PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Telecommunications Division	RESOLUTION T-16742
Public Programs Branch	May 8, 2003

R E S O L U T I O N

RESOLUTION T-16742, MODIFYING THE CALIFORNIA TELECONNECT FUND PROGRAM RULES TO EXPAND CALIFORNIA TELECONNECT FUND ELIGIBILITY TO INCLUDE COMMUNITY TECHNOLOGY PROGRAMS AND ALLOW ALL QUALIFYING ENTITIES TO RECEIVE IDENTICAL DISCOUNTS ON THE SAME TYPES AND QUANTITIES OF SERVICE.

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Summary

This resolution is issued to implement portions of Senate Bill (SB) 1863 (Stats. 202, Ch. 308) intended to focus efforts on providing educational institutions, health care institutions, community-based organizations and governmental institutions with access to advanced telecommunications services in recognition of their economic and societal impact.

This resolution is also issued pursuant to Commission Decision (D.) 02-10-060, which directed the Telecommunications Division (TD) to prepare a resolution implementing certain changes to the California Teleconnect Fund (CTF) program rules. The CTF rules currently provide different types and quantities of services at varying discount levels to schools and libraries, qualifying health care institutions and community-based organizations (CBOs). The changes to the CTF program rules adopted in this resolution will allow all qualifying entities to receive the same quantities and types of services at the same discount levels. Among the services available to participating entities, Digital Subscriber Line (DSL) service is specifically named as a service eligible for CTF funding.

This resolution streamlines the CTF application for all participants, reflecting changes to the program qualifying requirements and application process pursuant to the provisions of D.02-10-060, and implementation of SB 1863. In addition, this resolution adds hospital district owned hospitals to the list of health care institutions eligible to participate in the program. Finally, this resolution adopts a reporting requirement for carriers to file estimates of program expenses associated with reimbursements for CTF discounts for future periods.

Background

SB 1863 adds Public Utilities Code Section 884. Section 884(a) states the intent of the legislature

"...that any program administered by the Commission addressing the inequality of access to advanced telecommunications services by providing those services to schools and libraries at a discounted price should also provide comparable discounts to a nonprofit community technology program."

The bill also stated the policy goal of focusing efforts on providing education institutions, health care institutions, and community-based organizations with access to advanced telecommunications services in recognition of their economic and societal impact.

In D.96-10-066 dated October 25, 1996, the Commission established the CTF to provide discounts on selected telecommunications services to qualified schools and libraries, municipal or county owned and operated hospitals or health clinics, and CBOs offering health care, job training, job placement, and/or educational instruction. The CTF discount amounts and the type and quantity of eligible services currently available to each category of qualifying entity are listed in the table below:

Qualifying Entity	Eligible Services	CTF Discount
School and/or Library	All Measured Business Service lines, Switched 56 lines, ISDN, T-1, DS-3 and up to and including OC-1921 services or their functional equivalents	50%
Municipal or County Government Owned and Operated Hospital and Health Clinic	Switched 56 lines, ISDN, T-1, and DS-3 or their functional equivalents	20%
Community Based Organization	Two switched 56 lines or their functional equivalents, or two ISDN lines or their functional equivalents, or one switched 56 line or its functional equivalent and one ISDN line or its functional equivalent, or one T1 line or its functional equivalent	25%

The decision in Rulemaking 01-05-046, investigating the feasibility of redefining universal telephone service to include high-speed internet access, refers to comments from the public and certain parties suggesting that low participation by hospitals, health clinics and CBOs may be due, in part, to the low discounts and limited types and quantities of service available under the program. Certain parties and the public also commented that the application process was unduly burdensome, discouraging participation. D.02-10-060 directed TD to prepare a resolution implementing changes to the CTF allowing all qualifying entities to receive the same type and quantities of services at identical discounts.

Discussion

The modifications adopted in this resolution implement certain requirements of SB 1863, expanding CTF eligibility. As noted above, Section 884(a) requires that the same CTF discounts available to schools and libraries apply to community technology programs. Section 884(b), added to the Public Utilities Code by SB 1863, defines community technology program as:

"...a community-based nonprofit organization that is exempt from taxation under Section 501 (c)(3) of the Internal Revenue Code and engages in diffusing technology into local communities and training local communities that have no access to or have limited access to the Internet and other technologies."

