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Date of Issuance: 5/21/2010

PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Communications Division

RESOLUTION T-17252

Consumer Programs Branch

May 20, 2010

R E S O L U T I O N

_________________________________________________________________

Summary

This resolution grants United Way HELPLINK/2-1-1 hereinafter referred to as HELPLINK, the authority to use the 2-1-1 abbreviated dialing code to provide information and referral (I&R) services to all of San Mateo County. This authority is granted for an indefinite term, and is subject to review upon a letter to the Commission showing sufficient grounds to revise or rescind the term.

Background

2-1-1 is the national abbreviated dialing code designated by the Federal Communications Commission to be used to phone non-emergency community I&R providers. Upon dialing 2-1-1, a caller will be routed to a referral service and then to an agency that can provide information concerning social services such as housing assistance, programs to assist with utility bills, food assistance and other less urgent situations not currently addressed by either 911 or 311 services. On January 23, 2002, the California Public Utilities Commission (Commission) instituted Rulemaking (R.) 02-01-025 into the implementation of 2-1-1 dialing in the State of California. In Decision (D.) 03-02-029, the Commission adopted regulatory policies and procedures to implement 2-1-1 dialing.

Included among these policies were guidelines and procedures whereby the Commission can certify I&R providers as eligible to purchase network telephone service that will enable them to receive calls from those who dial 2-1-1. Most of the procedures for I&R providers to follow in requesting authority to use the 2-1-1 dialing code are contained in D.03-02-029's Ordering Paragraph 2, quoted below:

2. Information and Referral (I&R) providers seeking authority to provide 2-1-1 service or to establish Regional Technical Centers for routing 2-1-1 calls to I&R service providers in California shall submit a letter to the Executive Director of the Commission approximately nine months before they plan to commence service. The letter shall contain the information detailed in the Service Provider Application Package in Appendix A, shall include a service rollout plan, and shall demonstrate compliance with the guidelines contained in Appendix A to this decision, along with letters of endorsement from community groups as described in Appendix A. The I&R providers shall serve this application letter on the parties to this proceeding on the same day as its submission to the Commission. The Commission shall publish a notice of this letter in its Daily Calendar. We establish a milestone of six months from the initial filing of this application letter for action by the Commission via a resolution resolving any issues. This application letter should be served on the appropriate incumbent local exchange carriers and on all parties to this proceeding.

HELPLINK filed a complete copy of its application letter1 requesting certification as the 2-1-1 service provider in San Mateo County, as well as a copy with information HELPLINK considered confidential redacted, that was received by the Commission's Executive Director on December 23, 2009. On the same date, HELPLINK sent to the service list for R.02-01-025 redacted copies of its application letter.

We remind local exchange carriers of D. 03-02-029, Ordering Paragraph 3, which states "Within four months of the filling of a letter by I&R providers or a regional technical center seeking to initiate 2-1-1 service, the incumbent local exchange carriers serving the territory over which the 2-1-1 service will be offered shall file advice letters to provide the 2-1-1 switch translation services required. Ordering Paragraph 4 states "All other incumbent local carriers serving a territory over which the 2-1-1 service will be offered shall provide the needed switch translation service, but may either concur in the price terms offered by Pacific or Verizon or submit their own cost support information. This filing shall follow that of Pacific or Verizon by no more than 30 days." Competitive local carriers must comply with Ordering Paragraph 7, which states in part, "Within one month of the filing of an advice letter by incumbent local exchange carriers to offer 2-1-1 switch translation services in a specific area, each competitive local carrier providing services in the affected areas shall submit an advice letter, under General Order 96-A2, demonstrating that it will offer 2-1-1 switch translation service at a reasonable rate to I&R providers on a timetable consistent with their rollout plans."

We remind payphone service providers of the same decision's Ordering Paragraph 6, stating in part "The providers of payphone services in an area in which 2-1-1 service will be offered shall end all non-conforming uses of 2-1-1 service within six months of their filing." i.e., within six months of the filing of the application letter by the I&R provider.

Notice/Protests

HELPLINK states that it mailed a copy of its application letter to SBC Communications now AT&T as well as to the service list for R.02-01-025, which includes the appropriate incumbent local exchange carriers. The Communications Division published notice of HELPLINK's application letter in the Commission Daily Calendar on December 24 through December 31, 2009. In response to HELPLINK application letter, the California Alliance of Information and Referral Services, Inc. (CAIRS) submitted a letter dated March 17, 2010 supporting the request of HELPLINK to use the 2-1-1 dialing code in San Mateo County. No other comments were submitted.

