20160427Application.pdf

DONALD L. HOWELL,II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, tD 83720-0074
Idaho Bar No. 3366
Tele: [phone]
Fax: [phone]
E-mail : don.howell@puc. idaho. gov
Attorney for Commission Staff
IN THE MATTER OF THE APPLICATION
OF THE COMMISSION STAFF FOR AN
ORDER APPROVING THE DISPOSITION
OF TIER 2 FUNDS FROM THE QWEST
ERFORMANCE ASSURANCE PLAN (QPAP
oR PLAN)
RECE IVED
?CI6 erR 27 Plt 2: 23
-.!,ht I^I I 1. ! t: , i.i, LlrLlrr' :' ': iii,il'ti$SICN
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSTON
CASE NO. GNR-T.16.04
APPLICATION OF THE
COMMISSION STAFF
The Commission Staff files this Application requesting that the Commission
authorize the disbursement of the remaining balance of Tier 2 funds under the Qwest
Performance Assurance Plan (QPAP) to fund two telecommunication projects: (l) an expansion
of the Idaho Suicide Prevention Hotline administered by the Idaho Department of Health &
Welfare, Division of Behavioral Health; and (2) the development of standardized training and
certification for 911 dispatchers by the Idaho Emergency Communications Commission, through
the Idaho Peace Officer Standards & Training (POST) Academy. Staff proposes that remaining
balance of the QPAP fund in the amount of $89,710 be equally distributed to these two projects.
Staff recommends that this Application be processed under Modified Procedure
pursuant to Rule 201, et seq., and requests that written comments regarding the Application be
filed within 21 days.
BACKGROUND
Section 271 of the federal Telecommunications Act of 1996 established procedures
for Centurylink's predecessor Qwest Corporation (commonly referred to as a Bell Operating
Company (BOC)) to obtain authorization from the Federal Communications Commission (FCC)
APPLICATION OF
COMMISSION STAFF I
to provide in-region interLATA and interstate telecommunications services. 47 U.S.C. $ 271. In
particular, Section 271(c)(2)(B) contained a "competitive checklist" that generally provided that
Qwest and other BOCs must provide access and interconnection to competitors. Before allowing
Qwest to offer telecommunications services in its region, the FCC was also required to find that
allowing Qwest to compete in its region against competitors "is consistent with the public
interest, convenience and necessity." 47 U.S.C. $ 271(dX3XC). To ensure continued
compliance with the competitive checklist, the FCC determined that applicable carriers should
develop and implement a "Performance Assurance Plan" (PAP). As this Commission noted in
February 2003, "Qwest's PAP provides specific standards for [Qwest's] delivery of services to
competitor telecommunications providers and automatic penalties if the standards are not met."
Notice of Modified Procedure (Case No. USW-T-00-03).
Qwest's PAP (QPAP) was intended to provide economic incentives for Qwest to
provide non-discriminatory service to competitive local exchange carriers (CLECs). Order No.
32106 at 1. In the event Qwest failed to meet the performance standards set out in its QPAP, the
Plan required that Qwest make remedial payments to either the CLECs or to a Fund established
by the state regulatory commission. These payments were divided into two self-executing types.
First, Tier 1 payments were made to a particular CLEC if Qwest did not meet the service
standards when providing service or access to that CLEC. QPAP $ 2.1. Second, if Qwest failed
to meet certain other service standards that did not directly impact a particular CLEC, Qwest was
required to make Tier 2 payments to accounts established by the state commission. QPAP $
2.1.1; Order No. 30461 at 3.
Tier 2 payments were made to one of two accounts. The Tier 2 "special fund" was
used to defray audit and oversight expenses incurred by this Commission in reviewing Qwest's
Section 271 compliance. The Tier 2 "discretionary fund" was comprised of remedial and
intended to be used for o'competitively neutral Idaho telecommunications initiatives." QPAP $
I l.3.4. Payments to the Trer 2 accounts were discontinued in November 2010. Order No. 32106
at2-3. The current balance of the consolidated Tier 2 accounts is $89,710.56 as of April1,2016.
Given the discontinuance of Tier 2 payments, there is no longer a need to retain these funds.
Consequently, Staff believes it is now appropriate to disburse the funds to the two
telecommunications programs identified in greater detail below.
APPLICATION OF
COMMISSION STAFF
APPLICATION
Staff recommends that the Commission equally distribute the balance of the Tier 2
QPAP funds to the two programs set out in greater detail below. The first program would
expand the operations of the Idaho Suicide Prevention Hotline administered by the Department
of Health & Welfare, Division of Behavioral Health. The second program would provide initial
funding for the development of certification standards and training at the Idaho Police Officer
Standards & Training (POST) Academy for emergency dispatchers assigned to 911 calling
centers.