The original qualifications and list of services CBOs must offer in order to receive CTF discounts was established in D.96-10-066. It reads:

"In order to qualify for the CBO discount, a CBO must provide proof at the time of application that it is a tax exempt organization. This CBO must also certify that it offers health care, job training, job placement, or educational instruction."²

Thus, in accordance with SB 1863, this resolution makes CTF discounts of 50% available to CBOs and expands the list of eligible CBO activities to include community technology programs as defined in Section 884(b).

The modifications adopted in this resolution are also made pursuant to Decision (D.) 02-10-060, dated October 24, 2002. In that decision, the Commission determined that increasing discount levels and eligible types and quantities of services for CBOs and qualifying health care institutions to match those currently available to schools and libraries, will lead to increased participation in the CTF program by these entities. Modifications streamlining the application process will also lead to increased participation in the program.

Parties commenting on the draft resolution noted that the original definition of CTF-eligible health care institutions, contained in D.96-10-066, excluded hospital district owned hospitals and health clinics, although those institutions provide a substantial share of local government supported health care in California. The Commission agrees and adds hospital district owned hospitals and health clinics to the definition of qualifying health care institutions.

Various parties asked that DSL be included in the list of services available for CTF discounts. The Commission believes that DSL is already included in the list of available services. Although not specifically named, DSL would be included under the category of "or their functional equivalents". However, in order to remove any confusion, this resolution specifically adds DSL to the list of CTF eligible services.

This resolution adopts the following levels of discounts and services for the corresponding eligible entities:

Qualifying Entity	Eligible Services	CTF Discount
School and/or Library, Municipal, County Government or Hospital District Owned and Operated Hospital and Health Clinic, Community Based Organization	All Measured Business Service lines, Switched 56 lines, ISDN, DSL, T-1, DS-3 and up to and including OC-192 services or their functional equivalents	50%

All telecommunications carriers offering the services described in Rule 8 (b), (c), and (d) of Appendix B of D.96-10-066 and Attachment A of Resolution T-16542 are directed to file Advice Letters making these changes within 30 days from the effective date of this Resolution. Such Advice Letters and the associated tariff pages setting forth the discount levels for the CTF-eligible services will become effective 15 days after the Advice Letters are filed.

In response to concerns by certain parties in R.01-05-46, this resolution also streamlines the CTF application process. Under this modified process, applicants will no longer be required to submit their applications to telecommunications carriers, which in turn were responsible for forwarding completed applications to the Commission. Carriers will no longer be involved in the application process. All applications filed after the effective date of this resolution will be filed with the Commission. The Telecommunications Division will notify applicants of their eligibility in writing. That notification letter will include a copy of the application with the application filed-date stamped on the application. The entity becomes eligible for participation in the CTF program on the filed-date stamped on the application. The filed-date is the first date upon which the fund will reimburse carriers for discounted services that have been provided. Once applicants have received their notification of eligibility, they may then contact the service providers in their areas, provide a copy of the Commission's qualifying letter and date-stamped application as proof of eligibility and arrange to obtain discounted services.

Current CTF participants will not have to re-file applications based on their ability to receive more services and higher discounts, but must notify their service providers of the new types and quantities of services to which they wish to subscribe. Anytime participants subscribe to additional CTF eligible services, they must inform their carrier's customer service representative, at the time they add new services, of their participation in the CTF program. This will ensure accurate and timely claims processing and payment. Entities who filed applications prior to May 9, 2003, that are pending as of the effective date of this resolution and who are subsequently notified of eligibility, will not have to re-file. Their date of eligibility for participation will be the date stamped on the previously filed application. The list of CTF eligible entities will be posted on the Commission's website.

The application, Attachment A to this resolution, reflects changes to the instructions and qualifications for participation in the CTF program and the streamlined application process.

With the increased participation anticipated by these changes to the program, it will be more important than ever to track program fund requirements. To that end, no later than July 1, 2003, all participating carriers shall provide a written forecast of anticipated CTF claims for the fiscal year 2004/05. By March 1, 2004 for fiscal year 2005/06, and every March 1^st thereafter, all participating carriers shall provide a written forecast of anticipated CTF claims for the following fiscal year (July 1 through June 30). This forecast shall include information with regard to the carrier, their CPCN number and total of services subject to discount, total E-rate discount, total CTF discounts, taxes, user fees, and total claims categorized as to schools and libraries, municipal, county government or hospital district owned and operated hospitals and health clinics and CBOs. These three categories shall be totaled. This information shall be provided on a month-by-month basis for the entire fiscal year. The provision of a monthly breakdown is required by TD to determine varying cash flow requirements because of delays or termination of E-rate discounts. This information is to be mailed or faxed to the Telecommunications Division.

