Xchange Telecom Corp.

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July 2, 2012 WC Docket No. 11-42 Wireline Competition Bureau Federal Communications Commission 445 12th Street, S.W., Room 5-B442, Washington, D.C. 2055 To Whom It May Concern: Attached please find Xchange Telecom’s application in WC Docket No 11-42, for an application to participate in the Broadband Adoption Lifeline Pilot Program. Please contact me with any questions. Mordy Gross General Counsel Xchange Telecom Corp. (646) 722-7285 [email protected] 3611 14 th Ave 877.853.8350 Brooklyn, New York 11218 877.853.9378 fax www.xchangetele.com

Transcript of Xchange Telecom Corp.

Page 1: Xchange Telecom Corp.

July 2, 2012

WC Docket No. 11-42

Wireline Competition Bureau

Federal Communications Commission

445 12th Street, S.W.,

Room 5-B442,

Washington, D.C. 2055

To Whom It May Concern:

Attached please find Xchange Telecom’s application in WC Docket No 11-42, for an application to participate in the Broadband Adoption Lifeline Pilot Program.

Please contact me with any questions.

Mordy Gross

General Counsel

Xchange Telecom Corp.

(646) 722-7285

[email protected]

3611 14th Ave 877.853.8350

Brooklyn, New York 11218 877.853.9378 fax

www.xchangetele.com

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Xchange Telecom Corp., FRN 6831713, SAC 159017, is designated as an ETC in the State of

New York. Providing a full array of Lifeline and regular telephone plans, Xchange is the second

largest wireline provider in New York after Verizon, with over 8,800 lifeline customers.

Xchange provides Lifeline service in the Verizon New York Footprint.

Xchange provides several Lifeline plans, in order to ensure the public receives relevant services.

Xchange provides both traditional plans that are tax-exclusive, and an array of tax-inclusive

plans:

Plan Name Downstate Price Upstate Price Lifeline Basic Measured plan

$1.00 (plus tax) $1.00 (plus tax)

Lifeline Basic with Feature Pack Measured plan with 4 features (caller ID, Call waiting, 3-way calling

and Anonymous Call Reject)

Not Offered $18.95 (plus tax and fees)

Lifeline Xchange Local Unlimited Local Calling

Not Offered $10.15 (plus tax and fees)

Lifeline Xchange Local with Feature Pack Unlimited Local plan with 4 features (caller ID, Call waiting, 3-way

calling and Anonymous Call Reject)

Not Offered $28.10 (plus tax and fees)

Lifeline Xchange USA Plus Unlimited USA Calling plan with 4 features (caller ID, Call waiting, 3-

way calling and Anonymous Call Reject)

Not Offered $33.60 (plus tax and fees)

Lifeline Bigtalk Local Unlimited Local Calling with six features (Caller ID w/Name, Call

waiting, 3-way calling, Anonymous call reject, *69 – call return, *66 –

repeat dial)

$26.99 (tax and fee inclusive)

Not offered

Lifeline Bigtalk Metro Unlimited Local and Regional Calling with six features (Caller ID

w/Name, Call waiting, 3-way calling, Anonymous call reject, *69 – call

return, *66 – repeat dial)

$27.99 (tax and fee inclusive)

Not offered

Lifeline Bigtalk USA Unlimited USA calling, with 200 free international minutes, and six

features (Caller ID w/Name, Call waiting, 3-way calling, Anonymous

call reject, *69 – call return, *66 – repeat dial)

$31.49 (tax and fee inclusive)

Not offered

1) Proposed Pilot Project

(B) A full description of the proposed pilot project(s), including but not limited to:

1. The geographic area(s) in which the ETC will offer the broadband plan(s) for

their project(s), census data on the income levels of the residents of the specified geographic

area(s) (census tracts, blocks or zip codes), and whether the geographic area(s) will cover Tribal

lands;25

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Xchange proposes to focus the pilot on several neighborhoods in Central Brooklyn, where

Xchange currently services many lifeline customers, and currently suffer from high

unemployment, low median income and low broadband adoption. FCC research and

independent research has shown that access to broadband is essential to allow low income people

to escape from the vicious cycle of poverty.

