recommendation (continued) From a typical voice service provider implementation perspective, the following ranks the alternative solutions, from least to most effort required. Costs may be minimal for some VoIP networks, but more extensive for legacy TDM networks. The ranking does not include the evaluation of changes required from platform service providers and, again, does not speak to the effectiveness of any given approach in meeting Congress’s policy goal of helping individuals in crisis. • Continue to use existing toll-free number(s): The existing toll-free number(s) provide direct access to counseling and service providers already route calls to toll-free numbers. Perhaps greater public awareness of the existing toll-free numbers is needed. • Expand the 911 code: There is already some relationship between the two, and 911 is nearly ubiquitous in national availability. Thus, expanding the use of 911 would be optimal from a service provider perspective as there would be no service provider implementation necessary, but input from the PSAP community is needed first. • Expand the 211 code: There is already some relationship between the two. Thus, expanding 211 may be most appropriate since some 211 platforms already provide suicide counseling resources, but 211 would need to be deployed ubiquitously. • Expand other N11 codes: With the exception of 911 and 211, there is no relationship between a national suicide prevention and mental health crisis hotline system and the current uses of the remaining N11 codes. • Establish a new non-N11 3-digit code: A new non-N11 3-digit code could provide callers with direct access to a hotline, but requires reprogramming of all switches within service providers’ networks and would require extensive planning and implementation intervals. Some networks may not support any new non-N11 code, and any code selected cannot match an existing area code. • Repurpose an N11 code: A repurposed N11 code could provide callers with direct access to a hotline, but in addition to all the efforts for establishing a new non-N11 3-digit code, repurposing of a N11 code would require vacating the current use and an idle period. • Establish a new non-N11 3-digit dialing code using Number Sign or Star: A new non-N11 3-digit dialing code using Number Sign or Star could provide callers with direct access to a hotline, but likely cannot be implemented ubiquitously in all networks, and conflicts with the Star being used as a prefix when enabling or disabling a vertical service (e.g., *72 to activate call forwarding).

10. NAOWG Meetings • The group held 18 meetings and discussions, averaging 2.5 hours each • Participation averaged 12 attendees per meeting or discussion

11. Contact Information The Honorable Paul Kjellander, Commissioner Idaho Public Utilities Commission paul.kjellander@puc.idaho.gov Carolee Hall Idaho Public Utilities Commission Carolee.Hall@puc.idaho.gov