What Rules and Regulations Should the Commission Adopt to Ensure That 2-1-1 Dialing Is Implemented for All Californians in Furtherance of the Public Interest?

The purpose of the third and fourth questions proposed in R.02-01-025 concerning 2-1-1 tariffing and regulation was to examine those technical issues affecting the design of the telecommunications network, the routing of calls, and the interconnection of the different public carriers that have implications for who can and should implement the 2-1-1 service. The Scoping Memo expanded upon these two questions, and posed additional specific questions concerning the telecommunications networks and the steps needed to implement 2-1-1 dialing. The questions of the Scoping Memo became the subject of the technical workshop, the Workshop Report,³¹ and the comments and replies by the parties to this proceeding. Resolving the issues contained in these questions will permit implementation of 2-1-1 dialing in California. We therefore turn our attention to the Workshop Report and the responses of parties to it.

A. Workshop Report

The workshop "addressed the technical changes telephone companies must make, and how to effect those changes, in order to introduce 2-1-1 in the state."³² The Workshop Report makes recommendations in seven different areas:

1. Each I&R provider should serve the area of an entire county or form consortia to serve multiple counties.

2. A network architecture in which 2-1-1 dialing directs a call to a single "800" (or 8YY) number appears to be simpler and faster to implement than other options. Nevertheless, the Workshop Report recommends that the Commission not mandate a particular routing option since it is unclear whether another option would prove less expensive in the long term.

3. 2-1-1 calls should be able to terminate either at a county I&R provider or at a Regional Technical Center (RTC), which would then complete the routing of the call to a specific I&R provider.

4. Universal availability of 2-1-1 service will require switch translations to ensure the proper routing of calls originating on a local network.

5. The Commission should allow LECs [both ILECs and CLCs] to recover their costs for switch translation services. Recovery of switch translation costs for wireless carriers is beyond the scope of this proceeding.

6. The Commission should not set deadlines for 2-1-1 implementation, but should require periodic status reports.

7. The Commission should immediately order payphone providers to desist from utilizing 2-1-1 as the number for customers to call for refunds because this use is incompatible with the new 2-1-1 services.³³

Although the Workshop Report did not recommend that the Commission mandate the use of a particular network design, a large portion of the Workshop Report explored four different network designs for implementing 2-1-1 dialing in California. These include: 1) the routing of all 2-1-1 calls to a single 8YY number, with subsequent routing to a County I&R; 2) the routing of all calls to a single 8YY number, with subsequent routing to a Regional Technical Center (RTC) for subsequent telecommunications services and further routing; 3) variable routing, either through handoff to a "local" number or handoff to an 8YY number depending on the call's origin and location of an RTC; and 4) variable routing, either through handoff to a "local" number or handoff to an 8YY number, depending on the calls origin and location of the County I&R.

The analysis in the Workshop Report reached several favorable conclusions concerning options that use 8YY routing. The Workshop Report notes that "[r]epresentatives of all carrier types at the workshop (ILEC, CLEC, IEC) expressed their preferences for a network architecture in which 2-1-1 calls are translated and routed to an 8YY number; several carriers stated that the fewer the `point to' numbers used, the simpler and better they can implement this."³⁴ The Workshop Report also notes that carriers stated that the use of a single "point to" number permits a simpler and less costly implementation of 2-1-1 dialing. The Workshop Report also observes that a simple implementation of a single "point to" number would eliminate the need for a statewide "database" and complex policies controlling access to the database. Moreover, with the implementation of 2-1-1 dialing as a form of 800 service, then 2-1-1 service will likely consist almost entirely of the repackaging of existing telecommunications services. In particular, the Workshop Report notes that "[s]witch translation in itself is not a new service, although the use of the 2-1-1 number will be new."³⁵

On the other hand, the Workshop Report notes that CAIRS supported the variable routing solution because it felt that it would lead to lower costs and noted that "many calls that people dial today to I&R providers are local calls and are free to the caller as well as to the I&R provider."³⁶ Moreover, the Workshop Report, as mentioned earlier, recommends that the Commission not mandate a particular network design, but give the referral agencies and the utilities the freedom to determine what alternative best serves their needs.

