13. Consumer Education Program
Consumer education is the cornerstone to empowering and protecting consumers in a competitive telecommunications market. Education coupled with clearly delineated rights, a competitive marketplace, and effective enforcement of regulations, laws, and guidelines arms consumers with the tools necessary to empower themselves when making decisions about telecommunications products and services. The Commission's focused consumer education campaign will make consumers more likely to choose telecommunications products and services that best meet their needs.
There is widespread agreement among parties that consumer education, spearheaded by this Commission, would benefit consumers and companies alike. Although parties differ as to whether new prescriptive rules are also necessary to protect consumers, both consumer groups and industry representatives endorse a consumer education program. This section reviews individual parties' responses to our educational efforts.
CSBRT/CSBA makes a number of suggestions regarding development of our consumer education program. On a general level, CSBRT/CSBA urges that the Commission to consider adopting objective criteria to measure the effectiveness of the program, and it suggests that we examine our past efforts for guidance on setting realistic expectations and developing cost-effective strategies.298 CSBRT/CSBA also asks the Commission to work with small business organizations to gain a better understanding of how to reach small business organizations.299 It states that these efforts would be aided by the establishment of a Small Business Ombudsman, who could promote the two-way flow of information between the Commission and the small business community.300
DOD/FEA states that general comments in this proceeding effectively make the case for consumer education: "[I]t is clear from many comments that consumer protection regulations, while extensive, are not understood by many users. Since many consumers have difficulty understanding the protections, they are unlikely to make use of them. Consumer education is the best response."301 DOD/FEA urges the Commission to target this education to a broad base of consumers, including commercial and governmental users of telecommunications services.302
Disability Rights Advocates stresses that the new consumer education initiative must provide for consumers with disabilities. Specifically it encourages us to ensure that all our consumer education materials are accessible to individual with disabilities, and it urges us to target individuals with disabilities in our education campaign.303 Disability Rights Advocates states that disability-related CBOs will be valuable partners in these efforts.304
Division of Ratepayer Advocates endorses consumer education, so much so that it states that we "should be more aggressive" in our educational efforts.305 It specifically calls for the Commission to provide information in print and on its website that will both aid consumers who are choosing among carriers and inform others who are considering legal or administrative action.306
Greenlining supports consumer education, and its Executive Director John C. Gamboa testified that "this phase in the proceeding offers the Commission the perfect opportunity to address the consumer education . . . issues that have been notably absent from the discussions surrounding the creation of the Telecommunications Bill of Rights."307 Greenlining's Executive Director maintained that the Commission has spent insufficient time in this proceeding addressing the special needs of minority language communities and the role consumer education programs could play in meeting those needs.308
LIF has "continually advocated for consumer education directed to those vulnerable language-minority, immigrant communities that are often the target of consumer abuse."309 Specifically LIF supports funding CBOs so that they can work with these populations "that only they can properly reach."310 It also recommends that the Commission contract with a third party administrator when conducting the consumer outreach.311
TURN, joined with other members of Consumer Groups, supports education generally - but not the specific campaign proposed in this decision. They claim that Commission staff do not have sufficient resources to accomplish our stated goals.312 The Consumer Groups, referencing earlier comments filed by TURN and Consumer Advocates, claim that an effective consumer education program must have seven elements to be effective.313
The Wireline Group is very supportive of our consumer education program. It states that "[t]hroughout this proceeding the Wireline Group has consistently argued that the Commission should focus on consumer education rather than adopting prescriptive rules. Confusion for consumers is caused by the plethora of laws; and, new rules only multiply consumer's challenges in understanding their rights."314 It calls for further solicitation and consideration of many different parties' suggestions, for which it encourages a schedule and expectation of concrete products.315 Within this proceeding, AT&T individually provides a number of constructive comments on various components of our education campaign.316 We will describe and respond to these specific suggestions below.
