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A. a.(1)(a) i) a)DocumentgPleadingHeader for Numbered Pleading PaperE!n    X X` hp x (#%'0*,.8135@8:xYLTWECYW!CP@mW[G]NNLWWxWRI(((<<(@E@E@,EE@hEEEE*<,EChCC:5<5xLLLLLL(LLLLLLCCLLtL11xxL//<mCWCL3[EWEG@GG5L8R@bTW:`RY[YEW(L[RRY@C[RR((LLLLYWLLLRRRY(E<5(x2* S #X~xP7qXP#   9Before the .FEDERAL COMMUNICATIONS COMMISSION S3Washington, D.C. 20554 In the Matter of %,hh3;) ` `  %,hh3;) ` `  %,hh3;)BCC Docket No. 9645 FederalState Joint Board onhh3;) Universal Service %,hh3;) ____________________________________) W6Reply Comments of  S X THE UNITED STATES CATHOLIC CONFERENCE, NATIONAL COALITION (# FOR THE HOMELESS, WASHINGTON LEGAL CLINIC FOR THE HOMELESS, AMERICAN WOMENS ROUNDTABLE, COMMUNITY TECHNOLOGY INSTITUTE, CONSUMER ACTION, FIFTH STREET CONNECTION, HEARTLAND ALLIANCE FOR HUMAN NEEDS AND RIGHTS, INTERSTATE MIGRANT EDUCATION COUNCIL, NATIONAL ASSOCIATION OF MIGRANT EDUCATORS, MARCIA ZASHIN, EDUCATION CONSULTANT TO CLEVELAND PUBLIC SCHOOLS AND PROJECT ACT, MIGRANT LEGAL  S ACTION PROGRAM, AND VERMONT MIGRANT EDUCATION PROGRAM  Of Counsel:` `  %,hh3;BAngela J. Campbell ` `  %,hh3;BIlene R. Penn ` `  %,hh3;BJohn Podesta ` `  %,hh3;BInstitute for Public Representation Jewell Elliott, Law Studenthh3;BGeorgetown University Law Center Georgetown University Law Center;B600 New Jersey Avenue, N.W. ` `  %,hh3;BWashington, D.C. 20001 ` `  %,hh3;B(202) 6629535 ` `  %,hh3;BKatherine Grincewich ` `  %,hh3;BOffice of the General Counsel ` `  %,hh3;BUnited States Catholic Conference ` `  %,hh3;B3211 4th Street, N.E. ` `  %,hh3;BWashington, D.C. 200171194 ` `  %,hh3;B(202) 5413300 May 7, 1996:&0*0*0*     Many important issues were raised by the Comments filed in this proceeding. However, Commenters have focused in these Reply Comments on the four criteria listed in Section 254 of the Telecommunications Act of 1996 ("the Act" or "Telecommunications Act") that the Joint Board and the FCC must  SH consider in identifying services that qualify for universal service support.H S ԍ As discussed in our original filing, Commenters agree with the NPRM's conclusion that the FCC need only consider each criteria, but it need not find that each service meets each of the four criteria to be eligible for universal service support. The FCC's finding is consistent with the plain language of the Act because the Act unambiguously states that in defining the services that are supported by Federal Universal support mechanisms, the Joint Board and the FCC "shall consider the extent to which such telecommunications services" meet the four criteria listed within. See Caminetti v. United States, 242 U.S. 485 (1916). Moreover, the FCC's interpretation is consistent with the other related provisions in the statute. Where the statute was passed to ensure the provision of basic services to "all Americans," exclusion of homeless persons and migrant farmworkers from the provision of basic communications services would subvert the intent of the Act. Finally, the legislative history further supports the FCC's interpretation. The conference report stated that the definition of universal service "should be based on a consideration of the four criteria set forth in the subsection." Conference Report at 131. In stating the FCC should base its determination on a "consideration of the four criteria," it is clear that Congress did not intend the FCC to prove that every service to be included with in universal service meets each of these criteria. Had Congress' intended each criteria to be met, it would have stated the FCC must find each service meets each of the criteria listed in Section 254.  In these Reply Comments, we show how the proposals in our original filing meet each of  S the Act's criteria.#X~xP7qXP#>  S3" ԍ As stated in Commenters' original Comments, Commenters support the implementation of increased access to public payphones. This issue will be addressed in a separate proceeding as required under Section 276(b)(2) of the Telecommunications Act. See Notice, at  57.