The Workshop Report also identified several nonconforming uses of 2-1-1 dialing. The Workshop Report states that participants noted that 2-1-1 is "currently used by some payphone providers for refund purposes"³⁷ and would need to be discontinued to permit callers using payphones to reach the social services relying on 2-1-1 calling. In addition, the Workshop Report notes that Cox reported "that the wireless industry has petitioned the FCC to use 2-1-1 for wireless information."³⁸ Unlike the payphone situation, there is no FCC mandate for eliminating this use of 2-1-1 by wireless carriers at this time, and the Scoping Memo limited the scope of this proceeding to wireline carriers. The Workshop Report recommends that the Commission "proceed toward implementation of 2-1-1 by wireline carriers for I&R purposes, to conform with the federal mandate that 2-1-1 is reserved for I&R service provision."³⁹

Regarding a timetable for implementing 2-1-1 dialing, the Workshop Report recommends that the Commission avoid setting deadlines for the start of 2-1-1 services but instead rely on a series of milestones to insure progress. In particular, the report notes that it is unlikely that 2-1-1 service will have a simultaneous statewide rollout. Instead, consistent with the presentation of CAIRS, the Workshop Report anticipates that individual I&R providers will drive implementation as they make their own plans for service rollout. Because of the likely rollout of services at different times throughout the state, the Workshop Report recommends that the CPUC "actively monitor 2-1-1 implementation by requiring periodic status reports and establishing milestones for implementation.⁴⁰

In addition to the questions posed for the Workshop in the Scoping Memo, the Workshop Report noted:

· that customer education would prove necessary as the service was deployed,

· that the participants felt that the call should be free to the calling party, and

· that calls from payphones raised complex issues concerning routing and cost recovery.

The Workshop Report, however, did not make any further recommendations concerning these matters.

B. Comments and Replies on Workshop Report

The Workshop Report elicited comments from Pacific and Verizon (which filed jointly), Roseville, CAIRS, WorldCom, Allegiance Telecom, California Payphone Association, the Small LECs, AT&T, Cox, and Nexcare Collaborative (Nexcare), which also filed a motion to intervene. Pacific and Verizon (filing jointly), CAIRS, AT&T, and Cox also filed reply comments.

Pacific and Verizon note that "routing calls by county is technically unfeasible given the companies' current database and network architecture systems."⁴¹ In addition, they note that, contrary to assumptions in the Workshop Report, a LEC can handle an 8YY call that originates and terminates in the same LATA. In reply comments, they recommend that the Commission should "not mandate how 2-1-1 calls are routed;"⁴² that the Commission coordinate the deployment of 2-1-1 service with the schedule to eliminate 2-1-1/repair dialing for payphones; and that the Commission "not require carriers to file their costs with `stakeholders,' such as consumer groups and information and referral providers."⁴³ Finally, we note that in opening comments on the rulemaking, Pacific and Verizon requested that the Commission permit the carriers to have flexibility in the design of the 2-1-1 service and the decision of whether to offer it via a tariff, via a tariff developed on an Individual Case Basis, or via contract.⁴⁴

Roseville supports the Workshop Report's recommendation that the Commission "not mandate a particular architecture for implementation of 2-1-1 dialing."⁴⁵

The Small LECs note that their small number of switches would cause the cost to develop a tariff based on a cost study to exceed the potential revenues that the service will generate. They request that the Commission allow small carriers "to concur in any switch translation tariff rate that has been approved for another carrier."⁴⁶

