NOTICES
Order
[40 Pa.B. 1281]
[Saturday, March 6, 2010]Public Meeting held
February 11, 2010Commissioners Present: James H. Cawley, Chairperson; Tyrone J. Christy, Vice Chairperson, Statement; Kim Pizzingrilli; Wayne E. Gardner; Robert F. Powelson
Petition of the United Way of Pennsylvania for Information and Referral for the Assignment of 2-1-1 Abbreviated Dialing Code and the Designation of PA 2-1-1 as the Lead Implementing Agency for Pennsylvania 2-1-1 Service; Doc. No. P-2009-2136921
Order By the Commission:
On October 19, 2009, pursuant to the provisions of 52 Pa. Code § 5.41, the United Way of Pennsylvania (''UWP''), the state association representing local United Way chapters that serve communities throughout the Commonwealth of Pennsylvania, filed a petition requesting the assignment of the 2-1-1 abbreviated dialing code to the not-for-profit organization, PA 2-1-1, so that it can be the leading implementing agency of the 2-1-1 abbreviated dialing code for the provision of Information and Referral Services (''I&R Services'') for the State of Pennsylvania. In accordance with 52 Pa. Code § 5.41, UWP served copies of this petition on all parties directly affected and on other parties whom they deemed would be affected by the petition. Specifically, UWP served the petition on the following parties: the Commission's Office of Trial Staff, the Office of Consumer Advocate (''OCA''), the Office of Small Business Advocate (''OSBA''), the Pennsylvania Telephone Association (''PTA''), Verizon Pennsylvania, Inc. and Verizon North, Inc. (hereinafter jointly referred to as ''Verizon'') and The United Telephone Company of Pennsylvania, LLC, f/d/b/a Embarq Pennsylvania (now d/b/a CenturyLink). Additionally, a notice regarding UWP's Petition was published in the Pennsylvania Bulletin on January 2, 2010. See 40 Pa.B. 127 (January 2, 2010).
The Commission received over seventy comments on the UWP's petition. Most notably, comments were received from Senator Jay Costa, Representative Nick Kotik, Representative Dom Costa, the OCA, PTA and Verizon. Based on the information submitted by UWP and the content of the numerous comments, the Commission grants in part and denies in part the petition.
Background
On July 21, 2000, the Federal Communications Commission (''FCC'') ruled that the 2-1-1 abbreviated dialing code should be used exclusively to provide access to community information and referral services.1 The FCC, acting on a petition filed in 1998 by the United Way of America, the Alliance of Information and Referral Services (''AIRS'') and several other partners, assigned the 2-1-1 abbreviated dialing code as the universal telephone number for non-emergency community information and referral services.2 The FCC recognized that a universally and easily recognizable number would make it possible for callers in need to make critical connections with the appropriate community-based organizations and government agencies more easily.3 Accordingly, the FCC reserved the 2-1-1 dialing code for community information and referral services. However, in its order assigning the 2-1-1 dialing code for community information and referral services, the FCC left nearly all implementation issues for any interested local I&R Services group and relevant telecommunications carrier to sort out. The only direction given by the FCC in its order is that, once an entity requested the abbreviated dialing code 2-1-1 from a telecommunications provider, the provider had to grant them access to 2-1-1 dialing in its service territory.
In the meantime, the United Way of Southeastern Pennsylvania had filed a petition at Docket No. P-00001816 with the Commission on June 30, 2000. In its Petition, the United Way of Southeastern Pennsylvania requested the assignment of the 2-1-1 abbreviated dialing code to the Southeastern Pennsylvania 2-1-1 Collaborative for the purpose of providing community service information and referrals in the portion of the then-Bell Atlantic—Pennsylvania, Inc.'s4 (now Verizon Pennsylvania, Inc.) service territory comprising the five county Greater Philadelphia region (Philadelphia, Bucks, Chester, Delaware and Montgomery).