The Wireless Carriers also view consumer education as an effective means of empowering their consumers. They recognize that a consumer education campaign could be effective in educating consumers on choosing a service provider,317 or informing consumers about laws and regulations applicable to the wireless industry. 318 In order to ensure our education campaign is successful, the Wireless Carriers make two primary recommendations: 1) that consumer organizations, industry, representatives, and Commission staff work together in deciding "critical" issues of identification of the target audience, development of the message, and how the message is delivered; and 2) that a monitoring process be put into place and the results be made available to carriers and all stakeholder groups.319
Individual Wireless Carriers endorse, and make recommendations for, the education campaign too. Cingular Wireless provides many constructive comments on our education campaign, and we will describe and respond to its individual comments below.320 Verizon Wireless suggests that the Commission compile existing laws in one place so that customers can more easily know of their rights. Specifically it recommends that we post a summary of those laws in "plain English" on the Commission's website and provide appropriate hyperlinks to other references.321
Consumer education is central to providing California residents with the tools they need to make informed decisions on communications services. This Part discusses the multiple ways in which a consumer education campaign can benefit consumers, and explains how an education campaign may improve consumer welfare better than imposing new regulatory schemes.
Consumer education can inform consumers of the significant features of a service, technology, or a market that should affect their decision to purchase. While we do not believe that we should attempt to serve as a substitute for provision of specific terms by carriers, Cingular correctly notes that we can play a valuable role through providing materials that use a broad-based explanatory approach in describing telecommunications offerings.322 A valuable example of this type of educational effort is found at the FCC. The FCC currently offers a brochure on wireless phones that guides consumers with a set of questions concerning coverage, pricing issues, and handset features.323 This brochure may be found on the FCC's website.
Consumer education also can help consumers by informing them of the rights that they have under existing laws and regulations. Greenlining provided testimony in this proceeding that indicates that despite the wealth of rules and regulations that prohibit slamming, a complex set of cultural and linguistic factors combine to make certain consumers particularly vulnerable to "aggressive, deceptive and/or unscrupulous telecommunications service providers" whose marketing targets ethnic minorities.324 An effective education campaign, however, can assist these vulnerable consumers by informing them of their rights, so these consumers can assert their rights when dealing with carriers.
The benefits of education are particularly apparent in a dynamic marketplace - and thereby may produce more positive results than the adoption of more prescriptive rules. In a telecommunications market where technological change and new service offerings are occurring daily, education may offer a quicker and more robust way to protect consumers than the adoption of regulatory rules that constrain service offerings by imposing a one-size-fits-all model on a complex and fast-moving industry using many different business models.
An education program can be narrowly tailored to address specific problems encountered by identifiable groups of consumers. For example, to the extent that lack of English proficiency prevents certain consumers from making meaningful choices among providers or services or limits their ability to make use of existing consumer protections, narrowly targeted in-language consumer education materials may be far more effective in aiding those consumers than dozens of pages of printed contract terms.325 The problem of "information overload" could be particularly acute for such consumers.
Also the Commission has more freedom to experiment in a consumer education program and to learn from this experience than we would from adoption of extensive and costly rules. An education campaign can be quickly modified to respond to consumer feedback and marketplace developments.
Given parties' comments, we recognize that existing consumer protection laws and regulations, though extensive, are not readily understood by or available to the average consumer. To the extent that consumers are ignorant of existing legal protections or have difficulty in understanding them, they are not likely to make use of available protections. Consumer education is the best response to this situation.
In this decision, therefore, this Commission launches a new consumer education program that will be directed by Commission staff. We recognize that the carriers should be the first and most important source of information for consumers. This Commission, however, is in a unique position to provide consumers with additional information necessary to make informed choices as it can build on its existing programs and divisions that already interact with consumers.326 Also, as recognized by AT&T, consumers are more likely to view the Commission as a credible source of information.327
To be effective we will need to devote a significant amount of time and resources to this important education campaign. Our experience with the programs we administer for the benefit of low-income, disabled, and non-English-speaking consumers has proven to us that getting information to individuals who fall in these and similar categories can be time-consuming and expensive. The consumers most in need of education are also the hardest to reach: The consumers most likely to be targeted for exploitation by unscrupulous operators are often the least informed about how to protect themselves.328 We also acknowledge that our role as a consumer protection agency is not widely recognized by California consumers.329
We envision three prongs to our Commission-led consumer education program. The first prong is a broad-based information campaign that helps all consumers in the face of the complex and ever-changing array of telecommunications choices. The second prong consists of an education program designed to inform consumers of their rights. We will facilitate public access to our rules (including those compiled in the General Order). We also plan to advertise assistance provided by the CAB call center, and ensure that call center employees (and other Commission staff members) are aware of various laws and rules that telecommunications carriers must follow. The third prong combines the first two prongs and focuses more on orienting those customers who are non-English or low-English proficiency speaking, seniors, disabled, or low-income. We anticipate that we will work closely with CBOs through our efforts to educate these targeted communities.