Commencing on February 1, 2004 and every February 1^st, thereafter, the Director of the Telecommunications Division shall provide CTF claimants a written reminder that forecasts of anticipated claims for the following fiscal year are due March 1^st. The CTF Claim Forecast Worksheet format carriers are to use is set forth in Attachment B of this resolution.

Comments

In accordance with P.U. Code Section 311 (g), a draft resolution prepared by the Telecommunications Division staff was mailed on April 8, 2003, to the parties of record in Rulemaking (R.) 95-01-020/Investigation (I.) 95-01-021; R.01-05-046, all Competitive Local Exchange Carriers and all Incumbent Local Exchange Carriers; CTF Administrative Committee members; all carriers who currently participate in the CTF program; Community Based Organizations and eligible hospitals and health clinics for which CTF applications have been filed, and signed, completed copies of the applications have been sent to the applicant. These parties were informed of the availability of the conformed resolution at the Commission's website,

http://www.cpuc.ca.gov/static/industry/telco/proceedings/resolutions/index.htm.

The comment filing deadlines were contained in a cover letter that was not posted to the Commission's website with the Draft Resolution. Because of this, the initial and reply comment deadlines were extended from April 23^rd and April 28^th, to April 28^th and May 1^st, respectively. Initial comments were received from eight parties:

Community Technology Foundation of California (CTFC)

Office of Ratepayer Advocates (ORA)

SBC Pacific Bell (SBC)

Congress of California Seniors (CCS)

AT&T Communications of California (AT&T)

Verizon of California, Inc. (Verizon)

Christine Karim

California Community Technology Policy Group (CCTPG)

Reply comments were received from the Small Local Exchange Carriers (Small LECs) and Verizon. Only those reply comments conforming to the rules regarding reply comments will be addressed here.

Expand Definition of CBO

CCS, CTFC and CCTPG express support for a broader definition of qualifying CBOs to encompass all CBOs in recognition of their societal and economic impact. Section 709(b) of SB 1863 states:

"To focus efforts on providing educational institutions, health care institutions, community-based organizations, and governmental institutions with access to advanced telecommunications services in recognition of their economic and societal impact"

If the parties' interpretation of the above language is accepted, all educational and health care institutions will have to be included in the definition of CTF eligible entities as well as all CBOs. There is nothing in the legislative language to suggest this is the intent. In fact, if it were the intent, the language specifically pertaining to community technology centers would be unnecessary since they would be included under the umbrella of all CBOs. The suggestion to include all CBOs as CTF eligible entities is not adopted, however, any language in the resolution or application that could cause confusion on this point has been clarified.

Include Non-Profit Hospitals As Eligible Entities

CCTPG seeks the inclusion of non-profit hospitals as CTF eligible entities. If non-profit hospitals were included, one of the states largest healthcare providers would be eligible for CTF discounts. There is no indication in the original decision or SB 1863 that non-profit health care facilities should be included and the Commission is unconvinced that such a step should be taken now.

Commission and Utility CTF Contact Persons

It is suggested that the Commission post on its website, the name and number for Commission and utility CTF contact persons. The Commission has processes currently in place to aid the public in obtaining information about any regulated utility or public program. The Commission's website has a "Contact Us" button where the user can designate a regulated utility and send an e-mail asking a question or seeking information. The e-mail is forwarded to a staff member knowledgeable in the area. Similarly, the Commission's receptionists have functional phone lists to direct calls to appropriate staff based on the information provided by the caller. The Commission believes these systems are adequate to ensure the public has access to the information they seek and will continue its efforts to inform the public about these processes. Utilities should ensure that their customer service representatives are able to assist CTF participants with any questions they might have. No contact information for specific individuals will be posted on the Commission's website.

Application Review Deadline

The CCTPG and Ms. Karims seek a 30-day application review deadline. It is understandable that participants desire a quick response on applications and that is the Commission's desire as well. It is anticipated that the increased discounts and services, and expanded definition of qualifying entities will result in increased participation. The increased participation could in turn result in a large number of applications being filed, especially in the months immediately following the release of this resolution. Imposing a 30-day review period is unrealistic, especially in light of the expected number of new applications. However, the Commission's goal is to see all eligible entities receive the benefits of the CTF program as soon as possible. To that end, Commission staff will review applications and notify applicants of their program eligibility status as quickly as possible.