>  0*((Ԍ S  I.XCOMMENTERS PROPOSALS MEET THE CRITERIA LISTED IN SECTION 254(c)(1)(AD) OF THE TELECOMMUNICATIONS ACT, AND THEREFORE,  S SHOULD BE AFFORDED UNIVERSAL SERVICE SUPPORT (# In identifying services eligible for universal support, Section 254(c)(1) of the Telecommunications Act requires the FCC to consider the extent to which services: 1) are essential to education, public health or public safety; 2) have been subscribed to by a substantial majority of residential customers; 3) are being deployed in public telecommunications networks; and 4) are consistent with the  S public interest, convenience, and necessity.O  S7 ԍ Telecommunications Act 254(c)(1)(AD).O In considering each of these factors, the services Commenters proposed in our original filing should receive universal  Sb service support because they comport with the Act.by S ԍ As stated in Commenters' original Comments, the recommendations offered do not endorse any finite set of particular services. See Comments of the United States Catholic Conference et al. at 3, filed April 12, 1996. Rather, Commenters' goal is to suggest services that will allow homeless persons and migrant farmworkers to have access to the telecommunications network. In the Commenters' original filing, increased internet access and long distance learning capabilities were also recommended as additional services to be supported by universal service funding mechanisms. See Comments of the United States Catholic Conference et al. at 1113 and 1920. Commenters continue to support these services and indorse the comments of the National School Board Association et al., at 56; Richard W. Riley, Secretary of Education, at 3 and 5; International Society for Technology in Education, at 7, and the Edgemont Neighborhood Coalition at 13, which address each of these issues. Furthermore, United States Catholic Conference et al. agree with other Commenters that the Lifeline and LinkUp programs should not only be retained, but strengthened and expanded. See, supra, note 15. Commenters believe the LinkUp program should be expanded to provide assistance for more than one initiation per residence per year. Providing a means to allow migrant workers and other low income consumers more than one initiation per year will increase their access to telecommunications services and will enable poor and highly mobile&0*(( groups to communicate with employers, medical and educational facilities, and family. Because the Joint BoardbK0*(( and Commission need only consider each criterion, even if a service does not meet all four criteria it could be included in the Commission's universal support mechanism. In that instance, the FCC should show that the criteria met by the service are so significant that they substantially outweigh the necessity of demonstrating that all of the criteria are met.  S  X A.X` ` Voice Mail Services For Homeless Persons and Migrant Farmworkers  S Should Receive Universal Support (#` Voice mail for homeless persons and migrant farmworkers clearly meets the first criterion, because as described in Commenters' original filing, it ensures that these groups can effectively communicate with prospective employers, family, and  SK social service, health care and other providers.OKK SG ԍ Telecommunications Act  254(c)(1)(A).O Effective communication with employers and service providers is essential to the education, public health and public safety of these constituencies. Voice mail for homeless persons and migrant farmworkers also meets the second criterion, since this service is subscribed to by a majority of residential  Se customers.Oe S" ԍ Telecommunications Act  254(c)(1)(B).O Because homeless persons do not have a home and migrant farmworkers are away from their home for a substantial portion of the year, they cannot rely on residential phone service to receive incoming calls and to make outgoing calls. Therefore, voice mail serves as a substitute for basic telephone0*(( service, which is widely subscribed to by over ninetyfour (94%) percent of all  S residential customers.c SK ԍ Jorge Reina Schement, Beyond Universal Service, May 1994 at 2.c Moreover, voice mail itself is also widely subscribed to by residential customers. In May 1995, Pacific Bell Information Services reported that in California, demand for residential and business voice mail was growing at thirty  SH five percent (35%) per year.PHy Sr ԍ Sidewire, Telecomworldwire, May 15, 1995. P As of March 1995, Bell Atlantic's Answer Call voice mail service, the largest in the country, reached 1.4 million residential  S customers.  * S ԍ Mike Mills, Montgomery to Get Phone Message Service; Bell Atlantic's Residential 'TMail' Experiment is First in Country, Wash. Post, Mar. 17, 1995 at F1. Other telephone companies have reported similar findings.   SJ ԍ  Tom Michele, Telephone Company keeps Stride With Progress, Rhinelander Daily News, Feb. 13, 1995, at A1 (reporting approximately 48% of Rhinelander Telephone Companies 1994 voice mail growth was from residential customers).  Voice mail for homeless persons and migrant farmworkers also meets the third criterion because it is widely deployed in the public telecommunications  Sb network.P b0  SC ԍ Telecommunications Act  254(c)(1)(BC).P A press account reported that in voice mail's infancy it was growing  S4 in sales by 50 percent a year.o 4  S ԍ Andrew Pollack, Company News, NYT, Aug. 20, 1988 at Section 1, p.1.o Surely, almost ten years later voice mail can be found throughout the telecommunications infrastructure. Providing universal support to subsidize homeless person and migrant farmworker acquisition of voice 0*((  S mail also meets the fourth criterion.O  Sy ԍ Telecommunications Act  254(c)(1)(D).O It clearly serves the public interest, convenience and necessity for persons who would otherwise lack access to the telecommunications network, by enabling them to receive and retrieve messages from schools, social service agencies, medical facilities and family, and thus  SH become fuller participants in society.#Hy Sr ԍ See Comments of the United States Catholic Conference et al., at 810 and 18 (access to voice mail for these groups has lead to increased opportunities for obtaining jobs and housing.) See also, discussion supra, at 6.# Finally, Commenters believe that anyone who provides voice mail to these constituencies should be eligible for universal service support, and that the fund should not be limited to local telephone service providers.  S X B.X` ` Subsidized Telephone Initiation and Low Access Rates for NonProfit  Sy Organizations That Serve Homeless Persons and Migrant Farmworkers  Sb Should Receive Universal Service Support (#` In addition to voice mail, subsidizing telephone initiation costs and providing low telephone rates for nonprofit organizations that serve homeless persons and migrant farmworkers should be included in the universal service support mechanism since it meets all the criteria of Section 254(c)(1) and is another means of ensuring these groups have access to basic services. Many Commenters supported the retention of the FCC's Lifeline and LinkUp programs which ensure low income persons can both initiate telephone service through a subsidized 0*((  S initiation fee and maintain telephone service through a subsidized rate.  Sy ԍ See, Comments of NYNEX, at 16 (Lifeline and Link up should be expanded and/or restructured to carry out the purposes of Section 254), Bell Atlantic, at 6 (many low income consumers would be off the network without targeted programs such as Lifeline and Linkup and therefore these programs should be retained), BellSouth, at 13 (low income consumers can have access to telephone service through continuation of the Lifeline and Linkup programs), USTA, at 23 (these programs should be continued and expanded), US West, at 7 (US West has long supported and continues to support current Lifeline and Linkup programs) Southwestern Bell,at 67 (expanding Lifeline as well as Link up will be vital for those households that cannot pay the affordable price of universal service). We support these commenters' views to the extent they believe Linkup and Lifeline should be retained and/or expanded to ensure access by low income customers. These programs, however, do not meet the needs of persons without a home or those who are away from their residence for a substantial portion of the year. This disparity can be ameliorated by providing initiation and service rate subsidies, akin to those offered low income persons through Lifeline and LinkUp, to the nonprofit advocacy organizations that support the basic needs of these constituencies. Such subsidies would, in effect, improve access by these constituencies to both basic and advanced communications services. By way of example, many homeless shelters have a