AT&T states that the Workshop reached agreement on key issues, including: that carriers should be able to recover all costs for 2-1-1 implementation from I&R providers; that the Commission should not mandate 2-1-1 termination service - i.e., the requirement that a carrier terminate I&R calls to any I&R that requires it; that the Commission set milestones, not deadlines, for implementation of 2-1-1; that the Commission not select a single I&R provider to serve the entire state; that telephone local service areas do not overlap and do not generally follow county lines; and that calls should be routed by NPA-NXX protocols.⁴⁷ AT&T also asks the Commission to order an all 8YY approach to implement 2-1-1 dialing in California since that approach minimizes switch translation tasks and avoids complicated issues concerning reciprocal compensation agreements between local carriers and provides a simple means to compensate payphone providers. In addition, AT&T stated that "[c]arriers agreed that such an order [to require all LECs to offer 2-1-1 service to their end-users] is unnecessary and may present regulatory complications."⁴⁸

Cox laments the lack of information on traffic flows and volumes that would be needed to evaluate the different methods for structuring a 2-1-1 service product. Cox argues that "until the Commission convenes another workshop whereby the interested I&R parties provide actual documentation of demand and traffic projections so that the service architecture costing and pricing can be known, a single statewide 8YY number for 2-1-1 dialing is the only reasonable implementation strategy."⁴⁹ Cox also reiterates its support for a single statewide I&R provider, which it claims would offer both cost and service advantages. Finally, in commenting on the Workshop Report, Cox claims that it "failed to acknowledge Cox's position" and "overlooked the value of all these benefits."⁵⁰

In Reply Comments, Cox says that parties generally agree that "the technical efficiency of a single 8YY translation will result in quicker implementation of 2-1-1 services statewide and in lower carrier costs."⁵¹ Cox argues that permitting variable routing would enable a carrier "to entirely subvert the 2-1-1 implementation process"⁵² and argues that 8YY calling is the "most cost efficient and easily implemented solution presented at the Workshop."⁵³ Finally, Cox points out that the Commission has not required competitive local exchange carriers to submit cost data and that the use of 8YY calling solves cost issues because it is an existing tariffed service.

WorldCom compliments the Workshop Report as "thorough and balanced"⁵⁴ and proceeds to comment on the Report's findings and recommendations. WorldCom agrees that I&R providers should serve "a geographic area delimited by county boundaries and no less than an entire county."⁵⁵ WorldCom views the recommendation that the Commission should not mandate how to implement 2-1-1 dialing in California as a practical compromise, although WorldCom "strongly supports the TD's judgment that an all 8YY routing solution is the fastest and simplest to implement."⁵⁶ WorldCom supports the recommendation that the Commission refrain from mandating whether 2-1-1 calls should terminate at an I&R provider or at an RTC. Concerning the provision of 2-1-1 origination service, WorldCom notes that the FCC has "already issued a regulatory mandate for 2-1-1 service"⁵⁷ and observes that "the FCC made the duty to provide 2-1-1 call origination dependent on the request for service from the information and referral provider. "⁵⁸ WorldCom also observes that "2-1-1 service will not be universally available unless that Commission mandates that all LECs and payphones provide 2-1-1 origination service."⁵⁹ WorldCom also agrees with the recommendation that LECs be permitted to recover their switch translation costs, that the Commission not set deadlines for implementing 2-1-1 statewide and that the Commission should order payphone providers to "desist for using 2-1-1 as the number to call for refunds."⁶⁰

Allegiance notes that it provisions non-mandated N11 service in other states and "many counties exercise their option not to participate in the N11 service. "⁶¹ Allegiance states that it "is reasonable and prudent to provision 2-1-1 abbreviated dialing by programming switches to "point to" an 8YY County I&R Provider or "point to" an all-service 8YY."⁶² Allegiance argues that variable routing "has many cost and technical limitations"⁶³ and therefore Allegiance does not support such an alternative. Allegiance further states that there is no reason to select a single I&R provider to serve the entire state, and observes that the county is the natural dividing line for the provision of 2-1-1 service. Finally, Allegiance supports voluntary provision of 2-1-1 service, and an implementation approach that relies on milestones, rather than regulatory deadlines.

