DRAFT
PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
Telecommunications Division |
RESOLUTION T-16546 |
Public Programs Branch |
August 23, 2001 |
R E S O L U T I O N
RESOLUTION T-16546. TO IMPLEMENT THE 711 ABREVIATED DIALING CODE FOR CONNECTION TO THE CALIFORNIA RELAY SERVICE ADMINISTERED BY THE DEAF AND DISABLED TELECOMMUNICATIONS PROGRAM. TO CHANGE THE DEFINITION OF "BASIC SERVICE" AS DEFINED IN DECISION 96-10-066 TO INCLUDE FREE CONNECTION TO THE CALIFORNIA RELAY SERVICE BY MEANS OF THE 711 ABBREVIATED DIALING CODE.
_________________________________________________________________
SUMMARY
This Resolution establishes the abbreviated dialing code 711 for connection to the California Relay Service (CRS) effective October 1, 2001 and adopts the following provisions with regard to 711 service:
· Adds the following item to the list of services included in Basic Service as defined in Decision 96-10-066, the California Public Utilities Commission's universal service policy decision:
"Free access to the California Relay Service via the 711 abbreviated dialing code."
· Requires all carriers and owners of payphones to provide connection to CRS via the 711 abbreviated dialing code.
· Prohibits charges for connection to CRS and for the time required for establishing a relay call via the 711 dialing code.
· Prevents charges for local calls made through CRS via the 711 abbreviated dialing code, with the exception of wireless providers.
· Permits charges for toll and long distance calls placed via 711 for conversation minutes.
· Strongly encourages reduced rates for toll and long distance calls placed via 711 to accommodate the increased call time for relay calls.
· Specifies public education and outreach requirements related to 711 by means of bill inserts and customer mailings.
· Specifies payphone signage requirements related to 711.
BACKGROUND
Federal Communications Commission (FCC) Reports and Orders
In the FCC's CC Docket No. 92-105, on the use of N11 codes and other abbreviated dialing arrangements, FCC 97-51 (First Report and Order) and FCC 00-257 (Second Report and Order) established 711 as a nationwide code to reach Telephone Relay Service (TRS) providers. The purpose of these orders as they relate to 711 is to fulfill the goals set forth in Title IV section 401 of Public Law 101-336, the Americans with Disabilities Act (ADA), by providing persons with hearing and speech disabilities equivalent access to communication by means of a variety of telephony devices and/or processes. The FCC ordered all telecommunications carriers to provide access for customers to TRS as a toll free call.
Working Groups
The Telecommunications Division (TD) held two working group meetings with representatives of various constituencies related to 711 implementation for the purposes of gathering information prior to holding a public workshop.
Public Workshop
The Telecommunications Division (TD) held two working group meetings with representatives of various constituencies related to 711 implementation for the purposes of gathering information prior to holding a public workshop.
TD conducted a public workshop on April 11, 2001, in San Francisco to gather public input regarding the implementation of 711 in the State of California. A workshop notice was posted on the Commission's Daily Calendar on March 29, 2001 (revised April 5, 2001).
Excluding TD staff, 25 individuals, representing the spectrum of affected parties, attended the workshop. Participants included representatives of payphone operators and the Payphone Service Providers Enforcement (PSPE) program, the California Telephone Association (CTA), a variety of Local Exchange Carriers (LECs), national and local wireless providers, members of the deaf community, the Deaf and Disabled Telecommunications Program (DDTP), and both of the state's major relay service providers. At the workshop TD distributed a document entitled "Workshop on 711 Implementation" to participants to encourage discussion and comments. The draft workshop report was released to workshop participants for comments on April 18, 2001.
Workshop Report Comments
Comments on the draft workshop report were due by May 4th, 2001. The following parties submitted comments by the end of the business day May 4th.
Cooper, White & Cooper (on behalf of Roseville Telephone Company) (Roseville)
Deaf and Disabled Telecommunications Program
Pacific Telesis (Pacific)
Verizon
Hale Zukas - World Institute on Disability
Comments were also received from:
AT&T Wireless
Nossman, Guthner, Knox & Elliot (on behalf of California Payphone Association) (CPA)
The Telecommunications Division received and processed the comments and made necessary changes to the workshop report. This Resolution resolves issues unresolved in the Workshop Report. The final Workshop Report is attached as Appendix A to this resolution.