limited number of phones to support a large number of clients. Not only are many shelters unable to provide their clients with basic services, but they lack the wiring and affordable rates to offer more advanced services such as internet and other integrated computer networks. Subsidized phone installation will increase the number of lines a shelter can afford, thereby increasing the number of services it can provide. And reduced telephone rates will permit the shelter to maintain additional phone lines|| 0*(( once they are installed. Additional phone lines can be used by shelters to increase homeless persons' access to phones, as well as opportunities to access the internet and other integrated computer networks. As described in Commenters' original filing, access to basic phone and advanced communications services has profound effects on improving shelter service to clients. It also increases homeless persons' and migrant farmworkers' ability to communicate with employers, landlords, government officials, educational and medical facilities, emergency  S services and family members.y  S7 ԍ See, Comments of the United States Catholic Conference, et al., at 813.y Increased access to these persons results in increased employment, housing and other opportunities and therefore meets the first criterion that service be essential to education, public health or public  S4 safety.N4y S^ ԍ Telecommunications Act  254(c)(1)(A).N As discussed supra, basic phone service is initiated by and subscribed to by  S a majority of residential customers.d* S ԍ Jorge Reina Schement, Beyond Universal Service, May 1994 at 2.d It is certainly deployed in the telecommunications network by telecommunications carriers, and therefore meets  S| the second and third criteria.P| S! ԍ Telecommunications Act  254(c)(1)(BC).P Furthermore, providing universal support for subsidized phone initiation and affordable rates to nonprofit organizations meets  S  the fourth criteria and is consistent with the public interest because in the same way low income residential subscribers have access to subsidized phone initiations0*(( and service for their health, safety and welfare, nonprofit organizations that serve those persons who have no residence or are away from their residence a substantial part of the year, should also have subsidized lines to better serve their  Sv clients.Ov S ԍ Telecommunications Act  254(c)(1)(D).O In addition, providing subsidies to nonprofit organizations is an efficient and cost effective way for these two groups to gain access to telecommunications services since these organizations are already in existence and have mechanisms in place to serve these constituencies.  S X C.X` ` The Universal Service Support Fund Should Subsidize Toll Free  S Numbers for NonProfit Organizations That Service Homeless Persons  S and Migrant Farmworkers (#` Furthermore, the criteria of Section 254(c)(1) are also met by subsidizing toll free numbers for nonprofit organizations which serve the needs of homeless persons and migrant farmworkers. Subsidizing nonprofit advocacy organizations' acquisition of toll free numbers would enable homeless persons and migrant farmworkers to make calls to such organizations to obtain information regarding shelter availability, healthcare and legal advice, and other essential education,  SN public health and safety services and therefore satisfies the first criterion.NNy Sx ԍ Telecommunications Act  254(c)(1)(A).N (#(#o Toll free number hotlines enable farmworkers to make toll free calls to receive information on healthcare and educational programs that are available to them in the area in which they are currently working. Migrant farmworkers traveling on the road would otherwise be prohibited by cost from making calls to" *0*((  S check on benefits, legal advice and health care issues.vH Sy ԍ The Eastern Stream Center on Residence and Training (ESCORT) has recently been awarded a contract to establish a national coordination center in which a national toll free number is available for migrant farmworkers. Calls which are received on the toll free line are automatically routed to the nearest source center which then refers the caller to the necessary social service provider. This service allows migrant farmworkers to