V. Are the Proposed Guidelines and Application Package Attached as Appendix A of R.02-01-025 Consistent With the Public Interest?

R.02-01-025, the rulemaking instituting this proceeding, proposed guidelines and an application package in Appendix A that I&R providers would need to complete before certification by the Commission that they are eligible to provide I&R services.

No carrier or consumer group voiced any objections to these proposed guidelines and application package. In particular Pacific and Verizon stated that they "generally agree with the guidelines proposed in Appendix A."²³ AT&T, WorldCom and XO, on the other hand, take "no position on whether the proposed guidelines in Appendix A are consistent with the public interest."²⁴ Similarly, the Small LECs²⁵ and Roseville,²⁶ take no position on this matter. ORA and TURN characterize the application and guidelines as "generally acceptable."²⁷ They note, however, that additional guidelines may prove necessary should more than one service provider apply for certification as an I&R provider in a particular area.

Cox voices "no objection" to the information sought in Attachment A. However, Cox argues for the selection of a single statewide service provider, and states that "the provider should be selected on its ability to provide statewide service . . ."²⁸ To support the selection of a single statewide provider, Cox argues that the Commission "should ensure that the 2-1-1 designated service provider have the necessary resources to provide operator-assisted referrals on 24-hour, seven-days-per-week basis statewide."²⁹

CAIRS sponsored the selection guidelines and application package in its original petition that led to the institution of this proceeding. CAIRS also provided the most extensive discussion of these materials:

The proposed guidelines and application provide an appropriate mechanism to ensure that the use of the 2-1-1 abbreviated dialing code occurs in an efficient manner in furtherance of the public interest. They require a potential 2-1-1 provider to demonstrate sufficient expertise and financial integrity to support 2-1-1 service at the county level. Furthermore, a potential 2-1-1 provider is required to make an Information and Referral Specialist available twenty-four hours a day at no cost to the calling party. A potential 2-1-1 provider needs to demonstrate adherence to professional standards, which generally reflect standards developed by the Alliance of Information and Referral Services (AIRS), the national professional membership organization of the information and referral service providers. These standards include (1) providing an acceptable level of service, including access to people with disabilities, (2) developing and maintaining health and human service databases, (3) developing service reports and measurement standards, and (4) developing and maintaining cooperative relationships with other I&R providers. Potential 2-1-1 providers should be able to demonstrate an understanding of these standards and agree to adhere to these standards in delivering 2-1-1 service. The proposed guidelines and application also require potential 2-1-1 providers to demonstrate a strong level of community support for its application to become a local 2-1-1 provider. Finally, the proposed guidelines and application permit collaborative relationships amongst potential 2-1-1 providers, which minimize the possibility that I&R providers will submit competing applications.³⁰

Our own review of the application materials and criteria comport with the positive views of CAIRS and the parties in this proceeding. The application to provide 2-1-1 service is divided into four major sections. The first section elicits information on the organization, its structure, its background, and experience. The second section sets forth the required service conditions that a 2-1-1 service provider must meet. These include the minimum geographic scope of service, a prohibition on the acceptance of per referral fees from referred organizations or fees for inclusion in a referral database, the charge structure for callers, and the necessity of having live call takers 24 hours a day, seven days a week, and the steps taken to ensure accessibility to all, regardless of language or disability.

The third section requires that applicants comply with standards that conform to those established by AIRS for the delivery of I&R services. In addition, AIRS establishes standards for establishing and maintaining a database of service providers, for maintaining service in the event of a disaster, for collecting data and producing reports, and for establishing cooperative working relationships with others operating in the same service area.

In the fourth section, the application materials require that the 2-1-1 service provider demonstrate strong community support, including letters of support from groups serving particular needs. The list is generally comprehensive, but we note that it fails to solicit endorsements from veterans groups. Since there are a variety of governmental and community service organizations providing service to veterans, we have added veterans groups to the organizations eligible to provide endorsements.

We find that the standards and application procedures established for I&R providers do meet the public interest. These standards not only ensure the selection of qualified groups, but will also link California's I&R providers to a national professional community and establish procedures that will assist in maintaining and improving services. We thus plan to adopt the applications standards and forms contained in Appendix A of R.02-01-025 with the modification to accept endorsements from veterans groups. These are attached as Appendix A to this document.