Brooklyn is a vibrant and diverse community. Brooklyn was an independent city until its

consolidation with New York City in 1898, and continues to maintain a distinct culture,

independent art scene, and unique heritage. Many Brooklyn neighborhoods are enclaves where

particular ethnic groups and cultures predominate. It includes a diverse population that is 36%

African American, 20% Hispanic and 10% Asian, and 37% of the people living in Brooklyn are

immigrants.1 It is the most populous county in New York State and the second most densely

populated county in the United States.

Sadly, however, there is a darker side to Brooklyn’s history. Although Brooklyn is the most

populous borough in New York, it lags sorely in subscribership – indeed, it is among the six New

York State counties that is under 60% subscribed, notwithstanding the presence of over 30 broadband

providers that purport to serve Brooklyn. Brooklyn is suffering. Its high school dropout rate is over

fifty percent higher than the national average (24% versus 6%)2. Making broadband affordable for

Brooklyn’s students would enable them to retain more students and give them a more fulfilling

educational experience.

Brooklyn’s ability to provide employment for its citizens is likewise impaired. Brooklyn has a per

capita income rate that is less than 84% of that of the nation, and 75% of the state. 21% of the

population lives in poverty-in spite of the fact that Brooklyn’s workforce consists of double the

amount of persons with graduate level degrees compared to the nation’s average.3 Many Brooklyn

neighborhoods suffer from severe unemployment. Making broadband affordable will help connect

people to jobs and create new jobs.

Xchange will focus the pilot on the neighborhoods of Williamsburg, Kensington, Parkville, Borough

Park, and Midwood. These neighborhoods are some of the poorest neighborhoods in Brooklyn, with

1 Source: Census Data 2 Source: Nielsen, Census Data 3 Source: Census Data

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an average per capita income that is 64% of the national rate.4 Based on the most recent FCC data,

only 48% of the households have a broadband subscription. Census level data follows:

Census

Tract ID

City State County Per Capita

income

Households % Subscribership

(FCC 6/2012

report)

36047011000 Brooklyn NY Kings $14,029.00 597 60%

36047011200 Brooklyn NY Kings $11,405.00 1798 40%

36047011400 Brooklyn NY Kings $16,577.00 1157 40%

36047021400 Brooklyn NY Kings $16,936.00 562 60%

36047021600 Brooklyn NY Kings $13,711.00 966 40%

36047021800 Brooklyn NY Kings $13,139.00 1005 40%

36047022000 Brooklyn NY Kings $16,680.00 1256 40%

36047022200 Brooklyn NY Kings $14,342.00 1234 40%

36047022400 Brooklyn NY Kings $16,248.00 1340 40%

36047022600 Brooklyn NY Kings $11,151.00 650 60%

36047022800 Brooklyn NY Kings $9,522.00 788 40%

36047023000 Brooklyn NY Kings $13,861.00 1020 40%

36047023200 Brooklyn NY Kings $9,535.00 1558 20%

36047023400 Brooklyn NY Kings $13,547.00 1400 20%

36047023600 Brooklyn NY Kings $14,672.00 1672 20%

36047023800 Brooklyn NY Kings $16,528.00 1380 20%

36047024000 Brooklyn NY Kings $14,001.00 1377 40%

36047024200 Brooklyn NY Kings $13,450.00 759 60%

36047024400 Brooklyn NY Kings $20,392.00 1063 40%

36047024600 Brooklyn NY Kings $20,282.00 1033 60%

36047046400 Brooklyn NY Kings $11,348.00 681 40%

36047046800 Brooklyn NY Kings $20,068.00 400 80%

36047047000 Brooklyn NY Kings $26,428.00 800 40%

36047047200 Brooklyn NY Kings $16,942.00 722 20%

36047047400 Brooklyn NY Kings $18,579.00 833 40%

36047047600 Brooklyn NY Kings $13,766.00 1037 20%

36047047800 Brooklyn NY Kings $12,340.00 1246 40%

4 Source: 2009 Census Data

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Census

Tract ID

City State County Per Capita

income

Households % Subscribership

(FCC 6/2012

report)