Discussion

The 2-1-1 application process prescribed by D.03-02-029 for potential I&R providers is divided into four major sections. The first section elicits information on the I&R provider's organization, structure, background, and experience.

HELPLINK is a non profit organization incorporated in the State of California. The documents included to support this categorization are its articles of incorporation, including by-laws, and letters from the Internal Revenue Service. HELPLINK is located at 221 Main Street, Suite 300, San Francisco, Ca 94105. The contact person is Edward A. Schoenberger, Director, at (415) 808-4304 and email at eschoenberger@uwba.org.

The United Ways of Silicon Valley and the Bay Area have been conducting discussions with community leaders in the private, civic, non-profit and public sectors exploring, promoting and planning for the development of 2-1-1 San Mateo since 2004. There have been over 40 participants involved in the discussions about how 2-1-1 should look in San Mateo. Involved parties included representatives from non profits focusing on health care and housing, serving children and working families, representatives of local state, and federal government and interfaith organizations. Through these discussions, San Mateo was identified as part of United Way of the Bay Area's service area.

This process identified the sources of long term sustainable funding assuming that government support would not be available, whether or not the implementation of 2-1-1 in San Mateo would negatively affect help lines currently operated by San Mateo County and whether or not 2-1-1 would fill a currently unfilled need in San Mateo County.

The county has existing information and referral services which serve specific segments of the population. These services include the Peninsula Library system, which provides information and referral services during library hours at each of the 34 library locations in San Mateo. The library uses information provided by interested private and public agencies to provide information. The library, however, does not have a call center and does not have the capacity to either provide this service on a seven day a week, 24 hour basis, nor does it have the ability to ensure that the information provided is comprehensive for San Mateo. The Peninsula Library System and other organizations doing information and referral within their own areas of expertise were not interested in becoming the San Mateo county 2-1-1 provider because they felt that 2-1-1 was beyond their mission and required building a phone service capacity that was outside their ability to create.  

It was therefore left to HELPLINK to provide 2-1-1 service to San Mateo County.

HELPLINK currently has three staff members engaged in planning and implementation of San Mateo County 2-1-1 program. The I&R database, utilized by 2-1-1 in the provision of I&R, will be maintained by HELPLINK consistent with Alliance of Information and Referral Systems (AIRS) standards.

HELPLINK has the internal protocols to ensure calls are handled consistent with guidelines developed by AIRS, including call handling, database development and maintenance and disaster response and preparedness.

HELPLINK provided a three year budget as part of their application. HELPLINK's budget and financial statements indicate a stable and solvent financial position. It appears that HELPLINK has appropriate budgetary planning procedures to support 2-1-1 service at current call volumes.

The second section of the prescribed application sets forth the required service conditions that a 2-1-1 service provider must meet. Section 2 of HELPLINK's application indicates that it does not and will not receive fees from referred organizations for referrals and no fees or charges levied to providers listed in its database.

HELPLINK staff currently provides I&R services in English, Spanish, Cantonese and Mandarin along with access to Tele-Interpreters multi-lingual translation service with access to more than 160 languages. TTY/TDY services are in place. All of these options will be available with the implementation of 2-1-1 in San Mateo County.

In the third section of the prescribed application, the applicant must demonstrate its understanding of and must agree to adhere to the standards for delivery of I&R services as established by AIRS. HELPLINK's Information and Referral program has internal protocols to ensure calls are handled consistent with guidelines developed by AIRS. AIRS' guidelines are the basis for the service delivery standards associated with use of the 2-1-1 dialing code as specified by the CPUC Decision 03-02-029. HELPLINK's application included descriptions of its policies in the areas of call assessment and follow-up, confidentiality, database standards, disaster readiness, reports and measures, cooperative relationships, training, marketing, and program evaluation. These policies appear to meet the standards established by AIRS.

In the fourth section of the prescribed application, the applicant demonstrates its level of community support by including letters of endorsement from organizations and agencies that are stakeholders in the health and human services network in its community. HELPLINK included in its application letters of endorsement from twenty-three different organizations and agencies in a broad range of health and human service fields throughout San Mateo County and an endorsement from Assemblyman Jerry Hill of the 19th Assembly District. These endorsements demonstrate broad community support.

