THE CASE FOR MAKING PAYPHONE LINES “LIFELINE” & “LINK-UP” ELIGIBLE

1. FLORIDA PUBLIC SERVICE COMMISSIONLINK UP FLORIDA AND LIFELINE ASSISTANCE WORKSHOPAPRIL 11, 2006TALLAHASSEE, FLORIDA

2. THE CASE FOR MAKING PAYPHONE LINES “LIFELINE” & “LINK-UP” ELIGIBLE PRESENTED BY THE FLORIDA PUBLIC TELECOMMUNICATIONS ASSOCIATION (“FPTA”)

3. Introduction • FPTA IS A NOT-FOR-PROFIT TRADE ASSOCIATION REPRESENTING THE PUBLIC COMMUNICATIONS INDUSTRY IN FLORIDA • FPTA’S MEMBERS INCLUDE INDEPENDENT PROVIDERS OF PUBLIC PAY TELEPHONE SERVICE—RANGING FROM FEWER THAN TEN TO THOUSANDS OF PAYPHONES • FPTA’S MEMBERSHIP ALSO INCLUDES SUPPLIERS OF EQUIPMENT AND SERVICES TO THE PAYPHONE INDUSTRY • http://www.FPTA.com

4. Background • IN RECENT YEARS, “INDEPENDENT” PAYPHONE OPERATORS HAVE BECOME THE “PROVIDERS OF LAST RESORT” ALL ACROSS FLORIDA • WITH THE EXPLOSIVE GROWTH IN WIRELESS SERVICES OVER THE PAST 5-6 YEARS, THE NUMBER OF PAYPHONES IN FLORIDA HAS DROPPED DRAMATICALLY—FROM OVER 120,000 IN 1999 TO JUST OVER 56,000 IN 2004 (ACCORDING TO FCC STATISTICS)—AND WELL BELOW THAT TODAY. DURING THIS SAME PERIOD, THE LARGEST PAYPHONE PROVIDER IN FLORIDA, BELLSOUTH, EXITED FROM THE PAYPHONE BUSINESS ENTIRELY • WIDESPREAD PAYPHONE DEPLOYMENT IS AN ESSENTIAL ELEMENT OF THE “UNIVERSAL SERVICE” SOLUTION THAT MUST BE MAINTAINED

5. WHY PUBLIC PAYPHONES ARE STILL IMPORTANT: • CORE “UNIVERSAL SERVICE” FUNCTIONS • PAYPHONES ARE A TRUE “LIFELINE” SERVICE FOR THE HOMELESS, VISITORS AND THE MANY HUNDREDS OF THOUSANDS OF FLORIDIANS WHO CANNOT AFFORD TO HAVE A HOME PHONE • PAYPHONES PROVIDE “AS NEEDED” PUBLIC ACCESS TO TELEPHONE SERVICE FOR ALL FLORIDIANS AND VISITORS TO OUR STATE—ON A 24/7/365 BASIS—WITH NO MONTHLY FEES OR HOOK UP CHARGES TO THE PAYPHONE USER • PAYPHONES ARE A “LIFELINE” FOR THE MILLIONS OF FLORIDIANS (ESPECIALLY LOWER INCOME & THE ELDERLY) WHO DO NOT HAVE CELLPHONES • PAYPHONES EVEN PROVIDE AN IMPORTANT SERVICE FOR PEOPLE THAT DO HAVE CELLPHONES—DEAD BATTERIES; LOST OR MISPLACED HANDSETS; MONTHLY MINUTES USED, OUT-OF-SERVICE-AREAS, ETC.

6. WHY PUBLIC PAYPHONES ARE STILL IMPORTANT: • “EMERGENCY AND SECURITY FUNCTIONS” • PAYPHONES ARE VITAL TO PUBLIC SAFETY ON BOTH EVERYDAY AND EMERGENCY BASES—THEY PROVIDE FREE 24/7ACCESS TO “911” EMERGENCY SERVICES AND HAVE PROVEN VITAL IN TIMES OF NATIONAL AND REGIONAL EMERGENCY • PAYPHONES HAVE LITERALLY SAVED THE DAY FOR THE CITIZENS MOST DIRECTLY AFFECTED DURING THE 9-11 ATTACKS, THE GREAT NORTHEAST U.S. POWER BLACKOUT & THE PAST TWO DIRE HURRICANE SEASONS • WHEN CELLPHONE NETWORKS WERE DOWN, ALONG WITH NUMEROUS HOME AND BUSINESS PHONES, (AS WAS THE CASE IN EACH OF THE NOTED EMERGENCIES) PAYPHONES PROVIDED A TRULY RELIABLE AND WORKING MEANS OF COMMUNICATION—A SAFETY NET WE CANNOT AFFORD TO LOSE

7. Division Street, Biloxi Mississippi. This payphone is up andrunning and was found to have survived the Katrina disaster. (Although the store it was mounted in front of was not as lucky!)

8. DESPITE THEIR CONTINUED IMPORTANCE, PAYPHONES ARE GETTING HARDER AND HARDER TO FIND IN MANY AREAS AND MORE AND MORE DIFFICULT TO MAINTAIN ON AN ECONOMICAL BASIS—HELP IS NEEDED

9. What Must Be Done? • WHEN PAYPHONES WERE PLENTIFUL, THE CONCEPT OF A ‘PUBLIC INTEREST PHONE’ PROGRAM (TARGETED AT A FEW DOZEN OR EVEN A FEW HUNDRED LOCATIONS— PARKS, PLAYGOUNDS, ETC.) WAS VIABLE—IN THE CURRENT ENVIRONMENT THESE TYPES OF LIMITED PROGRAMS WILL NOT TRULY ADDRESS THE MAGNITUDE OF THE PROBLEM OR OUR RAPIDLY DWINDLING PAYPHONE BASE • WHAT WE NEED IS A BROAD BASED FORM OF SUPPORT ON ‘DIAL TONE’ FOR PAYPHONES (THAT REPRESENTS AN ESSENTIAL BUT HIGH COST ELEMENT OF PAYPHONE DEPLOYMENT) • THE MOST EFFICIENT WAY TO PROVIDE THIS TYPE OF RELIEF IS TO UTILIZE THE EXISTING ‘LIFELINE & LINK-UP” SUPPORT PROGRAMS—PAYPHONES PROVIDE THE ESSENTIAL COMMUNICATIONS LINKS TO THE VERY SAME CITIZENS THESE PROGRAMS ARE DESIGNED TO ASSIST

10. What Must Be Done? Cont’d. • WHILE “LIFELINE/LINK-UP” CREDITS ON PAYPHONE LINES WILL NOT GUARANTEE RETENTION OF WIDESPREAD PAYPHONE DEPLOYMENT—THEY WILL CERTAINLY HELP STEM THE TIDE OF PAYPHONE REMOVALS BY MEANINGFULLY LOWERING ONE OF THE LARGEST MONTHLY PAYPHONE DEPLOYMENT AND RETENTION “HURDLES” IN PLACE TODAY • FPTA IS ASKING THE FPSC TO CONSIDER HELPING TO HAVE THE FEDERAL-STATE UNIVERSAL SERVICE JOINT BOARD, IN CONJUNCTION WITH THE FCC, DECLARE THAT PAYPHONE LINES ARE ELIGIBLE FOR “LIFELINE” AND “LINK-UP” SUPPORT