36047019100 Brooklyn NY Kings $25,740.00 1461 80%

36047019300 Brooklyn NY Kings $25,358.00 2036 80%

36047023300 Brooklyn NY Kings $15,659.00 1573 60%

36047023500 Brooklyn NY Kings $11,316.00 997 100%

36047023700 Brooklyn NY Kings $13,531.00 708 60%

36047023900 Brooklyn NY Kings $11,532.00 367 80%

36047025500 Brooklyn NY Kings $8,026.00 1554 80%

36047050700 Brooklyn NY Kings $9,009.00 375 100%

36047050900 Brooklyn NY Kings $7,131.00 558 20%

36047052500 Brooklyn NY Kings $5,778.00 1048 60%

36047052900 Brooklyn NY Kings $11,176.00 977 20%

36047053100 Brooklyn NY Kings $10,801.00 1172 20%

36047053300 Brooklyn NY Kings $5,318.00 1881 20%

36047053500 Brooklyn NY Kings $7,271.00 1427 20%

36047053700 Brooklyn NY Kings $4,837.00 517 20%

36047053900 Brooklyn NY Kings $9,181.00 1015 20%

36047054300 Brooklyn NY Kings $20,281.00 118 0%

36047054500 Brooklyn NY Kings $6,904.00 2091 20%

36047054700 Brooklyn NY Kings $7,327.00 1004 40%

36047054900 Brooklyn NY Kings $21,576.00 1077 100%

36047045200 Brooklyn NY Kings $27,053.00 921 40%

36047045400 Brooklyn NY Kings $27,549.00 618 40%

36047045600 Brooklyn NY Kings $27,372.00 873 60%

36047045800 Brooklyn NY Kings $42,804.00 542 40%

36047053200 Brooklyn NY Kings $21,646.00 981 40%

36047053400 Brooklyn NY Kings $15,264.00 1363 60%

36047053600 Brooklyn NY Kings $16,879.00 293 80%

36047053800 Brooklyn NY Kings $18,752.00 2072 60%

36047054200 Brooklyn NY Kings $19,684.00 1558 60%

36047054400 Brooklyn NY Kings $22,820.00 1301 60%

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Census

Tract ID

City State County Per Capita

income

Households % Subscribership

(FCC 6/2012

report)

36047054600 Brooklyn NY Kings $19,303.00 1929 60%

36047074800 Brooklyn NY Kings $25,090.00 683 40%

36047075000 Brooklyn NY Kings $21,946.00 969 60%

36047075200 Brooklyn NY Kings $40,797.00 332 60%

36047075400 Brooklyn NY Kings $43,859.00 433 40%

36047075600 Brooklyn NY Kings $34,159.00 672 60%

36047075800 Brooklyn NY Kings $26,564.00 652 60%

36047076000 Brooklyn NY Kings $28,262.00 1091 60%

36047076200 Brooklyn NY Kings $16,350.00 1625 60%

36047054000 Brooklyn NY Kings $21,792.00 843 40%

36047053000 Brooklyn NY Kings $20,540.00 1099 60%

36047048800 Brooklyn NY Kings $19,379.00 1005 60%

36047049000 Brooklyn NY Kings $15,933.00 1100 80%

36047049200 Brooklyn NY Kings $20,624.00 2184 40%

36047049400 Brooklyn NY Kings $22,006.00 1019 60%

36047049600 Brooklyn NY Kings $16,683.00 1813 60%

36047049800 Brooklyn NY Kings $18,002.00 1423 60%

36047048000 Brooklyn NY Kings $13,083.00 1131 40%

36047048200 Brooklyn NY Kings $16,662.00 1973 60%

36047048400 Brooklyn NY Kings $15,355.00 1641 60%

36047048600 Brooklyn NY Kings $11,684.00 1005 40%

36047046201 Brooklyn NY Kings $27,504.00 992 40%

36047046202 Brooklyn NY Kings $20,113.00 448 60%

36047046001 Brooklyn NY Kings $16,092.00 1027 60%

Average $17,516.49 48.4%

2) Technologies to be deployed:

Xchange Telecom is unique in that in such a small area, it has the ability to deploy three different

types of technologies.

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In the Borough Park and Kensington area, Xchange will utilize its WiMax network currently

deployed to offer fixed wireless lifeline services. The subscriber will have a choice of

installation into their inside wiring and antenna placed on their roof, or an indoor unit to be

placed in their window. Both deployments will offer customers reliable voice and data.

In the Midwood, Parkville and Kensington area, Xchange will offer lifeline subscribers voice

and DSL, provided by reselling Verizon DSL and via Xchange’s own DSL provided over

Verizon UNE loops.