NOTICE OF AVAILABILITY OF DRAFT AND CONFORMED RESOLUTION AND PROTESTS
In accordance with Public Utilities Code section 311(g)(1), a draft resolution was mailed by July 24, 2001, to the parties of record in OIR R-00-05-001, OII I-87-11-031, R.95-01-021, I.95-01-021, those in attendance at the 711 public workshop of April 11, 2001, and those requesting placement on the service list for the workshop and/or subsequent resolutions related to 711. A copy of the cover letter of this mailing was also sent to all Commission telecommunications carriers informing them that the draft resolution is available at the Commission web site: www.cpuc.ca.gov. In a transmittal letter TD has informed the telecommunications carriers that the draft resolution, and subsequently the conformed resolution, is available on the Commission web site. This letter also informs parties that the final Resolution adopted by the Commission will be posted and available at the same web site. This means of distribution is consistent with the Commission's commitment to utilize our Internet web site for distributing Commission orders and information. In addition, a hard copy of the conformed Resolution will be mailed to all parties of record in OIR R-00-05-001, OII I-87-11-031, R.95-01-021, I.95-01-021, those in attendance at the 711 public workshop of April 11, 2001, and those requesting placement on the service list for the workshop and/or subsequent resolutions related to 711. Comments received on a timely basis will be addressed by TD in this resolution. Comments were received from ______.
DISCUSSION
The fundamental purpose of a unified abbreviated dialing code for access to TRS is to facilitate functionally equivalent access to telecommunication networks by simplifying the various numbers necessary for reaching different relay services. In the past these numbers have varied from state to state as well as from relay service type to relay service type [e.g. Voice Carry Over (VCO), Speech to Speech (STS), and Spanish relay service all have different numbers]. The First Report and Order assigned the abbreviated dialing code 711 to relay services for hearing-impaired and speech-impaired individuals in compliance with Section 401 of Title IV of the Americans with Disabilities Act.
The introduction of the 711 abbreviated dialing code for connection to TRS represents minimal changes to the network functions by which TRS is accessed. However minimal the change to the provision of relay services to the deaf and disabled, implementation of 711 requires some new provisions as well as clarification and amplification of certain provisions with regard to existing TRS regulation.
Technical Feasibility and Minimum Service Quality Standards
The Second Report and Order suggests both Advanced Intelligent Network (AIN) and switch-based technologies are acceptable means for providing connection to the relay service. The Second Report and Order specifies that the specific method of connection to TRS by means of the 711 abbreviated dialing code may be determined by carriers, provided the service does not interfere with TRS's Minimum Service Quality Standards requirements as detailed in Title 47 Section 64.604 of the Code of Federal Regulation. To ensure that the implementation of 711 does not inadvertently reduce the quality of service provision, CRS standards should supercede the federal standards for TRS calls where the CRS standards exceed the federal standards.1
Rate Structures
Title IV of the ADA, which is enforced by the FCC, includes US Code Section 47.225 (d) 1 (D) which requires that "users of telecommunication relay services pay rates no greater than rates paid for functionally equivalent voice communication services with respect to such factors as the duration of the call, the time of day, and the distance from point of origination to point of termination." In order to comply with this federal requirement, calls to CRS via the 711 abbreviated dialing code shall be free of charge. Additionally it should be noted that Title 47 CFR 64.1300(b) specifically prohibits payphone owners from charging for completed calls to TRS providers. Telecommunications carriers that provide dial tone to payphone owners should amend their tariffs to ensure calls from payphones made to CRS via 711 are free. TD recommends that the telecommunications carriers providing service to pay telephones file advice letters by September 15, 2001 to be effective October 1, 2001 that state:
"Payphone owners are not permitted to charge for connection to California Relay Service via 711."
Local calls completed through CRS by the 711 abbreviated dialing code shall be free of charge2 consistent with their handling prior to the designation of 711 as an abbreviated dialing code. Toll and long distance charges may be charged only upon connection to the intended number by CRS. Additionally the FCC recommends, but does not require, the application of reduced toll and long distance rates to accommodate the increased time required by relay conversations. Like the FCC, the Commission supports, but does not require, the reduction of rates for calls made through 711 as a means of ensuring equivalent access to communications for deaf and disabled persons.