As mentioned previously, subsequent to this filing, the FCC had issued its order assigning the 2-1-1 abbreviated dialing code Nationwide for the purpose of community information and referral services. Based upon its reading of the FCC's July 21, 2000 Order, the Commission stated that the FCC clearly stated that the entity requesting the use of the 2-1-1 abbreviated dialing code should make its request directly to the provider of telecommunications services in its service area. Accordingly, by an Order entered October 3, 2000, the Commission held that the United Way of Southeastern Pennsylvania's Petition was moot and advised the United Way of Southeastern Pennsylvania to follow the procedure as set forth in the FCC Order and dismissed the petition.
In 2006, UWP and the Pennsylvania Association for Information & Referral (''PAIR''), which is the Pennsylvania affiliate of the AIRS, joined forces and established a taskforce called the Pennsylvania 2-1-1 Collaborative that was made up of representatives from across Pennsylvania. Finally, in 2009, PA 2-1-1 was formed as an independently incorporated Pennsylvania not-for-profit organization dedicated to providing all Pennsylvanians with access to non-emergency community information and referral services. Additionally, UWP has been in contact with the service providers regarding the 2-1-1 abbreviated dialing code. Accordingly, UWP has filed this instant petition requesting the assignment of the 2-1-1 dialing code to PA 2-1-1 as the leading implementing agency for 2-1-1 service in Pennsylvania. For these reasons, we believe that the petition is ripe for action.
Discussion
UWP and PAIR are seeking to establish a Statewide 2-1-1 system that will provide users with easy access to information about the full range of public and private community programs and services provided throughout Pennsylvania. In an effort to accomplish this task, UWP and PAIR, along with other interested parties established PA 2-1-1, an independently incorporated nonprofit organization that was created solely for the purposes of providing all Pennsylvanians with easy access to community information and referral services. As mentioned previously, UWP served its petition on the prominent telecommunications companies and notice of the Petition was also published in the Pennsylvania Bulletin. Over seventy comments were received by the Commission. While we acknowledge that all the comments did not unanimously take the position that PA 2-1-1 is the proper entity to implement 2-1-1 service within Pennsylvania, the comments were unanimous in their endorsement that 2-1-1 service is much-needed in Pennsylvania.
We note that there have been successful efforts across the United States to implement health and human services I&R telephone call centers accessed by ''2-1-1'' dialing codes. As of November 2008, 2-1-1 has served over 234 million Americans through 244 2-1-1 systems covering all or part of 48 states plus Washington, D.C. and Puerto Rico. Pennsylvania is one of the last remaining states to not have implemented a 2-1-1 system.
In those states where 2-1-1 service has been successfully implemented and ongoing, generally, a single I&R organization has emerged as the ''developmental leader'' for 2-1-1 implementation. This organization has partnered with other bodies in the interest of developing an inclusive group to provide solutions to the obstacles against development of a viable 2-1-1 system. We believe that the UWP has demonstrated that PA 2-1-1 will have the knowledge, skills and technical expertise to serve as the lead implementing agency for providing 2-1-1 service in Pennsylvania.
In its Petition, the UWP explains that PA 2-1-1 is governed by a 12—15 member Board of Directors (''Board'') responsible for the development, operation and oversight of the 2-1-1 abbreviated dialing code in Pennsylvania. Representatives of the PA 2-1-1 Board reflect the geographic diversity of the state and include representation from: UWP, PAIR, and representatives from inter alia, the business community, county government, Red Cross, Volunteer Centers, Community Action, and the like. The Board is responsible for establishing the policies and overseeing the use of the 2-1-1 designation, securing and equitably distributing the resources required to complement regional investment to ensure full implementation and sustenance of the proposed system and ensuring quality service by establishing and monitoring performance against standards for regional 2-1-1 centers.
Furthermore, as 2-1-1 service is implemented in Pennsylvania, the Board will be complemented by an Operating Council—composed of Regional 2-1-1 Center directors, organized and led by the state executive director—that will advise the executive director on the shared functions that will link the regional centers with one another and provide consistency of operations and uniform quality throughout the system. The Council will identify and resolve system-wide operational issues, define needs and priorities for capacity building within the system, and assist in the planning and implementation of Statewide marketing activities. The Council will also be responsible for building the 2-1-1 network locally so that it includes both specialized I&R agencies, the service providers themselves and other business and local organizations as active partners and funders.
