VII. Miscellaneous Implementation Issues
ORA expresses concern that the schedule in the OIR provides for only a single workshop to revise the language of GO 153 after the Commission issues its decision adopting enrollment and verification rules. ORA would have us conduct another workshop prior to issuance of this decision. After reviewing the record of this proceeding, we determined that we have an adequate record to move forward to adopt the framework for a new certification/verification system for the ULTS program. However, there are some issues where the record could be augmented, and we will do that in a workshop setting. In response to comments made on the DD, we have scheduled two additional days of workshops. TD will have the option to schedule additional days if necessary to cover the issues.
In order to maximize time at the workshops, parties should follow the following schedule before the April 20, 2005 workshop:
4/11/2005 |
TD posts workshop agenda at: http://www.cpuc.ca.gov/static/industry/telco/index.htm |
4/14/2005 |
Parties provide suggested workshop agenda revisions to: ayy@cpuc.ca.gov |
4/18/2005 |
TD post revised workshop agenda at: |
TD will institute a similar process for the June workshop.
Verizon suggests that the Commission solicit participation of contractors who may be interested in the position of TPA. We believe that it is not appropriate for potential contractors to take part in the workshop to develop RFP specifications, so we will not ask TD to invite those that bid on the TPA position in Texas. Similarly, we reject Verizon's suggestion that the TPA selected be invited to the workshop to develop changes to GO 153. The TPA's role is not to set policy, but to administer GO 153 as directed by the Commission.
Cox indicates that carriers should be permitted to recover the administrative costs of transitioning to a single certification entity. In their comments on the DD, SBC and Verizon express concern that the DD's comment that carriers should be permitted to recover administrative costs during the transition period, was intended to limit their recovery. Such is not the case. We agree with Verizon that under GO 153 carriers are entitled to recover all reasonable costs that are (1) directly attributable to the ULTS program, (2) would not otherwise be incurred, and (3) are not recovered from other sources. As SBC states, such costs may include labor and programming expenses required to interface with the TPA's new system and modify the processing of ULTS orders. RA expresses the need to have a transition period that allows service providers and customers to adjust to the new procedures and minimize program disruption. This issue should also be addressed in workshops.
In its Reply Comments on the DD, Greenlining urges the Commission to conduct a study with the cooperation of ORA. The study would entail surveying at least 250 low-income families that were receiving ULTS before changes to the certification requirements were made but, after new certification requirements were put in place, are not longer receiving ULTS. We reject Greenlining's request for two reasons. First of all, with the rules we are putting into place today, any family that is currently participating in the ULTS program, will retain its eligibility. The rules we adopt here only apply to new applicants for the program on a going-forward basis. Also, if we see the need for a study in the future, we will order a study to be conducted by Commission staff, based on a statistically valid sample of ULTS participants.