Wireless providers stated in comments on the draft workshop report that the language of the rate structure section is preempted by the Omnibus Budget Reconciliation Act of 1993 (OBRA) amendment to the Communications Act, which prevents states from regulating "the entry of or rates charged" for wireless services. This resolution does not set rates for wireless providers.
Basic Service Definition
TD believes changing the definition of Basic Service to specifically include access to CRS by the 711 abbreviated dialing code is essential to the successful accommodation of deaf and disabled persons. Several facts support this change in definition. 711 service meets three of the four criteria necessary for petitions to make amendments to the definition of Basic Service as detailed in D-96-10-066, Appendix B Section (4) (D)(3).
a. The use of CRS is an essential component for the deaf and disabled community's participation in society.
b. The FCC mandates that all carriers provide 711 service by October 1, 2001, so 100% of residential customers subscribe to the service.
c. The qualitative and quantitative costs of the service are outweighed by the benefits as detailed in the FCC's Second Report and Order.
The fourth criteria [(d) availability of the service, or the number of subscribers would not increase without intervention] is not applicable because carriers are required to provide the service to 100% of the state's residential customers.
The addition of 711 service to the definition of Basic Service is consistent with the current requirement in D-96-10-066 to provide "access to telephone relay service as provided for in PU Code 2881." We also agree with the workshop report commenters that the 711 abbreviated dialing code does not represent a fundamental change to the definition of Basic Service but merely ensures the inclusion of an abbreviated form of a mechanism that is part of the existing definition of Basic Service. The definition of Basic Service must be modified in order to ensure that both the rate mechanisms and the breadth of coverage for 711 calls to CRS stay consistent with those already detailed in Decision 96-10-066 and PU Code 2881.
Education and Outreach
Education and outreach are important parts of the successful implementation of the 711 dialing code. The two primary target communities for education and outreach are providers and consumers. Providers need to be informed of their requirements with regard to 711. Telecommunications carriers that provide dial tone for payphones must inform those customers of the change in applicable tariffs as well as their responsibilities with regard to 711 service.
In order for the deaf, disabled and hearing communities to be aware of implementation of the 711 abbreviated dialing code, local and wireless telecommunications carriers are required to include bill inserts to all of their customers informing them of the existence of 711 on and after October 1, 2001, as well as the availability of alternate relay toll free numbers. The insert must be approved by the Commission's Public Advisor with the assistance of TD prior to mailing and may be sent as a separate mailing but must be received by customers prior to October 1, 2001.
Payphones Signage Requirements
Pay telephone signage provides important information to consumers and pay telephone signage should reflect that connection to CRS via 711 is a free call. We believe that payphone signage should state that 711 is a free call to CRS.
Although payphone owners should begin the process of converting signage as soon as possible, TD agrees with workshop comments that the larger payphone owners cannot change signage of all of their phones by October 1, 2001 without incurring substantial added expenses.
We require the telecommunications carriers that provide dial tone to payphone owners to file tariffs by no later than September 15, 2001, to be effective January 1, 2001, that state the following:
"Payphone signage must reflect the fact that 711 is a free call to the California Relay Service using the language `711 is a free call to TRS/CRS'."
FINDINGS
1. All telecommunications carriers and payphone owners should provide free access to the California relay services by October 1, 2001.
2. The basic service definition needs to include connection to California Relay Service via 711 to ensure accommodation to deaf and disabled Californians.
3. California Relay Service Minimum Service Quality Standards should not be diminished by federal standards where California Relay Service standards exceed federal standards.
4. Local calls made through California Relay Service should be free of charge.
5. Toll and long distance charges apply to 711 calls after connection by the California Relay Service to the called number.
6. Ongoing education and outreach should be required to ensure continued awareness of 711.
7. The Commission's Public Advisor should review the bill inserts or mail-outs with assistance from the Telecommunications Division before being mailed.
8. Signage for payphones is necessary to ensure public awareness of the availability and cost of 711.
9. The 711 abbreviated dialing code is an integral part of providing functionally equivalent telecommunication services to the deaf and disabled community.
10. Carriers are encouraged to provide rate discounts for toll and long distance calls placed via 711 as a means of ensuring functionally equivalent access to phone services.
THEREFORE, IT IS ORDERED that:
1. All Local Exchange Carriers, Competitive Local Exchange Carriers, wireless providers and owners of payphones shall provide connection to the California Relay Service via the 711 abbreviated dialing code on or before October 1, 2001.