Implementation Date

Verizon asks for an implementation date of July 1, 2003, while the CCS asks that implementation of the expanded discounts and services be retroactive to January 1, 2003. Verizon argues that the later implementation dates gives carriers time to adjust to the new program elements while CCS posits that the earlier date will allow participants to benefit from greater program discounts. The implementation date will remain as previously stated. To apply the implementation date retroactively adds another layer of administrative confusion to the claims process while delaying it needlessly deprives participants of program benefits.

Claims Forecasting

All the utilities express concern about their ability to accurately provide the CTF claims forecasting required by this resolution. They state that federal E-rate contributions are notoriously slow and therefore unreliable for forecasting purposes. The Commission is seeking the claims forecasting information as a means to ensure that the program budget is sufficient to meet program participation. Because claim payments are dependent upon program funding and program funding will be determined in part by the utilities' claims forecasts, it is in the utilities best interest to provide information that is as accurate as possible. Forecasts are estimates and it is therefore understood that absolute accuracy is impossible. The Commission merely requires the utilities to use the best available information in their forecasts and therefore no claim revision process will be necessary as requested by Verizon. However, if utilities were to submit their forecast and shortly thereafter receive more accurate information, the Commission would gladly accept an updated version. Timing is crucial though, as the state budget process requires the Commission to submit its program budget well in advance.

Competitive Local Exchange Carrier (CLEC) Participation

Verizon believes that the draft resolution imposed a new requirement that CLECs participate in the program and requests that they be exempt. Ordering Paragraph 10(a) of D.96-10-066 states:

"All telecommunications carriers offering the services described in Rule 8.B., Rule 8.C., and Rule 8.D. shall revise their tariffs within 45 days from the effective date of this decision to reflect these discounts."

The requirement for CLEC participation in the CTF program existed prior to the draft resolution. The Commission will not exempt CLECs from participating.

Workshops and Outreach

Various parties call for workshops to explain the application process and outreach efforts to inform and encourage broader participation in the CTF program. If this were a new program or if the existing application process were being made more complex, a series of workshops strictly for that purpose might be necessary. Neither is the case here, in fact the application process has been simplified, streamlined and is self-explanatory. However, the Commission agrees that outreach efforts are necessary and as part of the Public Advisor's ongoing outreach efforts, workshops may be scheduled for the purpose of informing and educating the public about the program's existence and benefits. The Public Advisor's office is currently engaged in efforts to determine how best to disseminate information about the CTF program to eligible entities that are not aware of or not currently participating in the program. Some of those efforts include better website information on the program, developing information packets explaining the program and compiling distribution lists with the help of knowledgeable CBO staff, individuals, organizational networks and other government agencies. Parties are encouraged to contact the Commission's Public Advisor's Office at 415-703-2074 for more information on these efforts.

Program Funding

The utilities are concerned the new streamlined application process, which does not include a check of CTF funding availability, coupled with increased participation could result in situations where CTF services are provided although no CTF funds are available to reimburse utilities. Similarly, other parties ask the Commission to ensure program funding is adequate to meet the needs of all eligible participants. Since the inception of the program, the Commission has monitored participation and claims to ensure adequate funding for each year's participants. The Commission-established cap has never been reached and no eligible entity has ever been denied services nor utility claim gone unpaid because of program funding shortfalls. The Commission intends to continue monitoring program needs and making the necessary adjustments to ensure the program is adequately funded. The utilities' claims forecasting requirement established by this resolution will assist in this effort and alleviate some of the uncertainty created by the new streamlined application process.

Reimbursements

AT&T and Verizon suggest that claims reimbursement go directly to the program participants rather than to carriers. Carrier participation is essential since it is the carriers who have the information regarding the services subscribed to by each participant. Removing the carrier from this process will complicate claims reimbursement, not simplify it.

Findings

1. Senate Bill (SB) 1863 states that telecommunications policies in California should focus on providing educational institutions, health care institutions and Community Based Organizations (CBOs) with access to advanced telecommunications services in recognition of their economic and societal impact.

2. The intent of SB 1863 is that any CBO engaged in diffusing technology into local communities via nonprofit community technology programs should qualify to receive the same California Teleconnect Fund (CTF) discounts as schools and libraries performing the same function.