A. Idaho Suicide Prevention Hotline
The Idaho Department of Health & Welfare, Division of Behavioral Health,
administers the Idaho Suicide Prevention Hotline. According to statistics from the Suicide
Prevention Action Network of Idaho, suicide is the second leading cause of death for Idahoans
age 15-34.1 In a report issued this month by the Centers for Disease Control and Prevention
(CDC), the National Center for Health Statistics reported that deaths from suicide increased from
1996 to 2014 by 24oh, from 10.5 to 13.0 per 100,000 population.2 The average annual
percentage increase in suicide mortality shows that the average increase was greater for the
period 2006-2014 than for the period 1999-2006. Increases in suicide rates occurred for both
males and females in all age groups except 75 years and older. The increase for females was
greatest for those ages l0-14, and for males between 45-64 years old. 1d
The Department of Health & Welfare has identified four special at-risk groups in
Idaho. The first of these at-risk groups for suicide is male teenagers between the ages of 15 and
17 years old.3 According to a recent survey, one in seven Idaho high school students said they
had seriously considered suicide.a According to the Idaho Suicide Prevention Hotline, "Idaho's
t http://healthandwelfare.idaho.gov/Portals/0/Medical/Suicide%20Prevention/August20l5SuicideFactSheet.pdf (last
viewed April2l,20l6).
2 Increase in Suicide in the United States, I 999-201 4, NCHS Data Brief No. 241 ,
http://www.cdc.gov/nchs/productsidatabriefs/db24l.htnr(lastviewed April22,20l6).
3 The other three special at-risk groups are Native American males, l5-24 years old; working age males, between the
ages of l8-64; and elderly men, age 75 and older.
http://healthandwelfare.idaho.gov/Families/SuicidePrevention/SpecialAtRiskPopulationsinldaho/tabid/1923/Default.
aspx (last viewed April2l ,2016).
a http:i/www.spanidaho.ors/ldaho-suicide-facts (last viewed April22,20l6).
APPLICATION OF
COMMISSION STAFF
overall suicide rate is 52%higher than the national average and the youth[s] age 10-19 is double
the national average." Exh. 1 , p.2.
To address this priority at-risk group, the Suicide Prevention Hotline proposes to
launch a new service called "Texts for Life" to reach people who are more comfortable texting or
using an on-line chat service. While this new service will be available to all Idaho residents, "the
focus is on increasing support for youth and other groups who favor these technologies, such as
veterans." 1d Funds from the QPAP program will improve the technological/telecommunications
capacity to handle several thousand text messages as well as chats and calls from those in crisis.
The Division of Behavioral Health has proposed utilizing approximately $44,900 of
QPAP funds to improve their telecommunications capacity. Id. In particular, the Division
proposes to use the money to procure the following equipment and facilities:
l. $18,000 to build and equip six additional workstations with telephones,
computers, power-jack wiring.
2. $6,000 to improve acoustic dampening between and among the existing
responder workstations and the new workstations.
3. $4,000 for two LED wall displays showing the waiting queue for calls and
texts.
4. $4,000 for ICAROL IT software to provide crisis texts & chat
functionality and voice-call management for one year.
5. $5,000 for access and security systems.
6. $7,900 for office supplies, other equipment, and administrative
management.
The Division asserts that this added functionality will improve efforts to prevent suicides by
effective intervention.
B. Idaho Emergency Communications Training Standards
The Idaho Emergency Communications Commission (IECC)s proposes to utilize
$44,910 of QPAP funding to develop employment and training standards, including certification
and recertification requirements, for emergency dispatchers located at public safety call centers
(911 centers). Exh. 2.
5 Effective July 1, 2016,the functions of the IECC and the Statewide Interoperability Executive Council (SIEC) are
to be consolidated into the Idaho Public Safety Communications Commission. See ldaho Code $ 3 I -48 I 5.
APPLICATION OF
COMMISSION STAFF 4
The Police Officer Standards &, Training (POST) Academy has a voluntary
dispatcher training program but desires to develop the necessary training standards for
employment, training, and certification of emergency dispatchers. Exh. 2. The IECC estimates
the funds necessary to fully develop this mandatory certification program is about $10,000 per
year. Utilizing available QPAP funds would provide the necessary funding for approximately
four years while other funding solutions are identif,red. Exh. 2 at p. 2. Funds would be
transferred to the IECC and eventually to the POST Academy.
Staff believes that the available QPAP funds can be put to good use by funding these
two programs. Staffs request to fund these programs is competitively and technologically
neutral, and in the public interest. Accordingly, Staff recommends that the Commission disburse
the funds to the Idaho Department of Health & Welfare, Division of Behavioral Services and to
the IECC, Post Academy, which will administer these funds. Use of the Tier 2 QPAP funds to
support these innovative projects will serve Idaho citizens.