2. No charges for use of the 711 dialing code shall be permitted with the exception of toll calls and long distance calls once the California Relay Service connects the caller to the intended number.
3. Local calls made through the California Relay Service via 711 shall be free calls.
4. Telecommunications carriers shall file tariffs by September 15, 2001, to be effective by October 1, 2001, that includes language to prohibit payphone owners from charging for access to the California Relay Service and to provide for local calls made via the California Relay Service at no charge.
5. All Local Exchange Carriers, Competitive Local Exchange Carriers, and wireless providers shall provide all California customers with bill inserts or freestanding mailings, approved by the Commission's Public Advisor with consultation of the Telecommunications Division, that contain information about 711 service and the availability of alternate numbers to reach relay providers. These inserts must be mailed by a date that assures delivery prior to October 1, 2001.
6. Telecommunications carriers shall file tariffs by September 15, 2001 to be effective by January 1, 2002, that includes language for payphone owners to include on payphone signage that 711 is a free call to the California Relay Service.
7. The Commission shall add the following to Basic Service as defined in Commission Decision 96-10-066:
"(18.) Free access to CRS via the 711 abbreviated dialing code."
This Resolution is effective today.
I hereby certify that this Resolution was adopted by the Public Utilities Commission at its regular meeting on August 23, 2001 . The following Commissioners approved it:
WESLEY M. FRANKLIN Executive Director |
APPENDIX A
CALIFORNIA PUBLIC UTILITIES COMMISSION
Implementation of the 711 Abbreviated Dialing Code
for the California Relay Service
Final Report for the April 11, 2001 Workshop
CALIFORNIA PUBLIC UTILITIES COMMISSION
505 Van Ness Avenue, San Francisco, California 94102
Table of Contents
TD Proposals, Public Comments and Discussion 55
Signage Requirements for Payphones 1010
Expansion of Basic Service Definition 1111
The Public Programs Branch staff of the Telecommunications Division (TD) conducted a workshop on April 11, 2001. The purpose of the workshop was to discuss issues relating to the implementation of the 711 abbreviated dialing code for access to the California Relay Service (CRS) including implementation deadlines and schedule, rate structure, technical specifications, education and outreach requirements, and signage requirements for payphones.
The workshop report covers background information regarding 711, the workshop discussion and TD staff's proposals and recommendations based on workshop discussions and policies adopted by the Commission for other public programs.
After consideration of the parties' comments, TD recommends the following to ensure successful implementation of 711 in the state of California:
Schedule
TD recommends a Commission vote on July 12, 2001 to give sufficient time for tariff adjustments and outreach and education.
· Education and Outreach
TD recommends bill inserts that include alternative relay provider 800 numbers to strengthen competitive elements between CRS providers.
· Technical specifications
TD recommends carriers use the switching method of their choice to connect 711 calls to the relay service as long as the minimum quality standards required by the FCC are met or exceeded.
· Rate Structures
TD recommends there be no charge for connection to CRS via 711 and that toll or long distance charges occur only after the dialed party is contacted through CRS. Additionally TD recommends that toll and long distance calls be billed at a reduced rate consistent with 225.1.d of the ADA.
· Signage Requirements for Payphones
TD recommends payphones be required to change signage by January 1, 2002 to indicate 711 is a free call.
· Expansion of Basic Service Definition
TD recommends the addition of free connection to CRS via the 711 abbreviated dialing code to the definition of basic service.
· Miscellaneous Items
TD recommends the service list include attendees of the April 11, 2001 workshop and those requesting formal inclusion of the service list as well as parties on the service lists from OIR R00-05-001 and OII I-8711031, excluding duplicates and those parties who formally request being removed from the service list.
The workshop was held in a training room in the state building at 455 Golden Gate Avenue from 9:30am to 12:15pm on April 11, 2001. The workshop adjourned earlier than scheduled after all the items on the agenda were discussed.
The workshop was open to the public (see Appendix B for a list of attendees and Appendix C for the public announcement with the workshop agenda). Excluding TD staff, 25 individuals attended the workshop. There was diversity of representation across the spectrum of effected parties. Participants included representatives of payphone operators and the Payphone Service Providers Enforcement (PSPE), the California Telephone Association (CTA), a variety of Local Exchange Carriers (LECs) and Competitive Local Carriers (CLCs), national and local wireless providers, members of the deaf community, the Deaf and Disabled Telecommunications Program (DDTP), and both of the state's major relay service providers.