The proposed 2-1-1 system will be accountable to the PA 2-1-1 Statewide organization but delivered locally by six or seven regional call centers. In its petition, the UWP stated that PA 2-1-1 has defined initial regions for the provision of 2-1-1 service. The regional call centers will be AIRS-certified and operate and answer calls 24 hours a day, 7 days a week, 365 days of the year. Additionally, the centers will form a network that can respond quickly to everyday calls from consumers as well as during times of emergency by distributing calls so that no one call center is overloaded. PA 2-1-1 is currently in the process of ensuring that each regional call center determines the best manner to make 2-1-1 service available to all residents within its region.
Additionally, PA 2-1-1 has designated a ''lead convener'' for each proposed region that will bring together other interested stakeholders and identify and collaborate with these interested stakeholders in a transparent, inclusive and participatory planning process. The benefit of this regional planning is that leaders within each region, with the assistance of PA 2-1-1, will be able to decide how to best provide 2-1-1 service in their region. For example, one region may decide to have a single regional center that will combine both direct response to consumers and development and maintenance of the resource database, while another region may decide to have a lead agency share responsibility with another agency, with one handling consumer response and the other the database. Thus, each region will have the ability to choose what works best for them after extensive planning and discussion. However, each region, regardless of the model chosen to provide 2-1-1 service to its constituents, will be required to meet the same quality standards and expectations for service.
We find that UWP has shown good cause to grant its request that PA 2-1-1 be given the authority to administrate the implementation of the 2-1-1 abbreviated dialing code on a statewide basis. PA 2-1-1 has developed a business plan for the creation and administration of an information system that will be one of the most complete, accurate and inclusive available today. PA 2-1-1 proposes a 2-1-1 system that will have the ability: (1) to respond to callers' needs 24/7/365; (2) to respond quickly in a disaster situation; (3) to generate meaningful statistics on service availability and service gaps; (4) to provide for effective collaboration on behalf of clients; (5) to computerize the state and local community information databases; (6) to make available a directory of services in print or electronic format; (7) to refer to specialized information and referral agencies, as defined by the Alliance of Information and Referral Standards for Professional I&Rs; and (8) to make information in the database available by means of the Internet.
Based on the content of its Petition, we also note that PA 2-1-1 has investigated the most pertinent aspects of 2-1-1 implementation including organizational issues, system design models, management approaches, relationships between service providers, state bodies, telecommunications providers, technological issues and common obstacles faced by implementation groups and created workable solutions to address these issues.
As we stated previously, UWP served its petition on the prominent telephone companies because it felt that they would have a material interest in the petition since they likely would have to perform switch translations or other facilities work to implement 2-1-1 service as requested by UWP. We acknowledge, as mentioned previously, that the FCC's ruling left the details of 2-1-1 implementation up to the requesting I&R parties and the relevant geographical telecommunications providers. There are no Federal requirements and no mandated way to pay for 2-1-1. This presents a challenge; however, we agree with the FCC that a three-digit number is easier to remember and would be particularly useful for travelers moving across local boundaries.
While it is no longer necessary to petition State utility regulators for reservation of the abbreviated 2-1-1 dialing code for I&R purposes, we acknowledge that the support of State utility commissions can be very helpful in implementation of 2-1-1 service. The involvement by commissions can facilitate arrangements between telephone service providers and I&R providers. However, we take note of the comments of both the PTA and Verizon. Both stated that they successfully worked with the Department of Transportation in its implementation of 5-1-1 and with the Pennsylvania One Call System, Inc. in its implementation of 8-1-1. No Commission staff was designated to assist in the negotiations and interaction between the telephone carriers and the administrators of 5-1-1 and 8-1-1.
