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Date of Issuance: May 6, 2011
PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
Consumer Programs Branch
May 5, 2011
R E S O L U T I O N
Resolution T-17254. INFO LINE of San Diego County, Inc. Request for certification as the 2-1-1 service provider for Imperial County. By Letter to Executive Director filed on January 13, 2011.
This resolution grants INFO LINE of San Diego County, Inc. hereinafter referred to as 2-1-1 San Diego, the authority to use the 2-1-1 abbreviated dialing code to provide information and referral (I&R) services to all of Imperial 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.
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.
2-1-1 San Diego filed a complete copy of its application letter1 requesting certification as the 2-1-1 service provider in Imperial County that was received by the Commission's Executive Director on January 13, 2011. On the same date, 2-1-1 San Diego sent to the service list for R.02-01-025 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.
2-1-1 San Diego 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 2-1-1 San Diego's application letter in the Commission Daily Calendar on February 10 through 17, 2011. In response to 2-1-1 San Diego application letter, the California Alliance of Information and Referral Services, Inc. (CAIRS) submitted a letter dated February 17, 2011 supporting the request of 2-1-1 San Diego to use the 2-1-1 dialing code in Imperial County. No other comments were submitted.
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.
2-1-1 San Diego 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. 2-1-1 San Diego is located at 5251 Viewridge Court, San Diego, Ca 92123. The contact person is John Ohanian, at (858) 300-1301 and email at firstname.lastname@example.org.
In 2009, John Ohanian, Chief Executive Officer of 2-1-1 San Diego met with Dr. Brian Brady of the Imperial Irrigation District to first discuss the needs of the County of Imperial. Dr. Brady then connected Mr. Ohanian to Ralph Cordova, Imperial County County Administrative Officer, who then began discussions regarding 2-1-1 San Diego's possible role in covering the County of Imperial. During these discussions a magnitude 7.2 earthquake hit at 3:40 p.m. on Sunday, April 4, causing roadway and building damages, power outages, water breaks and more. Residents flooded 9-1-1 with calls for non-emergency information like road closures, food distribution centers, and temporary shelter locations.
The initial conversations between 2-1-1 San Diego and Imperial County in 2009 evolved into collaborative effort and partnership between Sempra Utilities, the County of Imperial and the Imperial Irrigation District. This partnership proposed 2-1-1 San Diego to be the regional call center to provide residents of Imperial County with a comprehensive listing of all agencies and community resources in the Imperial County area.
Numerous agencies, such as the Red Cross of San Diego and Imperial Counties, the Girl Scouts of San Diego and Imperial Counties and Planned Parenthood of San Diego and Imperial Counties provide public services to residents in both Counties. With connections and partnerships to these agencies and the relationship built with the County of Imperial's governing body, 2-1-1 San Diego is a natural fit to be designated the 2-1-1 provider for the County of Imperial. In June 2010, Mr. Ohanian and Ms. Alia Del Rossi, Resource Specialist, attended the County of Imperial Board of Supervisors meeting at which the role of 2-1-1 San Diego in the County was discussed and approved.
2-1-1 San Diego 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.
2-1-1 San Diego provided a three year budget for the Imperial County service as part of their application. 2-1-1 San Diego budget and financial statements indicate a stable and solvent financial position. It appears that 2-1-1 San Diego 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 2-1-1 San Diego'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.
2-1-1 San Diego's staff currently provides I&R services in English, Spanish and Somali and contracts with Language Line multi-lingual translation service with access to more than 150 languages and dialects and has experience with I&R. TTY/TDY services are in place. All of these options will be available with the implementation of 2-1-1 in Imperial 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). 2-1-1 San Diego'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. 2-1-1 San Diego'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. 2-1-1 San Diego included in its application letters of endorsement from nineteen different organizations and agencies in a broad range of health and human service fields throughout Imperial County. Four additional endorsements were pending at the time the application was filed. These endorsements demonstrate broad community support.
In processing 2-1-1 San Diego's 2-1-1 application, the Communications Division considered the input of the Imperial 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 Imperial 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 December 17, 2010, the Imperial County Board of Supervisors, Louis a. Fuentes, Chairman sent a letter endorsing 2-1-1 San Diego's application to serve as the 2-1-1 provider of Imperial County residents and employees. The Commission values the input of the Imperial 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 Imperial 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 Imperial 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 2-1-1 San Diego 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.
1. INFO LINE of San Diego County, Inc., hereinafter referred to as 2-1-1 San Diego sent its application letter for certification as the 2-1-1 service provider for Imperial County to the Commission on January 13, 2011.
2. CAIRS submitted written comments in support of 2-1-1 San Diego's application for provision of 2-1-1 services in Imperial County on February 17, 2011. No other comments were submitted.
3. 2-1-1 San Diego'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. Louis A. Fuentes, Chairman of the Imperial County Board of Supervisor sent a letter to the Commission on December 17, 2010, endorsing 2-1-1 San Diego's application to serve as the 2-1-1 provider for Imperial County.
5. CD concludes that 2-1-1 San Diego'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. INFO LINE of San Diego County, Inc. is granted the authority to use the 2-1-1 abbreviated dialing code to provide information and referral (I&R) services to all of Imperial 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 INFO LINE of San Diego County, Inc. cannot implement 2-1-1 dialing within a year after the Commission's approval of INFO LINE of San Diego County, Inc.'s application for provision of 2-1-1 service in Imperial 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 INFO LINE of San Diego County, Inc. shall lapse so that another I&R provider may apply to offer service in a service territory containing Imperial County.
4. INFO LINE of San Diego County, Inc. 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 May 5, 2011 adopted this Resolution. The following Commissioners approved it:
/s/ Paul Clanon
MICHAEL R. PEEVEY
TIMOTHY ALAN SIMON
MICHEL PETER FLORIO
CATHERINE J.K. SANDOVAL
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.