Comments on the draft workshop report were due by May 4th, 2001. The following parties submitted comments by the end of the business day May 4th.
Cooper, White & Cooper [on behalf of Roseville Telephone Company (Roseville)]
Deaf and Disabled Telecommunications Program (DDTP)
Pacific Telesis (Pacific)
Verizon
Hale Zukas - World Institute on Disability
Comments were also received by:
AT&T Wireless
Nossman, Guthner, Knox & Elliot [on behalf of California Payphone Association (CPA)]
These comments are included in the report where applicable.
TD Proposals, Public Comments and Discussion
TD proposed the following schedule to ensure implementation of 711 abbreviated dialing consistent with the Federal Communications Commission (FCC) mandated October 1, 2001 deadline.
1. April 11, 2001 Workshop
2. April 18 Mail Draft Workshop Report
3. May 4 Comments on Draft Workshop Report due
4. June 12 Mail Draft Resolution
5. June 22 Comments on Draft Resolution due
6. June 29 Reply Comments due
7. July 12 Commission approves Draft Resolution
8. August 13 Tariffs filed
8. September Educational program(s) take place
9. October 1, 2001 Tariffs effective, implementation finalized
10.January 2, 2002 Pay telephone signage effective
As detailed in FCC 00-257, carriers that have already implemented 711 dialing have found time requirements for implementation of switching mechanisms to be minimal. In addition to the documented minimal time requirements for implementation carriers were required to file hazard notices with the FCC within four months of the release of FCC 00-257 with regard to implementation problems. No such notices were filed indicating no outstanding compliance problems. TD believes that a July approval by the Commission provides adequate time for all physical switching needs as well as customer education and outreach via bill inserts for all carriers regardless of size.
Multiple carriers indicated they preferred August 13 instead of July 12 for the Commission to vote on the Draft Resolution.
Time constraints on implementation issues were a dominant theme in the discussions at the workshop. During these discussions several factors, notably including the time necessary for signage requirements for payphones and tariff revisions, made compliance with the October 1, 2001 deadline difficult to reach for all aspects of the resolution. Pushing back the effective date of the resolution will make the October 1 deadline less likely to reach than keeping the schedule as proposed.
TD recommends that the Commission vote occur on July 12 to ensure sufficient time for bill inserts and tariff revisions. Changes in the schedule specifically related to payphones will be discussed in the subsequent payphone section of this report.
Hale Zukas comments that the uncertainty associated with the status of the primary provider for the California Relay Service was likely to create problems with the implementation of 711 including perceptions of long term unreliability. He suggests instead a November 1, 2001 implementation date.
Hale Zukas comments that the uncertainty associated with the status of the primary provider for the California Relay Service was likely to create problems with the implementation of 711 including perceptions of long term unreliability. He suggests instead a November 1, 2001 implementation date.
In order to ensure maximum public awareness of 711 both within the community traditionally served by relay services and those outside of it, consumer education and outreach efforts should be undertaken. TD proposed a freestanding insert (separate sheet) be included in consumer bills of all carriers. This insert must detail the 711 service in the state of California as well as the existence of alternative relay providers, be free of advertisements or endorsements and approved by the Commission's Public Advisor prior to release. The insert must be distributed at least 30 days prior to the implementation date of October 1, 2001.
AT&T Wireless (ATTW) plans to include information regarding 711 as a regular bill attachment and asked for clarification of the wording of the education and outreach proposal to provide it direction with regard to inserts. ATTW hopes the inclusion of 711 information on its monthly bills precludes any need for an additional insert.
Some carriers indicated they had already included inserts related to N11 services such as 711 and believed these inserts eliminated the need for additional inserts specifically for 711.
The efficacy of bill inserts over printed billing instructions is of great concern to TD. TD believes that ATTW's intended monthly inclusion of information related to 711 on consumer bills is admirable and TD commends their decision. TD believes that the inclusion of 711 information as proposed by ATTW has two significant shortcomings. The first concern is that information related to the availability of alternative relay service providers has been omitted from the language of the information. Secondly, TD questions the efficacy of billing line items similar to those proposed by ATTW as compared to separate informational inserts free of advertising.
