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Date of Issuance: 12/18/2009

PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Communications Division

RESOLUTION T-17217

Consumer Programs Branch

December 17, 2009

R E S O L U T I O N

_________________________________________________________________

Summary

This resolution grants United Way of Tulare County hereinafter referred to as UWTC, the authority to use the 2-1-1 abbreviated dialing code to provide information and referral (I&R) services to all of Tulare 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.

UWTC filed a complete copy of its application letter1 requesting certification as the 2-1-1 service provider in Tulare County, as well as a copy with information UWTC considered confidential redacted, that was received by the Commission's Executive Director on October 5, 2009. On the same date, UWTC 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

UWTC 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 UWTC's application letter in the Commission Daily Calendar on October 15 through October 21, 2009. In response to UWTC application letter, the California Alliance of Information and Referral Services, Inc. (CAIRS) submitted a letter dated November 13, 2009 supporting the request of UWTC to use the 2-1-1 dialing code in Tulare 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.

UWTC 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. UWTC is located at 1601 East Prosperity Av, Tulare, Ca 93274. The contact person is Emy Blankenship, at (559) 685-1766 and email at emy@unitedwaytc.org.

Tulare County's path towards a centralized information and referral service began in 1990 and 1999, when a devastating flood in Earlimart and debilitating freezes highlighted the necessity for a centralized clearing house for information and referral during disasters. In response to those needs, as well as to the continuing need for a central source of up-to-date information, United Way of Tulare County (UWTC) expanded its existing information and referral system by establishing FIRST CALL (1-800-283-9323) in 2001.

FIRST CALL has been providing Information and Referral to Tulare County Residents twenty-four hours a day, seven days a week since it's inception in 2001. FIRST CALL's database houses over 700 health and human service programs. Service provider information is updated on an ongoing basis to provide callers with up-to-date accurate information.

The current service delivery model through FIRST CALL involves collecting and evaluating inquirer data, ensuring broad access to services, and following up with callers to ensure that services were received.

Based on its experience with FIRST CALL it was logical for UWTC to explore transitioning into a 2-1-1 system. With the support of UWTC's Board of Directors, First 5 Tulare County and Tulare County Health and Human Services Agency, it was decided that UWTC would begin the process of establishing 2-1-1 Tulare County.

In January 2009, UWTC established a 2-1-1 advisory committee composed of local non-profits, the private business sector, county government agencies, and local city governments. Planning milestones were developed and used as the framework to begin the process of establishing a 2-1-1 system in Tulare County.

In March 2009, the Tulare County Board of Supervisors affirmed UWTC as the lead organization for 2-1-1 in Tulare County. UWTC has worked on establishing all standards set by the Alliance of Information and Referral Systems (AIRS) and will implement 2-1-1 Tulare County once approved by the California Public Utilities Commission. Calls will be taken twenty-four hours a day, seven days a week, three hundred sixty-five days a year by Interface Children Family Services and will use Refer database by RTM Designs.

UWTC will train Interface on localities in Tulare County and call handling. The database, funding, and contract with Interface Children Family Service will be maintained by United Way of Tulare County.

UWTC will be managing the I&R contract for Tulare county with Interface Children Family Services (ICFS). UWTC currently has three staff members engaged in planning and implementation of Tulare County 2-1-1 program. ICFS will be trained on the localities in Tulare County. The I&R database, utilized by 2-1-1 in the provision of I&R, will be maintained by UWTC.

ICFS has the internal protocols to ensure calls are handled consistent with guidelines developed by the Alliance of Information and Referral Systems including call handling, database development and maintenance and disaster response and preparedness.

UWTC provided a three year budget as part of their application. UWTC's budget and financial statements indicate a stable and solvent financial position. It appears that UWTC 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 UWTC'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.

ICFS staff currently provides I&R services in English and Spanish along with access to Language Line multi-lingual translation service with access to more than 150 languages. TTY/TDY service are in place. All of these options will be available with the implementation of 2-1-1 in Tulare 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 the Alliance of Information and Referral Services (AIRS). ICFS'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. UWTC'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. UWTC included in its application letters of endorsement from fifteen different organizations and agencies in a broad range of health and human service fields throughout Tulare County. These endorsements demonstrate broad community support.

In processing UWTC's 2-1-1 application, the Communications Division considered the input of the Tulare 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 Tulare 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 September 29, 2009, the Tulare County Board of Supervisors, Phillip A. Cox, Chair sent a letter endorsing UWTC's application to serve as the 2-1-1 provider of Tulare County residents and employees. The Commission values the input of the Tulare 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 Tulare 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 Tulare 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 UWTC 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 Tulare County, hereinafter referred to as UWTC sent its application letter for certification as the 2-1-1 service provider for Tulare County to the Commission on October 5, 2009.

2. CAIRS submitted written comments in support of UWTC's application for provision of 2-1-1 services in Tulare County on November 13, 2009. No other comments were submitted.

3. UWTC'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. Phillip A. Cox, the Chairman of the Tulare County Board of Supervisors sent a letter to the Commission on September 29, 2009, endorsing UWTC's application to serve as the 2-1-1 provider for Tulare County.

5. CD concludes that UWTC'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. United Way of Tulare County is granted the authority to use the 2-1-1 abbreviated dialing code to provide information and referral (I&R) services to all of Tulare 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 United Way of Tulare County cannot implement 2-1-1 dialing within a year after the Commission's approval of United Way of Tulare County's application for provision of 2-1-1 service in Tulare 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 United Way of Tulare County shall lapse so that another I&R provider may apply to offer service in a service territory containing Tulare County.

4. United Way of Tulare County 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 December 17, 2009 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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