These educational efforts will reach out to both business and residential consumers. We agree with DOD/FEA that all telecommunications users may benefit from the education,330 and in particular, we recognize that it is important for us to target California's small businesses. Our state's small business community has a significant economic impact on the state's economy both in terms of jobs and revenue base. Also many members of the small business community, like residential consumers, may be victims of marketing abuse and fraud. Both small business and residential consumers need to be aware of their rights when they sign service agreements, and also need to know how to file complaints with the Commission if their rights are not respected. We expect that many of the outreach and education materials developed for residential consumers can also be used for small businesses.
It is important that our consumer education materials provide understandable "plain English" answers to frequently asked questions. Consumer education material must be provided clearly, concisely and in laymen's terms. In order to guide development of the consumer education material, Appendix E sets forth consumer education program principles. Also Appendix F provides proposed consumer education topics, in an effort to assist Commission staff, carriers and consumer groups and organizations as they develop education material. These high-level principles along with the proposed education topics are intended to help create material that is informative, understandable, and helpful to telecommunications consumers of all walks of life.
In designing such materials, we will look to both carriers and consumer organizations for input about questions to be addressed, the form in which answers should be created, and the manner in which the materials should be distributed for maximum effect. We find that the FCC provides a good model for this Commission, and we will seek guidance from other state and federal regulators as well. We agree with multiple commenters that all interested parties should have the chance to have input into content development.331 In collecting this feedback, we support the recommendation of the Wireline Group, AT&T, and Cingular and direct CSID to hold workshops addressing the design, content, and dissemination of such consumer education materials.
Additionally we request that CSID explore how smaller working groups, as proposed by AT&T, may be able to complement our workshop efforts. AT&T recommends that details of the campaign "be developed in a collaborative way by a `working group' composed of carriers, consumer groups, [CBOs], and representatives from the Commission."332 These working groups would be an ongoing component to our education campaign efforts. As envisioned by AT&T, the working groups would conduct periodic conference calls to update materials and discuss any developing complaint trends, and the meetings of the groups could include presentations from key consumer advocates, such officials at the California Department of Consumer Affairs.333 AT&T further proposes that at least once a year all working group members come together in order "to evaluate the program, update the content, and suggest new strategies."334 Further suggestions for how working groups could be coordinated with workshops are provided by Cingular.335
Many entities have significant educational experience that may assist us in our design and subsequent implementation efforts. One such example is Communities for Telecom Rights ("CTR").336 CTR is a California non-profit network comprised of thirty-five nonprofit CBOs, and it provides education and guidance on telecommunications issues focusing on limited-English-proficient communities. CTR provides consumer education materials in seven languages.337 These consumer education materials include fact sheets on topics such as avoiding phone fraud, how to choose the best local and long telephone service, and warnings about misleading ads and telephone services. CTR's website, www.telecomrights.net, is a model approach to a comprehensive telecommunications education program. CTR is funded by the California Consumer Protection Foundation ("CCPF"), which is in part funded by the Verizon Grant Program. CTR also is building a statewide network capable of tracking abusive business practices.
Finally we concur with CSBRT/CSBA's recommendation that we hire an individual who will serve as an intermediary between the Commission and the small business community. 338 We suspect our sharing information with the community may inform the content, as well as other aspects, of our educational program. Given these benefits, we are requesting funds specifically designated for the hiring of a small business liaison.339
We expect that the educational materials will be disseminated through multiple avenues. The distribution effort will be led by the Commission staff, but may be aided by carriers, CBOs, and organized consumer groups. We describe forms of dissemination below.