TD believes the importance of timely public awareness of the implementation of 711 service outweighs any cost savings related to the retroactive acceptance of previously mailed information related to 711.
TD recommends no changes to the proposal for bill inserts.
DDTP comments that the bill insert should include all of the phone numbers for current CRS providers, direct numbers for Voice Carry Over (VCO), Spanish, and Speech to Speech (STS) to ensure quicker connections to those services. DDTP that local providers should develop a targeted direct mail piece to Private Branch Exchange (PBX) owners informing them of the need for reprogramming their equipment for access to 711 and that the mailer include a customer service number for the local provider.
Verizon comments that it opposes the requirement for bill inserts to disclose the existence of alternative relay providers. Verizon comments that the statement that existing 800 numbers will remain in effect is sufficient to convey information about 711 service and that any additional information will dilute the intended message.
Pacific comments that bill inserts should not be required. Pacific comments that including information about 711 at the end of a bill is more cost effective and less confusing than alternative forms of consumer education.
Roseville comments that clarification of the contents of the bill inserts is necessary.
AT&T comments that bill inserts are not preferable and that the inclusion of information about alternative relay providers will require AT&T to develop a different information plan for the state of California. AT&T comments that period billing statements and information provided to new customers is more effective than one time bill inserts.
FCC 00-257 permits carriers to determine the method by which the connection to the relay service through the use of abbreviated dialing is executed as long as minimum service quality standards and implementation dates are met. Consistent with that report and order, TD proposed carriers implement 711 service using either Advanced Intelligent Network (AIN) technology or switch-based technology as they see fit. Minimum service quality standards as detailed in 47 CFR 64.604 must be met or exceeded.
DDTP requested clarification of presubscription requirements and options. DDTP expressed some concern about the inability to select the relay service provider associated with TD's proposal for all 711 calls to be handled by the primary relay service provider.
The Translation Number has been identified as 866.212.8408 by MCI/WorldCom's (WorldCom) relay service. This number is owned by DDTP.
Bill McClelland was identified as the technician in charge of MCI's relay service. Certain technical questions could be directed to him at bill.mcclelland@wcom.com.
Bill Stobbe (representing DDTP) indicated that the translation number would still be in effect if the CRS provider changes.
Presubscription is not a service offered for the 711 abbreviated dialing code. The existence of alternative relay numbers that do not use abbreviated dialing is functionally equivalent to presubscription.
TD recommends no changes to TD guidelines for technical specifications. Additionally TD does not recommend changes to the design of 711 to incorporate presubscription options using an abbreviated dialing code. TD recommends the adoption of the FCC's minimum service quality requirements as detailed in 47 CFR 64.604 where they are in excess of the minimum service quality standards mandated by CRS.
DDTP comments that problems associated with misdials were not addressed in the workshop. DDTP would like providers to indicate the rate of misdial rates for 71X prefixes and area codes.
Roseville comments that CRS minimum quality standards should only apply to a relay service provider or should be in accordance only with the FCC's standards.
The nature of service provision by CRS via 711 prolongs the length of calls due to call type identification and translation/voicing. In the presence of time-based rates for carrier services this increase in call duration potentially creates inequitable charges for functionally equivalent communication services for persons with hearing or speech disabilities. TD proposed all calls to CRS via 711 be exempted from charges consistent with 47 USCS 225 (d).
TD believes this rate structure applies to all carriers and would like to emphasize that Carriers of Last Resort (CoLR), payphones, and wireless providers, as well as operators of commercial PBX systems are not exempted. With regard to payphone operators, calls to a telecommunication relay service are exempted from charges by payphone service providers under 47 CFR 64.13000(b). TD proposed that all LECs and CLCs that provide dial tone to payphone owners amend their tariffs to include free calls to CRS via 711.
TD proposed that wireless providers not charge for access to 711 including airtime for CRS services because wireless providers are not exempted from 47 USCS 225 (d).
Additionally TD proposed that hotels, hospitals, and other commercial operators of PBX systems be required to provide access to 711.
ATTW declined to discuss its intended rates for 711 in the presence of competitors citing a potential violation of SEC rules related to price fixing. ATTW maintained this viewpoint despite being informed that this was a public workshop, that specific prices would not be discussed and that the rate structure portion of the workshop was trying to determine if a non-zero fee would be associated with 711 service. WorldCom also neglected to indicate a price. Cingular indicated they intended to charge for airtime for 711 calls, but not toll.