The California Payphone Association (CPA) opposes the Workshop Report's recommendation that the Commission "immediately order payphone providers to desist form utilizing 2-1-1 as the number for customers to call for refunds."⁶⁴ CPA also argues the "FCC has not mandated immediate abandonment of non-conforming uses of the 2-1-1 code, but instead has provided for gradual conversion . . ."⁶⁵ Furthermore, CPA argues that the Workshop Report's recommendation to eliminate "charges to payphone users for 2-1-1 calls must not be acted on without due consideration of the complex issues it entails."⁶⁶ Finally, CPA states that if the Commission plans to impose rules on payphone providers, then CPA requests evidentiary hearings.

Nexcare provided information to the Commission concerning alternative models for providing referral services to callers. In particular, Nexcare noted that there are economies of scale in referral services, and that there are efficiencies in linking telephone based referral services to Internet referral services. Nexcare suggests "that it is possible that some categories of referral might be better handled on a state-wide basis, while others might be better handled on a regional or county-by-county basis."⁶⁷

CAIRS supports the Workshop Report as "accurately reflecting the dialogue between parties . . . "⁶⁸ CAIRS, however, uses its comments to suggest refinements to the recommendations of the Workshop Report. CAIRS, for example, supports the Workshop Report's recognition "that information and referral services have historically been provided at the county level,"⁶⁹ but recommends that the Commission accept collaborative efforts of different I&R providers to bring 2-1-1 service to a county. CAIRS also asks that the Commission "scrutinize underlying cost data in order to keep switch translation and related charges just and reasonable."⁷⁰

CAIRS also urges that the Commission recognize the complexities of implementing 2-1-1 service, and urges that the Commission "anticipate the procedural steps and timelines necessary to evaluate 2-1-1 applications."⁷¹ This implies that we should allow Commission staff several months to review applications. Further, CAIRS states that the costs of implementing a "point to number translation are transparent to the characteristics of the point to number."⁷² As a consequence, CAIRS believes that carriers can develop tariffs/costs for number translations without the need of a routing plan from CAIRS. CAIRS further distinguishes between call termination services, which are available already via tariff or contract, and 2-1-1 switch translations, for which there are no current tariffs.

In its Reply Comments, CAIRS urges that the Commission "initiate implementation efforts to fulfill the FCC's mandate."⁷³ CAIRS observes that although routing calls along county lines with 100% accuracy may be technically infeasible, it is possible to route calls along county lines with a high degree of accuracy and points out that I&R agencies have developed "cooperative arrangements" for "handling misdirected calls."⁷⁴ Thus, attempting to route calls along county lines makes sense as long as I&R providers develop procedures for handling calls that will necessarily be misdirected. CAIRS further notes that the Workshop explored multiple ways of routing 2-1-1 calls, and recommends that the Commission not mandate a single solution. Finally, CAIRS notes that although Pacific and Verizon have not provided information on switch translation costs to the Commission, several states have already implemented this service and developed either tariffs or contract prices, and recommends that "[a]t a minimum, the Commission should obtain this cost information from Pacific and Verizon."⁷⁵

C. Discussion: Permit I&R Providers to Implement 2-1-1 Calling Flexibly With ILECs; Set Implementation Steps to Permit Sequential Rollout of 2-1-1 Service

To implement 2-1-1 calling in California, it is necessary to resolve those issues that arise from the technology of the telecommunications networks and the issues that arise in routing the call. In California, 2-1-1 calls can originate on the phones served by incumbent LECs (ILECs), by competitive local carriers (CLCs) on facilities leased from ILECs, by CLCs using their own lines, by "smart" payphones housing small computers, or by "dumb" payphones using ILEC services.⁷⁶

For all calls placed to 2-1-1 service providers, the initial switch receiving the call (or intelligent payphone) will determine how to route it. The Workshop Report identified two different situations: either the switch will deliver all calls to an 800 number and the carrier who owns it for transport and termination (the 8YY solution) or the switch will determine whether the destination point is local and handle the call, or whether the destination point is not local, and then deliver the call to an 800 number for further transport and eventual termination (the variable routing solution). In no case, however, will it be possible to route calls strictly by county because a LECs central office frequently provides telecommunications services that straddle a county's boundaries.

