William F. Caton, Acting Secretary
Federal Communications Commission
Washington, DC 20554
RE: Notice of Ex Parte Presentation in a Non-Restricted Proceeding
In re Federal-State Joint Board on Universal Service Recommended Decision
CC Docket No. 96-45
Dear Mr. Caton:
Pursuant to Section 1.1206 of the Commission's Rules, the California Small Business Association and the Office of Advocacy, U.S. Small Business Administration (SBA), submit an original and one copy of this Ex Parte notification. To the extent that a waiver is necessary for the one-day filing requirement, we request the Commission's approval of this late filing.
Betty Jo Toccoli, President of the California Small Business Association (CSBA) and S. Jenell Trigg, Assistant Advocate for the Office of Advocacy, U.S. Small Business Administration met with the Federal Communications Commission to discuss the impact of the Federal-State Joint Board on Universal Service Recommended Decision on small businesses.
S. Jenell Trigg and Betty Jo Toccoli met with the following people on March 19, 1997:
Kathy Levitz, Deputy Bureau Chief, Common Carrier Bureau
Tim Peterson, Legal Advisor to the Bureau Chief, Common Carrier
Bureau
Catherine J.K. Sandoval, Director, Office of Communications
Business Opportunities
Jim Casserly, Senior Legal Advisor to Commissioner Susan Ness
Ms. Toccoli met with the following people on March 20, 1997:
Jim Colthorp, Special Advisor to Commissioner James Quello
Dan Gonzales, Legal Advisor to Commissioner Rachelle B. Chong
All comments, except the following, have been addressed in previous comment filings on the record from the SBA and/or in the March 10, 1997, letter to Chairman Reed Hundt from the CSBA. Specifically, Ms. Toccoli and Ms. Trigg voiced their concerns about the Joint Board recommendation that limits universal service fund support to only single lines for both businesses and residents in high cost areas. This recommendation has a severe and direct economic effect on the welfare of small businesses and the communities in which they serve. The limitation of only one line for businesses is detrimental to small businesses who are unable to afford or absorb the increase. Furthermore, the limitation on single residential lines also significantly affects small businesses; a direct impact on small telecommunications carriers who may lose customers or business upon an increase of monthly rates, and indirectly on other small businesses in the area that may be economically affected by the likely increase in the cost of living of their customers at large.
Ms. Toccoli and Ms. Trigg discussed the results of CSBA's survey of small businesses in California that indicated that if rates were to increase, small businesses would likely eliminate lines or possibly, eliminate work force. (This survey is also on the record as an attachment to CSBA's letter to Chairman Hundt.) This survey is being replicated on a national scale and the results are expected in the immediate future.
Ms. Toccoli recommended, that if it were necessary to restrict the number of subsidized lines to either residents or small businesses in high cost areas, small businesses should receive full universal service support for a minimum of 4-5 lines and residents a minimum of two lines. This will allow small businesses to have adequate lines for voice communications for the purpose of customer inquiries/service and business operations (including credit-card approval), a dedicated fax, and a dedicated computer line. Residents will have support for one voice line and one computer line.
Very truly yours,
S. Jenell Trigg
Assistant Advocate
Office of Advocacy
U.S. Small Business Administration
cc:James Casserly
Jim Colthorp
Dan Gonzales
Kathy Levitz
Tim Peterson
Cathy Sandoval
Jere Glover