Basic Service Definition

TD believes changing the definition of Basic Service to specifically include access to CRS by the 711 abbreviated dialing code is essential to the successful accommodation of deaf and disabled persons. Several facts support this change in definition. 711 service meets three of the four criteria necessary for petitions to make amendments to the definition of Basic Service as detailed in D-96-10-066, Appendix B Section (4) (D)(3).

a. The use of CRS is an essential component for the deaf and disabled community's participation in society.

b. The FCC mandates that all carriers provide 711 service by October 1, 2001, so 100% of residential customers subscribe to the service.

c. The qualitative and quantitative costs of the service are outweighed by the benefits as detailed in the FCC's Second Report and Order.

The fourth criteria [(d) availability of the service, or the number of subscribers would not increase without intervention] is not applicable because carriers are required to provide the service to 100% of the state's residential customers.

The addition of 711 service to the definition of Basic Service is consistent with the current requirement in D-96-10-066 to provide "access to telephone relay service as provided for in PU Code 2881." We also agree with the workshop report commenters that the 711 abbreviated dialing code does not represent a fundamental change to the definition of Basic Service but merely ensures the inclusion of an abbreviated form of a mechanism that is part of the existing definition of Basic Service. The definition of Basic Service must be modified in order to ensure that both the rate mechanisms and the breadth of coverage for 711 calls to CRS stay consistent with those already detailed in Decision 96-10-066 and PU Code 2881.