3. In Decision (D.) 02-10-060, the Commission found that increasing the discount levels and eligible services for CBOs and municipal or county government owned and operated hospitals and health clinics to levels which are currently available to schools and libraries, will lead to increased participation in the CTF program for these entities.

4. Ordering Paragraph 2, of D.02-10-060, directs the telecommunications Division to prepare a resolution increasing the CTF discount levels and types and quantities of service to eligible municipal or county government owned and operated hospitals and health clinics and CBOs to match those currently available to schools and libraries.

5. In the proceeding that led to D.02-10-060 (Order Instituting Rulemaking 01-05-046) parties stated that the CTF application process was too burdensome and discouraged participation in the program.

6. The CTF application must be revised to reflect the expanded list of qualifying entities and to streamline the application process by allowing entities to file applications directly with the Commission.

7. With the increased participation anticipated by the changes to the program, it will be necessary for carriers to file annual estimates of program funding requirements. Carriers should be reminded of this requirement, in writing, every year

8. On April 8, 2003, the draft of this resolution was mailed to the parties of record in Rulemaking (R.) 95-01-020/Investigation (I.) 95-01-021; R.01-05-046, all Competitive Local Exchange Carriers and all Incumbent Local Exchange Carriers; CTF Administrative Committee members, all carriers who currently participate in the CTF program; Community Based Organizations and eligible hospitals and health clinics for which CTF applications have been filed, and signed, completed copies of the applications have been sent to the applicant. A copy of the cover letter of that mailing was also sent to each of the Commission certificated telecommunications carriers advising them of the availability of the draft resolution and the conformed resolution, when adopted by the Commission on the Commission's website.

9. The comment filing deadlines were contained in a cover letter that was not posted to the Commission's website with the Draft Resolution. Because of this, the initial and reply comment deadlines were extended from April 23^rd and April 28, 2003, to April 28^th and May 1, 2003, respectively.

10. Initial and Reply Comments were timely filed by parties and are addressed in the body of the resolution.

11. Because they provide a substantial share of government-supported health care in California Hospital, district owned and operated hospitals and health clinics should be added to the definition of qualifying health care institutions.

12. Digital Subscriber Lines should be specifically named as CTF eligible services.

THEREFORE, IT IS ORDERED that:

1. The California Teleconnect Fund (CTF) program rules are modified to allow qualified health care institutions and Community Based Organizations (CBOs) to receive 50% discounts on all Measured Business Service, Switched 56, ISDN, DSL, T-1, DS-3 and up to and including OC-192 services or their functional equivalents.

2. The CTF program rules are modified to expand the list of CBOs eligible for CTF discounts to include non-profit CBOs operating community technology centers engaged in diffusing technology into local communities, and training local communities that have limited or no access to the Internet and other technologies.

3. All certificated telecommunications carriers are directed to file Advice Letters to reflect the new CTF discounts and expanded types and quantities of services within 30 days of the effective date of this resolution. The Advice Letter and associated tariff sheets shall become effective within 15 days of the filing.

4. All entities applying to participate in the CTF program will now file their applications directly with the Commission's Telecommunication Division, Public Program Branch as set forth in Attachment A of this resolution.

5. The Director of the Telecommunications Division shall, by letter, send a copy of the reviewed and signed application to applicants, notifying them of their eligibility to participate. The date of eligibility will be the date-filed stamped on the application.

6. The Commission shall post a list of qualified entities on its website

7. CBOs and municipal or government owned and operated hospitals and health clinics currently participating in the CTF program do not need to reapply to the Commission to receive the increased discounts and services, but must notify their service providers of new services to which they wish to subscribe and inform the service provider of their current participation in the CTF program.

8. The CTF application instructions and form, as set forth in Attachment A of this Resolution, are adopted.

9. All CTF participating carriers shall, by July 1, 2003 provide a written forecast of anticipated CTF claims for the 2004/05 fiscal year. Such forecast shall be submitted to the Director of the Telecommunications Division in the format set forth in Attachment B of this resolution.

10. All CTF participating carriers shall, by March 1, 2004 and every March 1^st thereafter, provide a written forecast of anticipated CTF claims for the following fiscal year (July 1 through June 30). This information is to be mailed or faxed to the Telecommunication Division and the CTF Administrative Committee. Such forecast shall be submitted to the Director of the Telecommunications Division in the format set forth in Attachment B of this resolution.