MODIFIED PROCEDURE
Staff believes that a technical hearing is not necessary to consider the disbursement of
Tier 2 QPAP funds and respectfully requests that this Application be processed under Modified
Procedure; i.e., by written submissions rather than by hearing. Rule 201 et seq. If the
Commission determines that a technical hearing is required, then Staff stands ready to present
testimony including support from the Idaho Suicide Prevention Hotline and the Idaho Emergency
Communications Commission.
COMMUNICATIONS AND SERVICE
Communications regarding this Application should be sent to the following:
Donald L. Howell,II
Deputy Attorney General
Idaho Public Utilities Commission
PO Box 83720
Boise, ID 83720-0074
E-mail : [e-mail]. gov
Carolee Hall
Telecommunications Specialist
Idaho Public Utilities Commission
PO Box 83720
Boise, ID 83720-0074
E-mail: [e-mail]
472W. Washington Street (83702-5918) 472W. Washington Street (83702-5918)
APPLICATION OF
COMMISSION STAFF
REQI'EST FOR RELIEF
Staff respectfully requests that the Commission issue an Order authorizing the
disbursal of Tier 2 QPAP funds in the amount of $89,710 to the two programs as described
above in greater detail.
Respecttully submitte d$is ZT
blVN:GNR-T-16-04_don
APPLICATION OF
COMMISSION STAFF
of April2016.
Deputy Attorney General
IDAHO DEPARTMENT OF
HEAI,TH &WE,LFARE
C. L.'BUTCH'OTTER - Govemor
RICHARD M. ARMSTRONG - Director
ROSS EDMUNDS- Administrator
DIVISION OF BEHAVIOML HEALTH
450 West State Sfeet, 3rd Floor
P.O. Box 83720
Boise, ldaho 8372G0036
PHONE [phone]
DATE
Carolee Hall, Utility Analyst
ldaho Public Utilities Commission
Address
P.O. Box
Boise, lD
Dear Ms. Hall,
The Division of Behavioral would like to thank the ldaho Public Utilities Commission for their
generous donation in support of the ldaho Suicide Prevention Hotline. ln keeping with the
intention of the donation, the Division intends to use the funding for the following:
r Additional responder stations
' lmplementation of Crisis Text & Chat Response program
I Support full capacity operation of Suicide Hotline services
lf you have further questions, please contact Treena Clark, Program Manager, Division of
Behavioral Health at 334-6611
EXHIBIT 1
Case No. GNR-T-16-04
I ki. t l-r'r
5ui:irle
Picl e niior.:
Hr:tiino,
t -'ti L't B - 2 7 3 -T A L l{ ( I 2 s 5 )
T,JANNUS
Twice as many ldaho youth die from suicide than US average
lf you are a young person in ldaho there are a couple of different ways you might die. Most people would
guess the most common way is in an accident, but shockingly, the second most common way for you to die is
for you to kill yourself. ln a recent survey, one in seven ldaho high school students said they have seriously
considered suicide. Between 2010 and 2074,96ldaho children, age 18 or younger, died by suicide; many
more, perhaps as high as 25 times as many, attempted suicide. ldaho's overall suicide rate is 52% higher than
the national average and the rate for youth age 10-19 is double the national average. Yet research shows that
with effective interventions, suicides can be prevented.
ln early 2016, in partnership with the Public Utilities Commission, the ldaho Suicide Prevention Hotline will
take a major step to help young people throughout the state who are in crisis. ISPH will launch a new service
called Texts for Life (working title) so we can reach people who are more comfortable texting or using an
online chat service. While this service will be available to everyone, the focus is on increasing support for
youth and other groups who favor these technologies, such as veterans. With additional funding we can build
our technological capacity to handle an anticipated several thousand text messages as well as chats and
increased calls from youth in crisis.
r 6 additional work/responder stations at S3000 per to include telephones, computers, cubicles,
computer and power jack wiring & dual monitors: 518,000
. lmproved acoustical dampening between existing and new responder stations: 56,000
o Jannus federally approved indirect rate of 13.6%: 55,106
o 2 Smart LED wall displays for queue monitoring, installed, 50 inch or greater: 54,000
o lcarol lT subscription- provides crisis text & chat functionality & voice call management for one year:
s4,000
. Upgraded controlled access & security system for call center: 55,000
r New commercial grade front door & installation: S1,100
o Additional office supplies: $694.