In the Williamsburg area, Xchange will service customers using two methods. First, in

partnership with the New York City Housing Authority (NYCHA), Xchange is deploying a fixed

point to point network to service NYCHA housing developments. Each link will connect the

apartment building to Xchange’s state-of-the-art network. Via an Ethernet Services Access

Node placed within the building, Xchange will provide DSL and voice to NYCHA customers.

To the lifeline subscriber, the experience is DSL, but the reliability is much greater than with

traditional DSL. For lifeline customers not within the NYCHA housing developments, Xchange

will provide services over resold Verizon DSL or UNE loops.

Deploying three technologies will allow Xchange to control for variations in the customer

experience, and provide the FCC with the best data as to what customers require.

3) Broadband Speeds Offered:

Because Xchange is deploying three different technologies, Xchange will offer speeds based on

each technology.

In the DSL areas, Xchange will offer one speed offering of 5MBPS down/1MBPS up.

In the NYCHA buildings, where Xchange will offer DSL backed by a wireless link, Xchange

will offer one speed offering of 10MBPS down/1MBPS up.

In the WiMax areas, Xchange will offer one speed offering of 15MBPS down/1MBPS up.

4) Monthly Discounts

Xchange will look to offer the broadband on a bundled and non-bundled basis, creating two

groups so that the FCC will get data on what type of program is best.

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In each of the two groups, Xchange would like to create three different subgroups, with different

discounts per group. Xchange would discount its DSL/WiMax offering by $10, $15, and $20 for

each group, with corresponding subsidies from USAC.

In the unbundled group, Xchange will offer the following three plans:

Base price (for non – lifeline customers) $24.99

Discount Group I $14.99

Discount Group II $9.99

Discount Group III $4.99

In the bundled group, Xchange will offer the same three tiers, but offer it together with

Xchange’s voice plans, all prices, tax and fee inclusive: Plan Name Standalone

Price

Discount

Group I

Discount

Group II

Discount

Group III

Lifeline Bigtalk Local Unlimited Local Calling with six features (Caller ID

w/Name, Call waiting, 3-way calling, Anonymous

call reject, *69 – call return, *66 – repeat dial)

$26.99 $41.99 $36.99 $31.99

Lifeline Bigtalk Metro Unlimited Local and Regional Calling with six

features (Caller ID w/Name, Call waiting, 3-way

calling, Anonymous call reject, *69 – call return, *66

– repeat dial)

$27.99 $42.99 $37.99 $32.99

Lifeline Bigtalk USA Unlimited USA calling, with 200 free international

minutes, and six features (Caller ID w/Name, Call

waiting, 3-way calling, Anonymous call reject, *69 –

call return, *66 – repeat dial)

$31.49 $46.49 $41.49 $36.49

In addition, Xchange would offer customers ISP filtered internet for an additional $9.99. Based

on a poll conducted by Xchange, 28% of customers polled that do not currently have broadband,

did not subscribe to broadband because of danger to children or their desire to avoid

pornography. A Pew research poll conducted in 20055 corroborates this concern of parents.

Thus, Xchange’s ability to offer an ISP based filter- one that cannot be avoided by a child

shutting off the filter – is likely to increase adoption.

5 http://www.pewinternet.org/~/media//Files/Questionnaire/Old/Filters_questionnaire.pdf

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Xchange will not limit the broadband offerings in terms of usage. Xchange currently does not

limit data usage and has no intentions of implementing such limits in the near future.

5) Nonrecurring fees

Xchange is seeking a Linkup style fee to recover costs. Xchange charges customers $49.99

activation fee for DSL. This cost recovers fixed costs for Xchange charged to us for Verizon for

a new line install (between $90 to $114) or for a port and hotcut (approximately), and costs of

DSL equipment of $35.

Xchange proposes that the FCC for this pilot should cover the activation fee entirely. The cost

for customers to get broadband is already too high, and cost is a significant barrier for new

customers. Regardless of the technology, there is fixed customer premises equipment charges

that almost all carriers charge – different from the voice scenario, where most carriers waive

such charges.6

6) Focusing on non-subscribers

Xchange has a current base of agents that have brought in more than half of Xchange’s current

customers. These agents know the specific market that they tap into, and in many cases,

personally know the customers. The agents have been an asset in the past in bringing in

customers, and if provided with new products such as a lifeline offering, they will bring in new

customers as well. Moreover, some of the agents have unique relationships within ethnic

communities, such as the Hispanic and Korean neighborhoods of Brooklyn, and can facilitate

ensuring a diverse pilot population.