11. The Annual CTF Claim Forecast Worksheet, as set forth in Attachment B of this resolution is adopted.

12. Commencing on February 1, 2004 and every February 1^st, thereafter, the Director of the Telecommunications Division shall provide CTF claimants a written reminder that forecasts of anticipated claims for the following fiscal year are due March 1^st.

This Resolution is effective today.

I hereby certify that the Public Utilities Commission at its regular meeting on May 8, 2003, adopted this Resolution. The following Commissioners approved it:

/s/ WILLIAM AHERN

WILLIAM AHERN Executive Director

MICHAEL R. PEEVEY President
CARL W. WOOD
LORETTA M. LYNCH
GEOFFREY F. BROWN
SUSAN P. KENNEDY
Commissioners

ATTACHMENT A

California Teleconnect Fund (CTF)-

Service Discounts Certification Application

Instructions for Applicants:

Applicants shall provide all information required on the application and return the completed application to the Commission for review. If applicants are applying for discounted services under more than one entity type, a separate application form is to be used for each entity type. Service under the discounted rates is not available until the application has been reviewed, in the order received, by the California Public Utilities Commission (CPUC) staff.

The Telecommunications Division will notify eligible entities, in writing, of the status of their application. The specific date of eligibility will be date stamped on your application, which will be returned with the notification letter. Applicants should then contact their service providers to receive service using the notification letter as proof of eligibility. Confirmed eligibility does not automatically establish participation. All participation is subject to the availability of program funds, which are administered on a first come, first served basis. If applicants add to or change subscribed services after they start participating in the program, they must inform the utility customer service representative at the time changes are made, of their participation in the CTF program. This information is necessary to ensure accurate claims information and timely program payments

Applicants are responsible for notifying the CPUC of any change in any statements attested to in the application within 30 days from the date of the change. This notification shall be accomplished by filling out a new certification application, along with any required attachments, and a brief explanation of the change. All applications and any notifications of changes shall be mailed or hand delivered to the CPUC, Telecommunications Division - Attention: California Teleconnect Fund, 505 Van Ness Avenue, Third Floor, San Francisco, CA 94102. Upon receipt of information regarding changes, the staff will evaluate whether the customer still qualifies for the California Teleconnect Fund discounts.

CTF Application No.

CALIFORNIA TELECONNECT FUND

Service Discounts Certification Application

Name of Institution or Organization__________________________________________________________

Mailing Address:_____________________________________________________________________

Please check one of the following boxes to identify your entity type (use a separate form for each entity if you are applying for service discounts under more than one type):

Date Stamp

_______ K-12, Public School / Public School District

Please enter your CDE Code #: ___________________

_______ K-12, Non-Profit Private School

Please enter your CDE Code #: ___________________

(Please attach a copy of tax-exempt statement from

the Internal Revenue Service.)

_______ Library eligible for funds in the state-based plans

under Title III of the Library Services and Construction

Act, now the Library Services and Technology Act.

(Please attach a copy of certification from the California State Library.)

_______ Municipal, county government or hospital district owned and operated hospital or health clinic.

_______ Community based organization, tax exempt under Section 501(c)(3) or 501(d) of the Internal Revenue Code and offering at least one of the following : health care, job training, job placement, educational instruction or a community technology program offering access to and training in the Internet and other technologies.

(Please attach a copy of your tax-exempt statement from the IRS and your latest IRS Form 990.)

Please answer yes or no to the following question as appropriate:

_______ If you are applying as a school, do you have a total endowment that exceeds $50 million?

Applicant is responsible for notifying the California Public Utilities Commission

within 30 days of any change in any of the above statements.

I, (please print name and title) _______________________________________________________, ____________________________ declare under penalty of perjury under the laws of the State of California that I am authorized to act on behalf of the above-named institution, that the above statements are true and accurate to the best of my knowledge and belief, and that the subscribed discounted telecommunications services will not be sold, resold, transferred or shared with any other non-qualifying entity or person.

Signature: ________________________________________ Date: ________________________

Tel: ( )____________ FAX (Required): ( )____________ E-Mail (Required): _________________

For CPUC Use only: Certification Application Complete: Yes ____ No_____ Initials: __________ Date: _______________

ATTACHMENT B

¹ Resolution T-16542, July 12, 2001, added OC-1, OC-3, OC-12, OC-48 and OC-192 services, or their functional equivalents, to the list of discounted services available to schools and libraries.

² D.96-10-066, p.85