One way we can inform consumers is through the Commission's website. We plan to work with carriers and CBOs to develop a portion of the Commission's website as a consumer education center. As a part of the website, as suggested by carriers, we will include a section that describes consumer protection laws and rules in layman's terms,340 and another section that allows consumers with problems or questions to directly communicate with Commission staff.341 Ultimately we plan for the website to be fully translated in all languages included in the project.342 The website, consistent with the third prong of our education campaign, will place particular emphasis on non-English and low-English proficiency speakers, people with disabilities, children, seniors, and small businesses.
Our website can be a powerful tool. Given the dominance and availability of the Internet as an information source in California, our website is a very cost-effective way to reach many citizens. The Internet makes it possible to cheaply disseminate and readily update information, and the Commission website can easily accommodate links and new web portals whereby a consumer can access information necessary to make informed choices when purchasing telecommunications services. Websites maintained by carriers,343 consumer organizations,344 and other public utility commissions in other states345 are good examples of how we can provide significant amounts of educational material regarding telephone service to consumers with Internet access.346 These websites also can help us ensure consumers' have easy access to Commission-provided information. We will encourage carriers and CBOs, as recommended by AT&T, to add a link to their web sites that connect to the Commission's page.347 We also will advertise the website in our outreach materials.348
We realize, however, that information on our website is not readily available to consumers who do not have Internet access, whose English proficiency is too limited to make effective use of the Internet, or have disabilities that make Internet access difficult or impossible. These limitations may affect both residential and small business consumers.349 For these reasons an effective consumer education program cannot rely entirely on the Internet as a means of distributing important information.
Thus we also will explore production of public service announcements that help provide consumers with information needed to purchase telecommunications services. We anticipate that a mass media campaign could reach more consumers than our website alone. If we decide to launch a mass media campaign, we anticipate that we will initiate a Request for Proposal ("RFP") process, where we will contract with communications consultants who will help us design and launch a media campaign. An important aspect of creating a media campaign, as noted by the Wireless Carriers, will be finding a message that resonates with our target audience.350 This message then could be conveyed through, among other avenues, radio advertisements or newspaper ads.
For example, AT&T proposes we develop a series of newspaper ads that focus on different telecommunications rights.351 These ads may explain "what consumers should expect when doing business with telecommunications companies and whom to contact if there is a problem."352 We could publish these ads in a wide variety of newspapers, including ethnic press.353
We may want to consider placing information in local phone books too. Our Universal Lifeline Telephone Service ("ULTS") outreach has shown us that the Asian Yellow Pages, in particular, are an effective means of reaching Asian populations.
Also carriers, community based organizations, and organized consumer groups, among others, may assist in distribution of educational materials. As recommended by AT&T, we may create a comprehensive brochure in multiple languages that explains key telecommunications issues, and this brochure could be supplies in bulk to community organizations.354
More broadly we intend to develop community-based programs with CBOs in order to get the information into the hands of consumers who cannot easily get it from the website. We will identify specific geographic areas where there are large, concentrated populations of our targeted audiences, and we will create appropriate outreach and education programs for identified communities. Part of these efforts may include staff initiation of a RFP process, where we solicit organizations to carry out components of the education program.
Finally we direct CSID reach out to CBOs that provide services to disabled consumers when addressing accessibility of our website and other educational materials. We agree with Disability Rights Advocates that the experience and knowledge of these CBOs will allow them to play a valuable role in helping us determine how to design online information so that it is accessible to the widest possible audience.355
Through these distribution efforts the Commission must take a lead role and extend its outreach through communication to business and community leaders as well as federal, state, and local officials. In particular our outreach efforts should include local government, the Chamber of Commerce, the Department of Social Services, and other governmental agencies involved with consumer affairs, senior centers, schools, and libraries. Currently we offer a Local Government E-netter; we also may offer a similar small business e-newsletter, which could provide useful tips regarding telecommunications services and protections, as well as update small businesses on policy issues before the CPUC. Increased outreach will assist in preventing and identifying consumer problems before they occur.