A switch can translate a 2-1-1 call to an 800 number or to a local number, but not both. Concerning this choice of routing, 8YY versus variable, we see no reason why the Commission should make a blanket order mandating a particular implementation plan for 2-1-1 call origination service. Although many parties have pointed out the simplicity of an 8YY solution, CAIRS stated that information and referral providers are willing to pay for the implementation of 2-1-1 dialing using a variable routing alternative. Moreover, Verizon and Pacific, the incumbent LECs whose switches will provide service to most callers, have asked the Commission to not mandate a specific program for implementing 2-1-1 dialing. For this reason, we will leave it up to these ILECs and CAIRS to develop their own program for implementing 2-1-1 call origination service on their networks.

There is no evidence in this record that would indicate that there would be a cost difference for switch translations under either an 8YY or a variable routing solution. Concerning the costs of implementing 2-1-1 service, we note that although CAIRS has repeatedly stated that information and referral providers are willing to pay reasonable costs, it has also stated that "it is critical to obtain information from carriers regarding the costs."⁷⁷ We note that there are Commission procedures in place that require ILECs to provide cost support information for tariffed services, whether the tariff is a standing offer or an Individual Case Basis (ICB) tariff offering. If such information is competitively sensitive, the filing party may seek a protection order. Under this procedure, the cost information will be submitted to the Commission for review by the Telecommunications Division, and to parties executing non-disclosure agreements. This procedure offers the ILECs protection of this sensitive information while preserving the rights of customers to protest unreasonable rates.

We will permit local exchange carriers other than Pacific or Verizon to concur with the tariffs of either Pacific or Verizon. As the Small LECs point out, their small number of switches would make the cost of developing cost-based rates higher than the revenues that they could reasonably expect to receive from this service. Any of the Small Incumbent LECs, however, will have the opportunity to provide their own cost data and a proposed price for the switch translation services should they find Pacific's and Verizon's prices unacceptable. Consistent with this Commission's prior decisions, CLCs may propose their own prices and will not be required to submit cost data to support their 2-1-1 switch translation services unless they are directly challenged as unreasonable or the Commission undertakes such an inquiry on its own motion.

We note that the ILECs' switches serve all customers of the ILECs and those customers receiving service from CLCs who provision their lines with facilities leased from ILECs. Thus, the offering of 2-1-1 origination service by Pacific and Verizon will provide coverage to a very large number of California access lines.

Concerning the responsibility of other CLCs for 2-1-1 services, we note that although some parties ask us to not mandate that all LECs provide 2-1-1 origination service, WorldCom has accurately noted that the FCC has already issued a regulatory mandate for 2-1-1 origination service upon request from an entity to use 211 for I&R purposes. Thus, as part of our implementation of 2-1-1 service, we will require all LECs to provide 2-1-1 origination service when they provide service in areas where 2-1-1 service will be implemented. All calls should be routed to their destination, and we cannot envision a legitimate regulatory policy that would permit the non-completion of 2-1-1 calls simply because they were made by customers not served by an ILEC. Moreover, we note that CAIRS expects to pay the reasonable costs of programming switches to provide this service, whether incurred by CLCs or ILECs.

Although we have declined to order a specific method for implementing 2-1-1 origination service by ILECs, we note that Cox and AT&T have made important points concerning the ease of implementing an 8YY solution. In addition, Cox notes that the FCC has not resolved the petitions for reconsideration and cautions against ordering an expensive implementation alternative for providing 2-1-1 service. We further note that virtually any implementation of 2-1-1 will require some use of an 8YY service to transport and terminate some calls. To make this inexpensive implementation alternative available, we require that CAIRS or any group providing a 2-1-1 routing or information service ensure that there is at least one 8YY number available that these carriers can use to route calls. We will permit wireline carriers other than Pacific and Verizon to route all 2-1-1 calls to an 8YY number. Upon the FCC's final resolution of pending matters, the Commission will entertain a "Petition to Modify" our decision granting CLECs permission to route all calls to an 8YY number.