The authority of state regulatory agencies over wireless providers is limited at best. ATT's and MCI's minimal contribution provides little clarification of their position regarding rate structures for 711 service. No information was provided with regard to discriminatory rate practices related to 47 USCS 225 (d).
TD recommends that its proposals related to rate structure remain unchanged.
DDTP comments that calls originating from PBXs could potentially charge for set up portions of calls to CRS resulting in additional charges for CRS users through 711. To this end DDTP comments that PBX calls to 711 should be free of charge until the call begins. Additionally DDTP comments that 711 calls from payphones should be free of charge except for any toll or long distance charges.
Verizon comments that clarification of the workshop language is required to indicate that calls to 711 are free but that applicable charges after the call is connected to the called party still apply.
ATTW comments that the CPUC does not have authority to set rates for wireless providers because the language for section 225 of the ADA was codified prior to the OBRA amendment of the Communications Act. ATTW maintains that 225 only prevents ATTW from charging a higher rate for TTY calls than voice-to-voice calls.
Signage Requirements for Payphones
In order to ensure public awareness of the availability of 711, TD proposed that the payphone operator be responsible for installing in a well-lighted location adjacent to each payphone a clearly legible, permanently printed sign indicating that 711 is a toll free call to the CRS for TTY/TDD and voice to voice calls. This language may be added to existing signage requirements as long as no required writing is obscured. This signage requirement is consistent with other signage requirements that currently apply to payphones.
Some payphone providers noted changing tariffs may take longer than the allotted time for implementation. Verizon plans on changing their tariffs to indicate 711 is a free call.
TD proposed that tariff revisions for 711 be filed by July 23 with an effective date October 1, 2001.
Pacific Bell indicated that it would prefer to postpone signage updates until all N11 codes have been assigned to minimize its costs for signage update. Pacific indicated that it projects costs of five dollars per phone if a separate truck rollout is required for signage updates for each of its more than 100,000 payphones.
TD inquired if anyone was opposed to a signage requirement waiver until January 1, 2002. No one objected.
DDTP suggested that signage was very important but that the October 1 rollout should not be delayed to ensure signage requirements would be met.
PSPE indicated that stickers were ineffective for signage requirements because they were frequently removed by the public or applied over existing required signage. PSPE also indicated that payphone owners would be cited for stickers removed by the public.
The concern over timely implementation of 711 with regard to payphones should not interfere with the implementation of the entire program. To this end, TD believes tariff revisions can be made consistent with the schedule outlined above. TD does not believe that signage requirements can be accomplished within this time frame, but does not believe that the cost of signage requirements merits delay of their changes beyond the suggested date of January 1, 2002.
In addition to the signage requirements proposed above, TD recommends implementation of signage requirements and their subsequent enforcement be postponed until January 1, 2002.
Verizon comments that the costs for signage changes on payphones far outweighs the benefits of that signage.
Pacific comments that there is no current requirement for payphone signage related to Telephone Relay Service (TRS) and nothing refers to nor requires payphone signage in the FCC Order. Pacific believes if signage is necessary, it should be permissible to implement the changes during the course of regular service of the payphones as opposed to by January 1, 2002. Pacific comments that under the FCC Order costs for signage would be recoverable from the DDTP fund.
CPA comments that lighting and location requirements from the workshop are not consistent with other lighting requirements and would require unnecessarily expensive modification. CPA comments that additional abbreviated dialing codes will shortly be issued and costs of multiple modifications are unreasonable. CPA comments that signage requirements should be postponed until there are certain dates for additional abbreviated dialing codes.
Expansion of Basic Service Definition
Language referring to 711 does not currently exist in definitions of basic service because an abbreviated dialing number for access to CRS did not exist at the time of the most recent revisions of the definition of basic service. TD proposed the augmentation of the definition of Basic Service (as detailed in Decision 96-10-066) to include:
Free access to the California Relay Service (CRS) via the abbreviated dialing code 711.
Several Carriers questioned the appropriateness of changing the definition of Basic Service outside of a workshop directly related to Basic Service.
Cingular believes it does not provide Basic Service and therefore should not comment on definitions thereof.
Some Carriers indicated that Basic Service is a wireline definition. Numerous members of the wireless industry withheld comment until a later date.
TD suggested that Carriers of Last Resort (CoLR) were providers of Basic Service regardless of their status as wireless or wireline providers.
