I'm glad that some people are thinking about details like this. It feels like the world is increasingly indifferent to scenarios a typical tech worker has not experienced. Someone actually had to stop and think outside of their bubble, or at least convince their colleagues to think outside of theirs. It took some effort to get that approved, no doubt.
What's frustrating to me about your comment is that you and the person you're replying to seem to basically agree on the pertinent points, but you've chosen to make an irrelevant, unfalsifiable semantic argument.
On cell phone plans that still charge per minute of talk, how is this going to work? Will those carriers make domestic violence hotline calls be free and not count against your total minutes? If not, then won't the resulting discrepancy between the amount of the bill and the number of minutes for each individual call on it make it obvious what happened?
They haven't decided details like this. The actual notice of proposed rulemaking [1] explicitly asks for feedback on this:
> 117. We also seek comment on whether we should establish exceptions...? How often are toll calls or usage-fee-inducing mobile calls
and text messages made to hotlines?
> 145. Are there any potential inconsistencies between the rules that we might adopt to ensure the privacy of calls and text messages to hotlines and other Commission rules or state regulations? For example, would omitting toll calls that incur separate charges from consumers’ bills conflict with our truth-in-billing rules? Are there any other potential inconsistencies? Should we explicitly resolve them and, if so, how? What role might disclaimers issued by service providers play?
It also sounds like the sought some industry comment already and had any "insurmountable" objection:
> 112. ...We note that there is no discussion of such concerns in the record in response to the Notice of Inquiry ... Indeed, neither of the two trade associations representing substantially different segments of what would be covered providers and/or providers of wireline voice service raise insurmountable issues relating to selectively omitting calls and text messages from call and text logs.
I also suspect most domestic volence hotlines are toll free.
Domestic abuser: "I tallied only 748 minutes of calls across these 9 pages, and after subtracting the 500 included minutes in your plan, we were only charged an additional $12.28 instead of the expected $12.40. Explain yourself!"
The most problematic ones, where this is most important, will definitely do so. A seriously unhinged domestic abuser is almost identical to an extremely scary stalker in demeanor, except they also live in your house and have access to an incredible amount of information about you.
Or... The abuser searches "why is my phone bill higher than my total minutes <carrier>" and the results are "Here are the 1 things that count against on your minutes, but don't show up on your bill: domestic violence calls"
Or they call the carrier and ask why the numbers don't add up. The carrier can't say "idk but still pay us". It's more complex than just saying that nobody ekll notice a few cents
You have to really be pinching pennies to get one of those plans. Even on Aldi Talk, you'd only pay €3 more per month for unlimited calls and SMS than you would for a data-only plan.
I wouldn't say it's common in Germany. I just checked some providers and most of them just have one line saying "Phone and SMS flatrate to all German networks" in their plans. The only differentiation between plans these days is how much data is included.
> Service providers must also “omit records of calls or text messages to certain hotlines from consumer-facing call and text message logs,” so that abusers cannot see when survivors are seeking help.
I can see some of the other part of the Safe Connections Act being new, but were calls to a domestic violence hotline showing up on consumer-facing cellular (and POTS) records for the last 20+ years?