We also note that CPA has raised numerous issues concerning compensation for the use of payphones by those dialing for 2-1-1 service. At the same time, CAIRS argues that all calls should be free to those dialing the 2-1-1 number. For those "smart" payphones that contain computers that can translate a 2-1-1 number to another number, redirecting the call to an 8YY service can enable the payphones to complete the call with no charge to the calling party while permitting the payphone operator to receive payment from the 8YY carrier consistent with the FCC's rules concerning these calls. We believe that this ensures fair compensation to the payphone providers and reliable service to Californians.

For other 2-1-1 calls, CPA argues that there is no basis for California to make these calls free. CPA notes that Section 276(b)(1)(A) of the 1996 Telecommunication Act states that:

. . . the Commission shall take all action necessary to prescribe regulations that establish a per call compensation plan to ensure that all payphone service providers are fairly compensated for each and every completed intrastate and interstate call using their payphone.

CPA further notes that:

While remanding certain other aspects of the FCC's orders on other grounds, the Court of Appeals held that "the statute unambiguously grants the [FCC] authority to regulate rates for local coin calls," and gives the FCC "an express mandate to preempt State regulation of local coin calls."⁷⁸

In reply, CAIRS notes that this Commission has facilitated 8YY call routing and states that it believes that "the FCC has provided the CPUC with sufficient authority to implement 2-1-1 and address nonconforming use, including requiring the availability of 2-1-1 dialing from payphones without the need for a coin drop."⁷⁹ In particular, it is important to note that no pay phone should be able to collect compensation for treating 2-1-1 calling as an 8YY call and again as a local call.

For other payphones lacking the ability to translate a number, we permit the payphone providers to make whatever arrangements they deem necessary to have the 2-1-1 call treated as an 8YY call for compensation purposes. However, absent FCC clarification of the appropriate charge for 2-1-1 calls dialed from a payphone, we do not set a charge for these calls.

From the information provided by CAIRS in this proceeding, it is clear that there are no plans to make a flash-cut implementation of 2-1-1 calling statewide. Indeed, CAIRS projects a phased rollout of 2-1-1 service in California.⁸⁰ Among other things, the rollout depends on the identification by CAIRS and approval by the Commission of an organization that will become the 2-1-1 service designee for the county. We envision that CAIRS and/or the 2-1-1 service provider or an integrated group of 2-1-1 service providers in a particular area will submit a formal letter to the Executive Director of the Commission consistent with the Service Provider Application package shown in Appendix A to this Decision, for review and certification of the I&R provider(s) and a service rollout plan. The Commission's staff will place a notice in the Commission's Daily Calendar and will review the letter and supporting materials. The Commission's staff will apply the Guidelines for Staff Review included in Appendix A to this Decision and prepare a resolution for the Commission's consideration to accept, reject, or modify the proposed plan. These letters should be served on the ILECs, as appropriate and on all parties to this proceeding.

Simultaneous with this submission, the ILECs serving the areas over which 2-1-1 service is proposed shall submit to the Commission a tariff, an ICB tariff, or a contract to provide the switch translation services that the 2-1-1 service will require via an advice letter. The Commission's advice letter procedures provide public notice of the plans for rolling out 2-1-1 service in an area and affords an opportunity for the Commission to determine that prices are reasonable.