For the purposes of the successful implementation of abbreviated dialing access to CRS, potential changes to the definition of Basic Service resulting from any other workshops are considered separate from this process. Omission of amendments to the current definition of Basic Service potentially interferes with the provision of 711 service consistent with applicable FCC rulings and orders.
TD recommends changing the definition of Basic Service as detailed in its original proposal.
Roseville comments that the precedent of modifying the definition of Basic Service outside of the context of formal preceding in accordance with D.96-10-066.
ATTW comments that the 711 workshop is an inappropriate venue for changes to definitions of Basic Service.
Miscellaneous Workshop Comments
It was proposed that the service list from the Senate Bill 669 OIR R00-05-001 and the compensation for agencies serving the deaf and hard of hearing OII I-8711031 be used as a source for the service list.
It was proposed that a notice of availability be communicated to TD's entire carrier list.
Bill Stobbe suggested that an expansive service list would discourage smaller companies and organizations from making comments due to excessive costs.
Parties agreed to notify TD to whom they serve their comments.
The cost of an extensive service list is of great concern to all parties including TD. Minimizing the size of the service list while maximizing the dissemination of information to concerned organizations and individuals can best be achieved by borrowing a service list related to DDTP and/or CRS.
TD recommends that the service list include the participating organizations (or where organizations are not applicable, participating individuals) of the April 11, 2001 workshop as well as individuals or organizations unable to attend the workshop but requesting inclusion on the service list. In addition to the workshop attendees the service list from OIR R00-05-001 and OII I-8711031 should be included, excluding duplicates.
Participants:
Jim Baker/PSP Enforcement
Cheryl Bella/Sprint Relay
Pat Chow/Worldcom
Kathy Jo Farey/Cingular
Richard Felix/Evans Companies
Margo Friedrich/Verizon
Brad Hubbard/Roseville Telephone Company
Richard Jankins/Pacific Bell
Barbara Bianchi Kai/DDTP
Abby Kelly/PSP Enforcement
Donald Kountz/Kerman Telephone
Katy M. Lindsay/ATT
Carol McFarland/Sierra Telephone
Marcus Y. Milam/ATT Wireless
Ron Miller/Roseville Telephone Company
Angel Martin/Pacific Bell
Linda Roller/Ponderosa Telephone
Barry Ross/CTA
Randy Sergeant/MCI Worldcom
William Stobbe/HSA/DDTP
Terry Tibble/DDTP
Betsy Wright/MCI Worldcom
George Zein/
Hale Zukas/DDTPAC
Aram Shumavon/TD
Carlos Figueroa/TD
Robert Weissman/TD
David Shantz/TD
Public notices
The workshop notice originally appeared in the CPUC's daily calendar Wednesday, March 28, 2001. It was revised April 5, 2001.
Workshop Notice
April 11, 2001 (Wednesday) 9:30 am - 4:00 pm |
San Francisco Civic Center Conference Center 455 Golden Gate Avenue, Training Room #4 (State Building across from the federal building, Golden Gate between Polk and Larkin) San Francisco California 94102 |
The Telecommunications Division is holding a workshop to address issues related to 711 implementation such as timelines for implementation, signage requirements, call routing, call duration, and additional issues.
People requiring special assistance should contact public advisors office at (415) 703-2074 by April 6th, 2001.
Agenda:
9:30-9:45 - Sign In
9:45-10:00 - Introduction of Participants/Schedule
10:00-10:20 - Review of Process Deadlines
10:20-10:45 - Implementation Time Table and Deadlines
10:45-11:00 - Break
11:00-11:30 - Technical Specifications for 711 Service
11:30-12:00 - Education/Public Information
12:00-1:15 - Break
1:15-2:15 - Rate Jurisdiction
- Revisions to the definition of basic service
- Requirements for payphones
- Requirements for wireless providers
2:15-2:45 - Price Structuring
2:45-3:00 - Break
3:00-3:30 - Miscellaneous Items
Please contact Aram Shumavon of the Telecommunications Division at (415) 703-2117 for further information.
1 TRS is the name used for relay service by the FCC. CRS is the name for the relay service in California.
2 Free of charge means there are no connection fees or charges for any unit of time for local calls placed via 711.
e.g. there would be no charges for a local call made from either a 1FR or a 1MB line.