The education program will be regularly monitored and evaluated in order to develop reliable data on which we can base changes to the educational program, as well as any necessary future rulemaking or enforcement action. Parties agree that effective monitoring is essential for ensuring the education program is cost effective, achieving our intended results, and responsive to changes in the telecommunications marketplace.356
This decision outlines some basic parameters of a monitoring and evaluation program, but it does not define specific program components. We direct Commission staff to develop a collaborative forum to contemplate various options and create a program based on its review of different monitoring and evaluation features.
Monitoring and evaluation efforts typically consist of five fundamental components: design, data collection, analysis, reporting, and evaluation critique. The scope of these efforts should include evaluation of all entities and activities contributing to the consumer education program. Thus the scope should include not only include consultants, contractors, and Commission staff, but also CBOs and participating carriers as well.
Design
The fundamental conceptual task in designing a monitoring and evaluation program is to define its purpose. Here the underlying purpose of the education program is based in economic theory: Competitive markets function optimally when consumers' choices are guided by perfect information; or stated more realistically, the more informed consumers' choices are, the better competitive markets function. Not only must consumers understand the differences between the products and services offered, they must understand the options they have in choosing, and switching to, different products and services.
Closely based on these concepts, a consumer education program theory, including a logical model, should be created and described. The underlying program theory is similar to the purpose described above: Consumer education will facilitate competitive market functioning and reduce the need for market regulation. A logical model specifies the sequential steps or causal links implied in the theory. For example, information will be presented to consumers, they will understand this information, they will then exercise choices and options better suited to their needs, these informed consumer choices will in turn influence the market to adapt efficiently to consumer needs, and this adaptation will satisfy both consumers and the market better than direct regulation could. Given that the world of telephone service has gone from a monopoly service to a competitive landscape, it is the Commission's duty to explain to consumers their new choices and rights, and to help them when there are problems.
Data Collection
Perhaps the most critical monitoring and evaluation task is to identify the observable, measurable outcomes that should follow from the education purpose and implementation. Several categories of observations are possible.
First, we may consider both outputs and outcomes. Outputs are the immediate results of the education process or activities; outcome observations document how well the overall education program affected consumer behavior and satisfaction and market functioning. Since outcome observations are to difficult make and assess, observations that examine the education process or outputs are likely to be complementary and uniquely informative. For example, process observations could include output measures such as exposure to the educational materials and comprehension of the materials. Process observations are also critical to the program in that they can indicate areas for improvements. Program theory and logical modeling should be helpful in linking the outputs to the outcomes.
Second, both objective and subjective measures are likely to be helpful. Objective observations are those where an observer gains evaluative information without asking consumers. For example, the change in number of complaints would be a relatively objective observation. In contrast, subjective observations seek individuals' opinions. For example, a survey could solicit consumers' opinions about education program components, or if/how it has improved their consumer experience.
Third, the evaluation should consider employing both cross-sectional and longitudinal analyses. A cross-sectional evaluation examines a program's effects for one time period and focuses on differences between categories of individuals, services, or products. A longitudinal evaluation tracks program effects over time to identify changes in effectiveness or need for adaptations. Since a database is a significant precondition to implementation of these forms of measurement, we direct the Commission staff, when directing the design of our new database, to assess the feasibility of adding evaluation metrics.
Since our education program will likely comprise multiple methods and materials, the evaluation effort should be multifaceted to adequately assess the different approaches. Multiple measures will enhance reliability and validity.
Additionally data characteristics should be assessed and statistical properties considered ahead of time so that helpful and appropriate analyses can be performed. Whenever reasonably feasible, the data to be gathered and the methodology to be used should be considered and constructed so that statistical analyses will produce estimates of the levels of confidence we can have in the evaluations' results. Consistent with our own statistical analyses precedents, statistical power and meaningfulness should be considered in addition to statistical significance.