Total: S44,900
*i
March 29,2016
Carolee Hall
Idaho Public Utilities Commission
P.O. Box 83720
Boise, lD 83720-0074
Dear Ms. Hall:
It was a pleasure speaking with you this afternoon. As I explained,I am a commissioner on the
Idaho Emergency Communications Commission (IECC) and as a result, I chair their PSAP
Standards & Training Sub-Committee. The following is pulled directly from the PSAP
Committee by-laws: "The purpose of the PSAP Committee is to assist the IECC in accomplishing
their Goals, Strategies, and Outcomes of their adopted Strategic Plan, which includes, but is not
limited to:
. Developing an onnual work planfor approval by the IECC.. Identfying options and methods for public safety dispatcher certification and re-
certification in ldaho.. Identfying minimum training standards and model of credentialing process for public
safety dispatchers within the State of ldaho.. Assisting in the identification of the issues and opportunities with emerging
technologies.. Assisting the IECC withfulfilling its mission statement by identifuing professional
development opportunities and training. "
The third bullet point is the Committee's biggest task. There are approximately 34 states that
mandate minimum hiring and training certification standards for emergency dispatchers, with 5
additional states pending. Idaho is one of the states where it is not mandated. APCO
(Association of Public Safety Communications Officials) International's PToCHRT (Professional
Communications Human Resource Taskforce) Core Principles Manifesto states "every state
mandate and/or adopt standard criterion for 9-1-l public safety call taker and dispatcher training,
using APCO ANS 3.103.1-2010: Minimum Training Standards for Public Safety
Telecommunicators as a baseline, accredited by American National Standards Institute (ANSI),
for certification and re-certification to maintain the highest level of knowledge, skill and ability."
Obviously, ensuring there are mandated hiring and training standards, with a certification and
recertification requirement, is critically important to ensuring a safer, more effective and
professional emergency dispatch system. On September 4,2014, the IECC met in Lewiston and
during the meeting, I brought up the mandatory dispatcher certification/re-certification issue and
asked the IECC to either reaffirm their position on it, or remove it from our by-Iaws. The IECC
voted unanimously to continue to stand in support of Idaho requiring certificatiorVre-
certification, including minimum hiring and training standards of its public safety dispatchers.
It is remarkable that Idaho requires certification of nail technicians, hairdressers, food service
workers, and many more, but our state's public safety communications professionals are not
EXHIBIT 2
Case No. GNR-T-16-04
required to complete and maintain any formal training, receive a certification, or meet a
minimum hiring standard.
The Idaho Peace Officer Standards & Training (POST) academy does have a dispatch academy
and certification, but it is voluntary. The PSAP Committee has worked very hard, with the
support of the IECC, Idaho Sheriff s Association, Idaho Chiefs of Police Association, Idaho
Association of Counties, Idaho Association of Cities, and other stakeholders, and we believe we
have built a great proposal. We anticipate the proposal moving before the 2017 legislative
session and have several legislators prepared to move this issue forward.
The PSAP Committee proposal can be viewed at:
http ://bhs. idaho. gov/Pages/ECC/PsapBusiness. aspx
The PSAP Committee consists of hard-working, dedicated professionals from agencies all over
Idaho and I cannot overstate their passion and drive to represent both their profession and its
needs in as balanced a way as they can.
The incurred costs to POST for the administration of this proposed mandate is estimated to be
just shy of $10,000 per year. The $10,000 is for the processing of certification applications,
auditing traininglhiring records, and potential decertification issues. Without a funding source
for these costs, POST is likely to oppose the legislation. While we recognize this needs to be an
ongoing $10,000 for each year, your contribution of the remaining $44,910 would assure funding
for at least 4 years while another solution is identified. I presume the funding would funnel
through the IECC, then on to POST, but perhaps we can clarify how this would need to occur if
the monies can be awarded. Thank you for your consideration of this noble and worthy project.
Sincerely,
Lt. Kevin Haight
ISP Statewide Communications
Idaho Emergency Communications Commissioner
Idaho PSAP Standards & Training Committee - Chairman
700 S. Stratford Dr.
Meridian, ID.83642
I HEREBY CERTIFY THAT
THE FOREGOING APPLICATION
NO. GNR-T-I6-04, BY MAILING A
FOLLOWING:
LISA A ANDERL
ASSOC GENERAL COUNSEL
CENTURYLINK
1600 7rH AVE ROOM 1506
SEATTLE WA 98I9I
IDAHO PEACE OFFICER
STANDARDS & TRAINING
7OO S. STRATFORD DR
MERIDIAN ID 8364I
CERTIFICATE OF SERVICE
I HAVE THIS 27th DAY OF APRIL 2016, SERVED
OF THE COMMISSION STAFF', IN CASE
COPY THEREOF, POSTAGE PREPAID, TO THE
DEPARTMENT OF HEALTH & WELFARE
DIVISION OF BEHAVIORAL HEALTH
450 W STATE STREET, 3RD FLOOR
BOrSE rD 83720-0036
SECRETARY
CERTIFICATE OF SERVICE