communicate with service providers regardless of where the migrant farmworker is located using a single number. Interview with Phillip Kellerman, May 7, 1996.v Toll free number hotlines also permit homeless persons to call local social service providers when they are out of money. Subsidizing acquisition of these services to nonprofit organizations will make these organizations more accessible to the people they serve, whether those people reside across the country or across town. Furthermore, toll free numbers may also be used by homeless persons and migrant farmworkers to call into their voice mail. In our original filing, Commenters described how several current voice mail programs utilize toll free numbers to  S access voice mail.} S ԍ See Comments of the United States Catholic Conference et al., at 89.}  Toll free numbers are widely subscribed to by residential customers and  S4 therefore comply with the second criterion of  254(c)(1).N4 + Sn ԍ Telecommunications Act  254(c)(1)(B).N The United States has seen an unprecedented demand for toll free numbers which has been in part attributed to the growth in the use of "personal 800 numbers to residential  S customers.": + S% ԍ According to David Rogers of BellSouth Telecommunications and as reported in Bellsouth ready To Offer TollFree 888 Numbers, PR Newswire, Feb. 28, 1996 at Financial News.  CoChairman of the Industry Numbering Committee, Dennis Byrne, 0*(( observes, "[w]ith 7.6 million 800 numbers, you can have one for every business with no problem, so what's really done it is all the residential 800 numbers . . . [i]n 26 years, we used 2 million 800 numbers, but in less than 1 1/2 years, we've  Sv used up another 5 million."v+ S ԍ Elizabeth Douglas, Number CRUNCH High Demand Forces Rationing of TollFree Phone Lines, San Diego UnionTribune, June 25, 1995 at I1. Toll free numbers have gained in popularity so much so that the FCC has run out of 800 numbers and has had to begin to issue  S 888 numbers.H b+ S- ԍ Toll Free Service Access Code, 10 FCC Rcd. 13692, Notice of Proposed Rule Making, CC Dkt. No. 95155, (adopted and released January 25, 1996). (The FCC pointed out that toll free telephone numbers were increasingly being used to meet consumers' personal needs. One example cited was that parents can give their toll free number to a child away at college, enabling that child to call home free of charge at any time. Due to pace at which these numbers are being used by consumers, the danger existed that 800 toll free numbers could be depleted before an additional toll free code could be introduced.)  The use of the these numbers is also widely deployed in the  S telecommunications network, and therefore, satisfies the third criterion.N r + S ԍ Telecommunications Act  254(c)(1)(C).N Furthermore, subsidized access to these numbers meets the fourth criterion since it serves the public interest by making service providers more accessible to migrant farmworkers and homeless persons who could otherwise not afford to call them because of the prohibitive cost of a toll or local call.  S  CONCLUSION  S  Because the proposals recommended by Commenters meet all four of the criteria listed in  254(c)(1) of the Telecommunications Act of 1996, they should be included in the services that receive universal service support.| # 0*((Ԍ#X~xP7qXP#Й` `  %,hh3;BRespectfully submitted, ` `  %,hh3;B______________________________ ` `  %,hh3;BAngela J. Campbell Of Counsel:` `  %,hh3;BIlene R. Penn ` `  %,hh3;BJohn Podesta ` `  %,hh3;BInstitute for Public Representation Jewell Elliott %,hh3;BGeorgetown University Law Center Law Student, Georgetown University;B600 New Jersey Avenue, N.W. ` `  %,hh3;BWashington, D.C. 20001 ` `  %,hh3;B(202) 6629535 ` `  %,hh3;BKatherine Grincewich ` `  %,hh3;BOffice of the General Counsel ` `  %,hh3;BUnited States Catholic Conference ` `  %,hh3;B3211 4th Street, N.E. ` `  %,hh3;BWashington, D.C. 200171194 ` `  %,hh3;B(202) 5413300 May 7, 1996  0*((  S 3 CERTIFICATE OF SERVICEă   S  I, Ilene R. Penn, hereby certify that I have this 7th day of May, 1996, mailed by first class United States mail, postage prepaid, copies of the foregoing Reply Comments of the United States Catholic Conference et al. in the matter of "FederalState Joint Board on Universal Service," CC