Where Xchange deploys in the NYCHA buildings, Xchange will work with NYCHA to promote

the lifeline product within the NYCHA buildings. NYCHA residents are inherently lifeline

eligible, and make up a diverse cross-section of the ethnicities of Brooklyn. NYCHA serves as a

small test lab for each type of deployment.

Xchange is partnering with the Older Adults Technology Services (OATS) to both focus on

deployment to eligible seniors and provide them with digital outreach and technology training.

6 From Comcast’s website: “Equipment, installation, taxes, the Regulatory Recovery Fee and other applicable charges (e.g., per-call, toll and international rates) extra. $29.95 activation fee may apply.” From Time Warner’s website – “Additional charges apply for installation, equipment including modem, applicable taxes and fees.”

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OATS engages, trains and supports older adults in using technology to improve their quality of

life and enhance their social and civic engagement. Because many seniors do not currently have

broadband, it is crucial to focus on deployment of the lifeline program to seniors.

7) Overall Funding Amount

Xchange proposes to sign up the following total of customers, in each tier:

Tier I Tier II Tier III Total

Wireline/DSL 834 834 832 2500

Wireline

(NYCHA)

250 250 250 750

Fixed Wireless 1667 1667 1666 5000

Xchange estimates the total overall funding amount to range in between $1,217,370 and

$1,897,320. The reasoning is as follows:

If Xchange were to immediately sign up every customer, (factually improbable), the cost,

because of the monthly discount provided, would be $1,897,320 – this is thus the maximum.

Tier I Tier II Tier III Total

Wireline/DSL 834 834 832 2500

Wireline

(NYCHA)

250 250 250 750

Fixed Wireless 1667 1667 1666 5000

Total Monthly Cost Total Yearly

Cost

$27,510.00

$41,265.00

$54,960.00

$123,735.00 $1,484,820.00

Linkup $412,500.00

Total $1,897,320.00

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What is more likely is that Xchange will sign up the customers over a period of 12 months, in an escalating fashion. Below appears a

straight-line growth estimate: Monthly

Cost t Total

Yearly

Cost

Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12

Total Wireline DSL

$208.00 $416.00 $624.00 $832.00 $1,040.00 $1,248.00 $1,456.00 $1,664.00 $1,872.00 $2,080.00 $2,288.00 $2,500.00

Total NYCHA

$63.00 $126.00 $189.00 $252.00 $315.00 $378.00 $441.00 $504.00 $567.00 $630.00 $693.00 $750.00 Total Fixed Wireless

$417.00 $834.00 $1,251.00 $1,668.00 $2,085.00 $2,502.00 $2,919.00 $3,336.00 $3,753.00 $4,170.00 $4,587.00 $5,000.00

Total $688.00 $1,376.00 $2,064.00 $2,752.00 $3,440.00 $4,128.00 $4,816.00 $5,504.00 $6,192.00 $6,880.00 $7,568.00 $8,250.00 Tier I $2,293.00 $4,587.00 $6,880.00 $9,173.00 $11,467.00 $13,760.00 $16,053.00 $18,347.00 $20,640.00 $22,933.00 $25,227.00 $27,500.00 Tier II $3,440.00 $6,880.00 $10,320.00 $13,760.00 $17,200.00 $20,640.00 $24,080.00 $27,520.00 $30,960.00 $34,400.00 $37,840.00 $41,250.00

Tier III $4,587.00 $9,173.00 $13,760.00 $18,347.00 $22,933.00 $27,520.00 $32,107.00 $36,693.00 $41,280.00 $45,867.00 $50,453.00 $55,000.00

Total $10,320.0 $20,640.00 $30,960.00 $41,280.00 $51,600.00 $61,920.00 $72,240.00 $82,560.00 $92,880.00 $103,200.00 $113,520.00 $123,750.00 $804,870.00

Linkup $412,500.00

$1,217,370.00

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Xchange is also seeking recovery for the costs of additional surveys of non-subscribers, as more

fully outlined in section 14, on page 14 below.