The data collection methodology and the data itself should be designed and constructed to be as unambiguously interpretable as possible. For example, simple increases in the number of complaints could reflect multiple indistinguishable causes, such as increases in customer problems, increases in service sales, new types of service, increased awareness of rights, and/or increased awareness of the means to file complaints. While additional information, such as normalizing data or detailed cross-sectional data, can help identify causes in these cases, the conclusions may only be as good as this additional information.
Analysis
The analysis should be focused both on program outputs and outcomes, with the primary purpose of finding areas for improvement. To the degree possible, analyses should strive to assess the overall success of the program. Descriptive statistics should show differences between different groups, services, products, companies, geography, and other distinguishing characteristics, as well as trends. Statistical analyses can help decision-makers determine differences that are not better explained by sample randomness or temporal fluctuations. More sophisticated modeling statistics may help in elucidating causal models. Extra care must be taken to construct the analyses so that quality inferences can be made, and at the same time, limitations or alternative explanations should be sought and examined.
Report
The essential product in any monitoring and evaluation effort is the feedback. This feedback should be focused primarily on how to improve the consumer education program, but also on assessing the program's effectiveness.357
We direct staff to provide the Commissioners an annual report covering each calendar year. The feedback should be presented to the individuals implementing and updating the education program, and otherwise to any Commission decision makers who may take action based on the results. The report should be finalized no later than June 1st the following year.
Additionally Commission staff should create a more frequent periodic report for its own monitoring uses. For example, monthly reports could uncover acute problems that could be addressed in a timelier manner than possible with only an annual report.
Critique
A metaevaluation,358 or an evaluation of the evaluation, should reflect on what can be improved in the monitoring and evaluation effort. This critique may be separate from the report, included in the report, or summarized in the report. The purpose of the critique is not to critique the education program, but to critique the monitoring and evaluation effort and improve it through periodic redesign.
In conclusion, a monitoring and evaluation program that incorporates the five factors listed above will help us improve how we run our education program and, more generally, how we make decisions. The problems that we have faced in using CAB complaint data demonstrate the importance of developing a means of systematically measuring the efficacy of Commission programs. An effective monitoring and evaluation program will help us identify if certain materials and approaches are more useful to consumers than others, so that we can emphasize and extend those materials and approaches. Similarly feedback through this program will help ensure that our future decisions are based on more reliable data.
We will take steps both internally and as part of the Commission's budget proposal to the Legislature to ensure that CSID has the resources and personnel required to create and monitor the education program. The Commission budget for our ongoing education program detailed above is $7.05 million for the first year, $1.0 million of which has been earmarked to fund CBOs.359 The first year expenses are high, because they include both design and implementation of the program. After the first year the annual program budget is $4.9 million, $1.9 million of which is specifically designated for funding CBOs. This budget proposal, which has been sent to the Legislature for approval, is modest given the broad scope of the campaign, and it is consistent with the size of other statewide consumer education programs.360
While we are requesting these funds, we direct CSID develop and implement an interim consumer education campaign using existing Commission staff and resources. The initial education program shall be implemented within 120 days of issuance of this decision. Relying upon existing personnel and materials, staff will use its website to host an interim consumer education center that will include consumer education materials, summaries of and references to consumer protection rules and laws, and links to other useful resources. Initially Commission staff plans to focus outreach and education on the seven most common languages spoken in California: English, Spanish, Chinese, Vietnamese, Korean, Tagalog, and Hmong.361 Also staff will launch a preliminary media campaign that that may include public services announcements and feature stories in print media.
In order to support current and future efforts, Commission staff will schedule workshops with carriers and CBOs to discuss resources available to support the Commission's education efforts. These early workshops will serve as brainstorming sessions for interested parties to discuss how best to direct our educational efforts. Collaboration among various entities will help us determine how to design a needs assessment, which will evaluate which population groups we need to target and the specific information that would be most useful to individual groups.362
It is our intent that the outreach and education activities that are implemented during the initial stage of the education program will stay in place until funded programs are developed and become operational. There will be no break in the education campaign during the transition from the initial, unfunded program and the ongoing, funded program.
