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Date of Issuance: 2/5/2010

PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Communications Division

RESOLUTION T-17220

Consumer Programs Branch

February 4, 2010

R E S O L U T I O N

_________________________________________________________________

Summary

This resolution grants Shasta County Health and Human Services Agency hereinafter referred to as Shasta, the authority to use the 2-1-1 abbreviated dialing code to provide information and referral (I&R) services to all of Shasta 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.

Shasta filed a complete copy of its application letter1 requesting certification as the 2-1-1 service provider in Shasta County, as well as a copy with information Shasta considered confidential redacted, that was received by the Commission's Executive Director on November 23, 2009. On the same date, Shasta 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

Shasta 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 Shasta's application letter in the Commission Daily Calendar on December 14 through December 18, 2009. In response to Shasta application letter, the California Alliance of Information and Referral Services, Inc. (CAIRS) submitted a letter dated January 6, 2010 supporting the request of Shasta to use the 2-1-1 dialing code in Shasta 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.

Shasta is a division of the Shasta County, a political subdivision of the State of California. Shasta County was established as a general law county on February 18, 1850. Shasta County Health and Human Service Agency is located at 2650 Breslauer Way, Redding, Ca 96001. The contact person is Susan Morris Wilson, at (530) 243 7760 and email at swilson@shastacoe.org.

Shasta's effort to implement 2-1-1 in Shasta County began three years ago when information about the role of 2-1-1 in California was presented to local residents. Development of 2-1-1 in the county was identified as a goal in the strategic plan of the newly-formed Shasta County Health and Human Services Agency (HHSA). With the support of HHSA Director, Marta McKenzie, a collaborative that included at various times, Help Inc., First 5 Shasta, United Way of Northern CA, Office of Emergency Services/Shasta County Sheriff's Office, the Shasta Area transportation providers (including both public and private transportation providers), the Health Improvement Partnership, People of Progress, Shasta Senior Nutrition Program, Golden Umbrella, Northern Valley Catholic Social Services, Shasta Public Libraries, the Shasta Consortium of Community Health Clinics, the Mental Health Assessment and Redesign Collaborative, the Older Adult Policy Council, and Shasta County Social Services/Public Health/Mental Health and securing the services of the consultant that led to the creation of the Shasta 2-1-1 application.

The collaborative initial efforts focused on Help Inc, a local non-profit providing specialized I&R services through a contract with Shasta County Mental Health. Help Inc. had historically provided a variety of I&R services focusing particularly on suicide prevention and crisis intervention. They were a member of and active in CAIRS. The organization had the hardware and technology to provide the 2-1-1 services, had purchased a license for appropriate software and was in the process of training staff in the Alliance of Information and Referral Services (AIRS) standards as Call Specialists and Resource specialists. In 2009, Help Inc. was unable to raise sufficient funds to continue and was forced to close.

With the foreclosure of Help Inc as a possible I&R provider, other options were examined. After evaluating all potential information and referral providers, the collaborative determined that Shasta County was the only organization capable of initiating and providing 2-1-1 services. An Intra agency steering team consisting of Marta McKenzie, Michael Conti, Information and Technology; Roxanne Burke, Community Outreach; Kristen Logan, Public Health and Anthony Bertain, Office of Emergency Services, has been working together as a steering committee.

Shasta County is currently being considered by CalTrans as a possible site for a pilot mobility management grant. The mobility management program integrates human services with the transit required to access these services. The presence of 2-1-1 service in Shasta County is an essential component of this pilot program.

The collaborative determined that contracting with 2-1-1 Sacramento would be the most appropriate call center solution for Shasta County. Local efforts have since been focused on creating and maintaining the Shasta County call center database. Shasta purchased a license for ReferNET and for the AIRS/Info Line of LA taxonomy. A team of three individuals is in the process of creating the referral database. These three have been trained on ReferNET.

Shasta provided a three year budget as part of their application. Shasta's budget and financial statements indicate a stable and solvent financial position. It appears that Shasta 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 Shasta's application indicates that it does not and will not receive fees from referred organizations for referrals and no fees or charges will be levied to providers listed in its database.

2-1-1 Sacramento 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 services are in place. All of these options will be available with the implementation of 2-1-1 in Shasta 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 AIRS. 2-1-1 Sacramento'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. Shasta'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. Shasta included in its application letters of endorsement from fifteen different organizations and agencies in a broad range of health and human service fields throughout Shasta County. These endorsements demonstrate broad community support.

In processing Shasta's 2-1-1 application, the Communications Division considered the input of the Shasta 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 Shasta County. Shasta County is the actual applicant in this case. 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 November 4, 2009, the Shasta County Board of Supervisors, Glenn Hawes, Chairman sent a letter endorsing Shasta's application to serve as the 2-1-1 provider of Shasta County residents and employees. The Commission values the input of the Shasta 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 Shasta 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 Shasta 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 Shasta 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. Shasta County Health and Human Services Agency, hereinafter referred to as Shasta sent its application letter for certification as the 2-1-1 service provider for Shasta County to the Commission on November 23, 2009.

2. CAIRS submitted written comments in support of Shasta's application for provision of 2-1-1 services in Shasta County on January 6, 2010. No other comments were submitted.

3. Shasta'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. Glenn Hawes, the Chairman of the Shasta County Board of Supervisor sent a letter to the Commission on November 4, 2009, endorsing Shasta's application to serve as the 2-1-1 provider for Shasta County.

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

4. Shasta County Health and Human Services Agency 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

February 4, 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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