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No government or private company should be able to shut down wireless service in an emergency, several public interest groups told the Federal Communications Commission (FCC) in comments filed late April 30.
The Commission had asked for comments on the issue in the wake of a shutdown of service in San Francisco by the Bay Area Rapid Transit (BART) District.
In a joint filing, Public Knowledge, the Center for Democracy & Technology, the Electronic Frontier Foundation, the Benton Foundation Free Press, the Minority Media and Telecommunications Council, the National Hispanic Media Coalition, and the Open Technology Institute at the New America Foundation said that a service shutdown would violate a "general principle of providing access to wireless communications and preventing their interruption during emergencies has been a cornerstone of public safety policy" that started with the sinking of the Titanic 100 years ago
The groups argued that there have been no cases which would justify such a drastic step and in which the benefits would outweigh the harms. The filing said: "Deliberately interrupting wireless service, in nearly all cases, will mean disrupting the communications of every person in the affected area. Unlike the disconnection of a wireline connection, which can target an individual telephone facility, wireless interruption will necessarily prohibit the communications of completely innocent parties—precisely those parties closest to the site where the emergency is located or anticipated."
The groups noted that communications about an emergency aren't all transmitted via a 9-1-1 emergency system: "For example, individuals often provide information to non-emergency channels such as news outlets or publicly-accessible sites like blogs, Twitter, Facebook, or other social media services. Information disseminated in real time, whether to professional journalists or to the Internet at large, can serve valuable public safety purposes, informing first responders and other members of the public of hazardous or inaccessible areas and alerting people to important breaking developments."
Similarly, private companies or other entities should not have the power to shut down communications even though they might be under great pressure to do so, the groups said: " The Commission should be clear in its recommendations, rules, or statements that private entities should not interrupt wireless services during emergency situations."