298 CSBRT/CSBA Opening Comments, p. 11.
299 Id. at 10.
300 Id. at 11.
301 DOD/FEA Opening Comments, p. 13.
302 Id. at 14.
303 Disability Rights Advocates Opening Comments, p. 14.
304 See id. at pp. 14-17 (describing various disability-focused organizations that may be able to help us in designing and implementing our education campaign).
305 DRA Opening Comments, p. 2.
306 Id. at 2.
307 Gamboa Testimony, p. 6 (on behalf of Greenlining).
308 See id. (describing how business can exploit immigrants).
309 LIF Opening Comments, p. 3.
310 Id. at.5.
311 Id.
312 Consumer Groups Opening Comments, p. 23.
313 Id. (citing Comments of TURN and Consumer Action on the Assigned Commissioner's Ruling Regarding a Telecommunications Consumer Education Plan (Oct. 9, 2001)). The seven elements are as follows: "Ensure educational materials are designed to educate and not sell a particular philosophy or public relations messages; Have clearly defined project goals; Ensure that the funding matches the goals and expectations of the project; Coordinate local outreach efforts with state-wide message; Emphasis on multi-lingual outreach with culturally appropriate adjustments when needed; Use all types of mass-media for outreach efforts; Ensure consumers also have access to legal remedies, effective complaint handling and strong enforcement efforts." Id.
314 Wireline Group Opening Brief, p. 18.
315 Wireline Group Reply Comments, p. 5.
316 See generally Opening Comments of Pacific Bell Telephone Company D/B/A AT&T California (U 1001 C) on Proposed Decision of Commissioners Peevey and Kennedy (Jan. 17, 2006) ("AT&T Opening Comments") (focusing almost entirely on our education campaign). These comments receive support from Verizon. Reply Comments of Verizon California Inc. to Opening Comments of Pacific Bell Telephone Company (DBA AT&T California) on Proposed Decision of Commission, p. 1 (Jan. 23, 2006).
317 Wireless Carriers Opening Brief, p. 48.
318 Katz Reply Testimony, p. 40.
319 Wireless Carriers Opening Comments, p. 10.
320 See generally Reply Comments of Cingular Wireless on the Proposed Decision of President Peevey and Commissioner Kennedy (Feb. 3, 2000) (devoting its comments to discussion of the education campaign).
321 Verizon Wireless Opening Brief, p. 36.
322 Cingular Reply Comments, p. 3.
323 Comments of Cingular Wireless in Response to the March 10, 2005 Assigned Commissioner's Ruling (Mar. 25, 2005), p. 3.
324 Testimony of John C. Gamboa (Aug. 5, 2005) ("Gamboa Testimony"), p. 3 (on behalf of the Greenlining Institute).
325 Katz Testimony, p. 14.
326 Cingular Reply Comments, p. 2. The Commission already has significant experience in conducting similar education campaigns (such as one for ULTS), and our education efforts are a useful complement to our efforts to assist consumers in protecting their rights. AT&T Opening Comments, p. 2.
327 AT&T Opening Comments, p. 2.
328 See, e.g., LIF Opening Brief, pp. 2-4; DRA Opening Brief, pp. 8-10.
329 As pointed out in Katz's reply testimony, "the authors of a study sponsored by the Commission concluded that `Mostly, people seem to be uninformed about the CPUC and what it could and could not do to help consumers resolve problems' (Diane Schmidt and James E. Fletcher, `A Final Report on Telephone Survey of Telecommunications Customers in California,' report prepared for the California Public Utilities Commission, Telecommunications Division, May 15, 2001 at page 22.)." Katz Reply Testimony, p. 41, n.117. A nationwide survey undertaken for the American Association of Retired Persons reached a similar conclusion. Id.
330 DOD/FEA Opening Comments, p. 14.
331 AT&T Opening Comments, p. 2; Cingular Reply Comments, p. 2; Wireless Carriers Opening Brief, p. 10.
332 AT&T Opening Comments, p. 2.
333 Id. at 3.
334 Id.
335 Cingular Reply Comments, p. 4.
336 CTR is coordinated and supported by three lead agencies: Asian Pacific American Legal Center ("APALC"), and LIFUCAN. The project is funded by grants primarily from the Telecommunications Consumer Protection Fund ("TCPF"), which is administered by the California Consumer Protection Foundation ("CCPF").
