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Mailed Date: January 30, 2007
PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
Market Structure Branch
January 25, 2007
R E S O L U T I O N
Resolution T-17070. Community Action Partnership of Kern. Request for certification as the 2-1-1 service provider for Kern County.
By Letter to Executive Director filed on November 6, 2006.
This resolution grants Community Action Partnership of Kern, hereinafter referred to as the Partnership , the authority to use the 2-1-1 abbreviated dialing code to provide information and referral (I&R) services to all of Kern 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.
By Letter to the Commission's Executive Director received on November 6, 2006, The Community Action Partnership of Kern (the Partnership) filed a complete copy of its application letter1 requesting certification as the 2-1-1 service provider in Kern County, as well as a copy with information the Partnership considered confidential redacted. On the same date, the Partnership sent to SBC Communications now AT&T and Verizon Communications as well as 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-A, 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.
The Partnership states that it mailed a copy of its application letter to SBC Communications now AT&T and Verizon Communications as well as to the service list for R.02-01-025, which includes the appropriate incumbent local exchange carriers. The Telecommunications Division published notice of the Partnership's application letter in the Commission Daily Calendar on November 8, 2006 through November 20, 2006. In response to the Partnership's application letter, the California Alliance of Information and Referral Services, Inc. (CAIRS) submitted written comments supporting the request of the Partnership to use the 2-1-1 dialing code in Kern 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, its structure, its background, and experience.
The Partnership is a non profit corporation in Kern County, and is federally chartered to fight poverty. For the past ten years the Partnership's program known as Helpline has been the formally designated comprehensive information and referral (I&R) provider for Kern County. The documents included to support this categorization are its articles of incorporation, including By-laws, and letters from the Internal Revenue Service. Its location is 300 19th street, Bakersfield, CA 93301. The contact person is Fred A. Drew, Executive Director, at (661) 336-5236 ext. 138 or via e-mail at email@example.com .
The Partnership's application states that it has been providing comprehensive information and referral services to Kern County through a program of the organization known as Helpline for 12 years. The Partnership provides its major services through four key divisions: Child Education and Development services, Health and Nutrition Services, Family and Community Services, and Administrative and Support. In addition to pursuing its four main missions, the Helpline also has experience in providing post-disaster response. Between February 1997 and June 2004, Helpline has been able to assist more than 560 disaster victims. The Partnership has internal protocols to ensure calls are handled consistent with guidelines developed by the Alliance of Information and Referral Systems ("AIRS").
The Partnership application indicates that staff and key managers have many years of experience either directly in comprehensive I&R service, or in similar human services planning and information management.
The Partnership has provided a 3-year budget. The Partnership's budget and financial statements indicate a stable and solvent financial position. It appears that the Partnership 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 the Partnership's application indicates that it does not and will not receive fees from referred organizations nor charge providers to be listed in its database. Furthermore, the Partnership's information and referrals services have been provided free of charge to callers and will remain that way upon implementation of 2-1-1. The Partnership states that upon implementing 2-1-1 dialing, it will assist callers 24 hours a day, seven days a week to all callers regardless of language and disability by live and trained I&R Specialists. After hours, weekends and holidays, service will be contracted to Interface. Both agencies will meet AIRS service delivery standards. The Partnership's Helpline services are provided both in English and Spanish. Fifty percent of the I&R Specialists are bilingual with interpreter support in more than 140 languages is available through a professional tele-interpreting language line service. Assistance is also available through out TTY/TDD for persons with disabilities.
In the third section of the prescribed application, the applicant must demonstrate its understanding of and agreement to adhere to the standards for delivery of I&R services established by the Alliance of Information and Referral Services (AIRS). The Partnership has internal protocols to ensure all calls are handled consistent with guidelines developed by the Alliance of Information and Referral Systems ("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. The Partnership's application includes 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 be more than adequate 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. The Partnership included in its application letters of endorsement from 18 different organizations and agencies in a broad range of health and human service fields throughout Kern County.
In processing this 2-1-1 application, Telecommunications Division considered the input of the Kern 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 Kern 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. Supervisor Barbara Patrick, District 3 on behalf of Kern County Board of Supervisors sent a letter on September 21, 2006 endorsing the Partnership's application to serve as the 2-1-1 provider of Kern County residents and employees. The Commission values the input of the Kern 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 Kern 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 Kern 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 Telecommunications Division concludes that the application letter filed by the Partnership of Kern 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. The Community Action Partnership of Kern, hereinafter referred to as the Partnership sent its application letter for certification as the 2-1-1 service provider for Kern County to the Commission on November 6, 2006.
2. CAIRS submitted written comments in support of the Partnership application. No other comments were submitted.
3. The Partnership'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. The Chairman of the Kern County Board of Supervisor sent a letter to the Commission on September 21, 2006, endorsing Partnership to serve as the 2-1-1 provider for Kern County.
5. TD concludes that the Partnership'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. The Partnership is granted the authority to use the 2-1-1 abbreviated dialing code to provide information and referral (I&R) services to all of Kern 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 the Partnership cannot implement 2-1-1 dialing within a year after the Commission's approval of the Partnership 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 the Partnership shall lapse so that another I&R provider may apply to offer service in a service territory containing Kern County.
4. The Partnership shall notify the Director of the Telecommunications Division in writing of the date 2-1-1 service is first rendered to the public, within five days after service begins.
This Resolution is effective today.
I hereby certify that the Public Utilities Commission at its regular meeting on January 25, 2007 adopted this Resolution. The following Commissioners approved it:
/s/ STEVE LARSON
MICHAEL R. PEEVEY
DIAN M. GRUENEICH
JOHN A. BOHN
RACHELLE B. CHONG
1 The terms "application 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.