Docket No. 9645 to the following: (#҇ * The Honorable Reed E. Hundt Chairman FCC 1919 M Street, N.W. Room 814 Washington, D.C. 20554 * The Honorable Rachelle Chong Commissioner FCC 1919 M Street, N.W. Room 844 Washington, D.C. 20554 * The Honorable Susan Ness Commissioner FCC 1919 M Street, N.W. Room 832 Washington, D.C. 20554 The Honorable Julia Johnson, Commissioner Florida Pub. Service Commission Capital Circle Office Center 2540 Shumard Oak Blvd. Tallahassee, FL 323990850 The Honorable Kenneth McClure Vice Chairman Missouri Public Service Commission 301 W. High Street, Ste.530 Jefferson City, MO 65102 The Honorable Sharon L. Nelson Chairman Washington Utilities and Transportation Commission P.O. Box 47250 Olympia, WA 985047250 * Hand saved ( 0*0*0*Ԍ The Honorable Laska Schoenfelder Commissioner South Dakota Public Utilities Commission 500 E. Capital Avenue Pierre, SD 57501 Martha S. Hogerty Pub. Counsel State of Missouri P.O. Box 7800 Harry S. Truman Bldg. Room 250 Jefferson City, MO 65102 Deborah Dupont, Federal Staff Chair FCC 2000 L Street, N.W., Ste.257 Washington, D.C. 20036 Paul E. Pederson, State Staff Chair Missouri Pub. Serv. Comm. P.O. Box 360 Truman State Office Building Jefferson City, MO 65102 Eileen Benner Idaho Public Utilities Commission P.O.Box 83720 Boise, ID 837200074 Charles Bolle South Dakota Public Utilities Commission State Capital, 500 E. Capital Avenue Pierre, SD 575015070 8( 0*0*0*) &_ &0*0*8ԌWilliam Howden Federal Communications Commission 2000 L Street, N.W., Ste.812 Washington, D.C. 20036 Lorraine Kenyon Alaska Public Utilities Commission 1016 West Sixth Avenue, Ste.400 Anchorage, AK 99501 Debra M. Kriete Pennsylvania Public Utilities Commission P.O. Box 3265 Harrisburg, PA 171053265 Clara Kuehn Federal Communications Commission 2000 L Street, N.W., Ste.257 Washington, D.C. 20036 Mark Long Florida Public Service Commission 2540 Shumard Oak Blvd. Gerald Gunter Building Tallahassee, FL 323990850 Samuel Loudenslager Arkansas Public Service Commission P.O. Box 400 Little Rock, AR 722030400 Sandra Makeeff Iowa Utilities Board Lucas State Office Building Des Moines, IA 50319 Philip F. McClelland Pennsylvania Office of Consumer Advocate 1425 Strawberry Square Harrisburg, PA 17120 (0*0*0*ԌMichael A. McRae D.C. Office of the People's Counsel 1133 15th Street, N.W., Ste.500 Washington, D.C. 20005 Rafi Mohammed Federal Communications Commission 2000 L Street, N.W., Ste.812 Washington, D.C. 20036 Terry Monroe New York Public Service Commission Three Empire Plaza Albany, NY 12223 Andrew Mulitz Federal Communications Commission 2000 L Street, N.W., Ste.257 Washington, D.C. 20036 Mark Nadel Federal Communications Commission 1919 M Street, N.W., Rm. 542 Washington, D.C. 20554 Gary Oddi Federal Communications Commission 2000 L Street, N.W., Ste.257 Washington, D.C. 20036 Teresa Pitts Washington Utilities and Transportation Commission P.O. Box 47250 Olympia, WA 985047250 Jeanine Poltronieri Federal Communications8#'0*(()US(((8ԌCommission 2000 L Street, N.W., Ste.257 Washington, D.C. 20036 James Bradford Ramsay National Association of Regulatory Utility Commissioners 1201 Constitution Avenue, N.W. Washington, D.C. 20423 Jonathan Reel Federal Communications Commission 2000 L Street, N.W., Ste.257 Washington, D.C. 20036 Brian Roberts California Public Utilities Commission 505 Van Ness Avenue San Francisco, CA 941023298 ` `  %,hh3; Gary Seigel Federal Communications Commission %,hh3; 2000 L Street, N.W., Ste.812 Washington, D.C. 20036 Pamela Szymczak Federal Communications Commission 2000 L Street, N.W., Ste.257 Washington, D.C. 20036 Whiting Thayer Federal Communications Commission 2000 L Street, N.W., Ste.812 Washington, D.C. 20036"0*0*0* Deborah S. Waldbaum Colorado Office of Consumer Counsel 1580 Logan Street, Ste.610 Denver, Colorado 80203 Alex Belinfante Federal Communications Commission 1919 M Street, N.W. Washington, D.C. 20554 Larry Povich Federal Communications Commission 1919 M Street, N.W. Washington, D.C. 20554 *International Transcription Service 1919 M St., N.W., Ste.640 Washington, D.C. 20036 * Ernestine Creech (disk) Common Carrier Bureau Accounting and Audits Division 2000 L Street, N.W., Ste.257 Washington, D.C. 205548|0*((#}sW((8ԯ ` `  %,hh3;B  ` `  %,hh3;BppJIlene R. Penn #'0*((Ԍ