337 These languages are English, Chinese, Spanish, Khmer, Korean, Laotian, Tagalog, and Vietnamese.
338 CSBRT/CSBA Opening Comments, p. 11.
339 This proposed position is included in our BCP, which is currently under review by the Administration and the Legislature.
340 See Verizon Wireless Opening Comments, p. 36 (recommending this component).
341 See AT&T Opening Comments, p. 3 (supporting this function).
342 See AT&T Opening Comments, p. 3 (recommending that website material "be available in language").
343 See, for example, the Cingular "customer forum" on its website at http://forums.cingular.com/.
344 See, for example, the information available at the websites of the National Consumers League at http://www.nclnet.org/phonebill/billingrights.html#top and the Ohio Consumers Council at http://www.pickocc.org/publications/phonerights.pdf.
345 See, for example, the telephone consumer information posted by the Michigan Public Service Commission at http://www.michigan.gov/mpsc/0,1607,7-159-16368_16408_18085---,00.html and the similar information posted by the Ohio Public Utilities Commission at http://www.puco.ohio.gov/puco/consumer/index.cfm.
346 For example, extensive information on a wide range of telephone-related consumer issues is available in English, Chinese and Spanish from Consumer Action at http://www.consumer-action.org/.
347 AT&T Opening Comments, p. 3.
348 AT&T offers a number of useful suggestions for how we may want to conduct outreach based upon the website. Id. at 3.
349 See CSBRT/CSBA Opening Comments, pp. 10-11 ("A survey of businesses by the California Small Business Education Foundation of small businesses in the Inland Empire found that only 50 percent of small business owners used a computer in their business and, of those businesses with computers, only 25 percent routinely used them to access the Internet.").
350 Wireless Carriers Opening Comments, p. 10.
351 AT&T Opening Comments, p. 4.
352 Id.
353 Id.
354 AT&T Opening Comments, p. 4. AT&T states that topics for this brochure may include the following: how to shop for services; what the various services (call waiting, caller ID) do; ordering service; payment methods; how to read a bill; and how to resolve billing questions. Id.
355 Disability Rights Advocates Opening Comments, pp. 14-17 (listing a number of organizations that it says can assist us in our education efforts). See also Cingular Reply Comments, p. 3 (agreeing that our consumer education efforts should be accessible to individuals with disabilities).
356 Reply Comments Of Cingular Wireless (U-3060-C) on the Proposed Decision of President Peevey
and Commissioner Kennedy, pp. 4-5 (Jan. 23, 2006) ("Cingular Reply Comments"); CSBRT/CSBA Opening Comments, pp. 11-12; Wireless Carriers Opening Comments, p. 10.
357 A useful academic checklist for an evaluation report is available in M. Scriven, The Key Evaluation Checklist. (2005), http://www.wmich.edu/evalctr/checklists/kec_october05.pdf. Further direction is available in E.J. Davidson, Evaluation Methodology Basics: The Nuts and Bolts of Sound Evaluation (2005). A checklist should assist not only in drafting a report, but also in guiding the creation, implementation, and periodic review of our monitoring and evaluation efforts, as well as the education program itself. While the checklist may present the ideal evaluation that is not always attainable in actual application, it presents a helpful guide and presents a standard against which we can assess our efforts.
358 Scriven at 8.
359 This funding request included in our BCP, which currently is under review by the Administration and Legislature.
360 California has sponsored a number of educational efforts directed toward the state's consumers. In 1999 the Legislature ordered that $13 million be used for a five-year education and outreach program on electric service competition. In 1996, approximately $5.million per year was set aside for outreach and education on ULTS, a telecommunications program focused on low-income individuals. Energy efficiency education programs recently received $36 million in funding. All of these programs included funding for CBOs that participated in the outreach and education.
361 In the future we may identify additional languages spoken by other hard-to-reach communities and whether we also should use those languages in outreach and education materials.
362 See Cingular Reply Comments, p. 4 (recommending the needs assessment).