Concerning the timing for implementing 2-1-1 service, we decline to set deadlines for the review of the letters requesting certification of I&R providers and the commencement of 2-1-1 service. We will instead set a combination of milestones and deadlines for the implementation of 2-1-1 calling.⁸¹ In particular, we expect that the Commission would require approximately six months to review and approve a specific 2-1-1 proposal, including the certification of I&R providers.⁸²

In addition, we will set a deadline of four months following the filing of a 2-1-1 proposal by an I&R provider for receiving from the affected ILECs an advice letter proposal for providing 2-1-1 call origination service covering the specific area over which the 2-1-1 service will be implemented.⁸³ The review of the price and cost of 2-1-1 service should have a milestone of Commission action within six months of the tariff filing with immediate effectiveness. In other words, incumbent local exchange carriers should be able to implement 2-1-1 origination services no later than six months after filing. We anticipate that once an ILEC has obtained approval of a tariff or contract to provide 2-1-1 origination service, subsequent advice letters submitted by that ILEC may be approved on an expedited basis. Incumbent local exchange carriers other than Pacific or Verizon may offer 2-1-1 origination service at Pacific's or Verizon's rates without providing cost data and may follow Pacific's or Verizon's filings by 30 days.

Furthermore, we will set a deadline for each payphone provider to discontinue nonconforming uses of the 2-1-1 number from payphones in those affected geographic areas when 2-1-1 service will be offered. The payphone providers should also ensure that their payphones can handle 2-1-1 calls when dialed by those seeking information and referral services.

Similarly, CLCs providing service in an area affected by a 2-1-1 service proposal shall file an advice letter setting forth the carrier's 2-1-1 charges within 30 days of the ILECs filing of a proposed tariff to provide 2-1-1 service. ⁸⁴ The CLCs should be able to offer 2-1-1 origination service simultaneous with the offering of this service by ILECs, or approximately five months following their filing. The CLCs may use 8YY calling to implement 2-1-1 origination service. To make this inexpensive implementation alternative available, we require that CAIRS or any group providing a 2-1-1 routing or information service ensure that there is at least one 8YY number available that these carriers can use to route calls. Pending final resolution of matters by the FCC, we will permit facilities-based wireline carriers other than Pacific and Verizon to route all 2-1-1 calls to an 8YY number.

As a result of these deadlines and milestones, we anticipate that all the Commission approvals and network changes needed to provide 2-1-1 origination and I&R services should be in place ten months after the initial filing by an I&R provider. If for some reason the I&R provider proves incapable of implementing 2-1-1 service within a year of the Commission's approval of the 2-1-1 providers and the needed tariffs, then the Commission's approval should lapse so that other potential I&R providers can offer services in this area.

In summary, the milestones and deadlines look as follows:

Event	Milestone or Deadline	Action
1	Day 0	Filing of Letter with Executive Director of the Commission seeking approval of 2-1-1 implementation proposal and specific I&R providers.85 This letter should be served on ILECs, as appropriate.
2	Deadline Event 1 plus 120 days	Pacific and Verizon's Proposals to regarding 2-1-1 origination services. Payphone Telephones initiate process to relinquish use of 2-1-1 service for access to refund and repair service.
3	Deadline: Day 150 or Event 2 plus 30 days	Other ILEC proposals for 2-1-1 origination services.
3	Deadline: Day 150 or Event 2 plus 30 days	CLC Proposal to offer 2-1-1 Origination Services via 8YY"point to" methods.
4	Milestone: Day 180 or Event 1 plus 180 days	Commission approval of Resolution designating I&R providers to provide services to those calling 2-1-1.
5	Milestone: Day 300 or Event 2 plus 180 days86	Commission approval of all advice letters for 2-1-1 origination.
6	Milestone: Day 300 or Latest of events 4 and 5	The commencement of the rollout of 2-1-1 services (contingent upon Commission approvals) to be completed in 60 days.
7	Deadline: Day of Event 6 +360 Days	If no rollout of 2-1-1 services occurs by this date, then I&R providers will forfeit their certification to provide 2-1-1 service in the affected areas

This set of milestones and deadlines should provide the guidance that the affected parties require to assure a timely implementation of 2-1-1 dialing in California.