In processing HELPLINK's 2-1-1 application, the Communications Division considered the input of the San Mateo County government because it oversees the operations of county hospitals, a county welfare department, and numerous other agencies and programs in the fields of health and human services, and is best equipped to evaluate whether an I&R provider is well suited to provide comprehensive I&R service in San Mateo County. California's size and diversity, in geography, politics, and many other categories, argue against a statewide "one size fits-all" approach to evaluating and choosing comprehensive I&R providers. County governments can best apply local standards and local knowledge to this difficult but important task. On December 8, 2009, the San Mateo County Board of Supervisors, Mark Church, President, sent a letter endorsing HELPLINK's application to serve as the 2-1-1 provider of San Mateo County residents and employees. The Commission values the input of the San Mateo County Board of Supervisors on this matter, and takes official notice of its action.

D.03-02-029 did not specifically address the length of time for which the Commission's grant of authority to use the 2-1-1 dialing code should be made. Utilities and other frequent participants in Commission proceedings generally know that most Commission decisions, resolutions, and actions can be later modified or rescinded if a showing of sufficient grounds to do so is made in a filing before the Commission. However, most I&R providers and county governments are not frequent participants in Commission proceedings, and may benefit from some clarification of this point. The grant of authority to use the 2-1-1 dialing code in a county or group of counties is for an indefinite term and may be revised or rescinded if a showing of sufficient grounds to do so is made to the Commission. For the reasons cited in the previous paragraph, the Commission should consider a resolution by the San Mateo County Board of Supervisors as a crucial part of any showing that the authority to use the 2-1-1 dialing code for comprehensive I&R service for San Mateo County should be rescinded, reassigned, or modified. A letter to the Commission's Executive Director could serve to initiate such a process. Any such process should provide notice to all affected parties and an opportunity to be heard.

The Communications Division concludes that the application letter filed by HELPLINK meets the requirements set forth in the Commission's order and recommends that the Commission approve this filing. Commission approval is based on the specifics of the application letter, and does not establish a precedent for the contents of future filings or for Commission approval of similar requests.

This is an uncontested matter in which the resolution grants the relief requested. Accordingly, pursuant to P.U.Code Section 311 (g) (2) and Rule 14.6(c) (2) of the Commission's Rules of Practice and Procedure, the otherwise applicable 30-day period for public review and comment is being waived.

Findings

1. United Way of the Bay Area, hereinafter referred to as HELPLINK sent its application letter for certification as the 2-1-1 service provider for San Mateo County to the Commission on December 23, 2009.

2. CAIRS submitted written comments in support of HELPLINK's application for provision of 2-1-1 services in San Mateo County on March 17, 2010. No other comments were submitted.

3. HELPLINK's application provides sufficient information to meet the four major sections of the 2-1-1 application process required by D. 03-02-039.

4. Mark Church of the San Mateo County Board of Supervisor sent a letter to the Commission on December 8, 2009, endorsing HELPLINK's application to serve as the 2-1-1 provider for San Mateo County.

5. CD concludes that HELPLINK's application meets the requirements established by D. 03-02-029 to use the 2-1-1 dialing code.

THEREFORE, IT IS ORDERED that:

1. HELPLINK is granted the authority to use the 2-1-1 abbreviated dialing code to provide information and referral (I&R) services to all of San Mateo County.

2. This authority is granted for an indefinite term, and is subject to review upon showing sufficient grounds to revise or rescind the term. Any process to contest, revise, or rescind this authority shall provide notice to all affected parties and an opportunity to be heard.

3. If HELPLINK cannot implement 2-1-1 dialing within a year after the Commission's approval of United Way of San Mateo County's application for provision of 2-1-1 service in San Mateo County and the needed tariffs of the telecommunications service providers ordered in Ordering Paragraphs 3, 4, and 7 of D.03-02-029, then, barring further Commission action, the certification of HELPLINK shall lapse so that another I&R provider may apply to offer service in a service territory containing San Mateo County.

4. HELPLINK shall notify the Director of the Communications Division in writing of the date 2-1-1 service is first rendered to the public, within five business days after service begins.

This Resolution is effective today.

I hereby certify that the Public Utilities Commission at its regular meeting on May 20, 2010 adopted this Resolution. The following Commissioners approved it:

1 The terms "application letter", "letter" and "application" used herein mean the package of materials the prospective I&R provider files with the Commission by letter to the Executive Director, as specified in D.03-02-029, and are not a formal application to the Commission as described in the Commission's Rules of Practice and Procedure.

2 General Order 96-A has since been replaced by General Order 96-B.

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