With this understanding, we do not believe that it is necessary to designate any Commission staff persons to assist and coordinate on an ongoing basis any arrangements between any affected jurisdictional local exchange carriers and PA 2-1-1. We simply direct that all jurisdictional local exchange carriers expeditiously perform all analyses required to quantify its costs for the necessary translations and/or facilities work if it plans to seek recovery of internal costs associated with enabling 2-1-1 call completion and estimate the time required to perform the necessary translations and/or facilities work to allow 2-1-1 call completion from its subscribers.
We believe that the provision of N11 service is relatively straight-forward. As has been noted by the PTA in its comments, in the previous instances of the implementation of 5-1-1 and 8-1-1 abbreviated dialing in Pennsylvania, the PTA companies simply submitted their cost estimates for the work associated with the translations. However, we are sure that there are technical issues that might have to be resolved between PA 2-1-1 and the telephone companies; therefore, we will not direct any technical specifications or protocols at this time. Rather, we encourage PA 2-1-1 to provide detailed information regarding its network and feature requirements so that the telephone companies can provide PA 2-1-1 with specific proposals.
UWP states that PA 2-1-1 anticipates that at least two regions will be ready to operate by February 2010. With this time frame, we will direct PA 2-1-1 to provide access expeditiously to a copy of its implementation plan for 2-1-1 in order to assist jurisdictional local exchange carriers in compiling the information necessary so that the 2-1-1 system can be implemented and established Statewide in a prompt manner in this Commonwealth. We also recognize that wireless callers and other alternate service providers will provide access to 2-1-1. Therefore, we encourage wireless carriers and other alternate service providers to coordinate and work with PA 2-1-1 in an expeditious manner as well regarding any implementation issues.
In conclusion, we find that the referral to community information and referral services by means of 2-1-1 will benefit the citizens of this Commonwealth by providing a simple, universal, easy-to-remember number to access this oftentimes critical information. Moreover, no party opposes the assignment of 2-1-1 to PA 2-1-1.; Therefore,
It is Ordered That:
1. The Petition of the United Way of Pennsylvania that PA 2-1-1 be Designated as the Leading Implementing Agency of the 2-1-1 Abbreviated Dialing Code for the Provision of Information and Referral Services in Pennsylvania is hereby granted in part and denied in part.
2. Within 20 days of the entry date of this Order, all jurisdictional local exchange carriers, if they have not done so already, shall immediately discontinue using the 2-1-1 abbreviated dialing code for purposes other than access to community information and referral services.
3. Within 30 days of the entry date of this Order, PA 2-1-1 shall provide all jurisdictional local exchange carriers with access to a copy of its implementation plan for 2-1-1 dialing.
4. Within 45 days of the entry date of this Order, all jurisdictional local exchange carriers that possess switches that would have to undergo re-programming shall perform all analyses required to quantify its costs for the necessary translations and/or facilities work if it plans to seek recovery of internal costs associated with 2-1-1 call completion and estimate the time required to perform the necessary translations and/or facilities work to allow 2-1-1 call completion from its subscribers and shall forward that information to PA 2-1-1.
5. All affected jurisdictional local exchange carriers shall comply with the implementation schedule established herein unless a petition for waiver is filed with the Commission pursuant to 52 Pa. Code § 5.41.
6. A copy of this Order shall be served on all jurisdictional local exchange carriers and the Pennsylvania Telephone Association.
7. A copy of this Order shall be published in the Pennsylvania Bulletin.
8. The Secretary's Bureau mark this matter closed.
JAMES J. McNULTY,
Secretary
[Pa.B. Doc. No. 10-423. Filed for public inspection March 5, 2010, 9:00 a.m.] _______
1 In the Matter of the Use of N11 Codes and Other Abbreviated Dialing Arrangements, CC Docket No. 92-105, Third Report and Order and Order on Reconsideration, 15 FCC Rcd 16753 (July 31, 2000).
2 Id.
3 Id.
4 Subsequent to the filing of this Petition, Bell Atlantic—Pennsylvania, Inc. changed its name to Verizon Pennsylvania, Inc.
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