8) Marketing Description

Xchange has successfully relied in the past on marketing its lifeline product via print and radio

advertisements, and via its agent program. However, due to the fact that the pilot envisions

different groups with different programs offered, Xchange will rely on targeted mailings and

agents in order to control the groups. Xchange will advertise in mass media only in general

terms, so as not to “poison” the groups.

Xchange will look towards its existing 8800 lifeline subscribers that are in the pilot study areas,

and towards potential customers brought in by OATS and NYCHA. Xchange will advertise in

English and Spanish, and in any other language that individual agents would like to advertise.

Examples are attached hereto as Appendix B – Samples of Current Advertisement material.

9) Customer Support:

Xchange Customer Support operates Monday – Thursday, 8AM through 9PM, and Friday 8AM -

4PM. After-hours voicemails are returned immediately the next business day. Xchange has a

customer support department of highly trained specialists, and an off-site backup support group

that takes overflow and helps service when the on-site support is down.

10) Digital Literacy Training

Xchange is partnering with OATS to provide digital literacy training to seniors. Promoting

broadband adoption and use among low-income seniors is at the heart of OATS' mission and

work. Under the proposed partnership, OATS will play the following roles:

o Support pilot program outreach efforts among low-income seniors by conducting

a promotional communications campaign to existing and new OATS partner sites

located within the geographies served by the proposed pilot program.

o Deliver "Computer Basics for Older Adults", a ten-week, twenty-session course

that introduces groups of 8 to 12 seniors to the fundamentals of using a computer,

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the internet, and email. This course will be delivered by professional OATS

instructors who, on average, have delivered over 350 training sessions to seniors.

The course curriculum is specifically designed for older adults and is designed to

foster and maintain broadband adoption and use. The number of courses

delivered will be determined by the overall enrollment / subscription in the pilot

program by seniors. Courses will be delivered locally in a group setting, at

existing computer labs housed at local partner sites in or adjacent to the

neighborhoods in which the subscribers reside.

The efficacy of OATS' training have been documented by the New York Academy of Medicine

in an independent evaluation report issued in 2010.

Key findings that are relevant to the pilot program include:

• 98% of participants reported an increase (47% significantly; 27% somewhat) in their

ability to use computers after completing the OATS course

• Prior to the OATS course 51% of participants used a computer regularly (daily or

several times per week). Immediately after the training 95% reported regular use.

• Six months later 93% continued to use their computers regularly, and 89% of

participants reported they were still able to do what they learned in the course

• 64% of participants reported that the amount of time they spent communicating with

friends and family increased as a result of the OATS training

• In the post-course survey, 89% reported that their ability to access information

increased as a result of the training (56% significantly increased; 33% somewhat

increased). Health and medical information was the most common type of

information pursued on the internet (71% of participants reported searching for health

information online)

To learn more about OATS, please visit www.oats.org

Xchange is also partnering with the City University of New York Computer Sciences

Department (CUNY-CS) to offer digital literacy training. Xchange will offer to a controlled

group a class or series of class locally located that will train customers in basic digital literacy.

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Due to timing constraints and the RFP deadline, the class curriculum is currently in development

between Xchange and CUNY-CS.

11) Partnerships

Xchange is partnering with the School of Public Affairs, Baruch College, City University of New

York (Baruch), in designing the pilot program. This partnership will provide Xchange with

guidance in planning adoption efforts that provide for a more holistic approach. The faculty of

Baruch has many years of experience in designing and running such research programs. The CV

of the Baruch faculty involved is attached as Appendix F – CVs. Combined with Xchange’s field

experience in marketing lifeline products, Xchange and the School of Public Affairs has come

forth with a pilot program that tests multiple technologies and speeds and provides for controlled

groups for testing.

Xchange is partnering with OATS to help with outreach to seniors. Older Adults Technology

Services, Inc. (OATS) “harnesses the power of technology to change the way we age.” By

engaging, training and supporting low-income senior citizens in digital literacy and the use of

broadband technology to improve their lives, OATS has created a national model for addressing

the vital health, socialization, financial, civic, and creative needs of older adults. OATS is deeply

committed to community partnerships and has delivered outcomes-focused digital literacy

programs at more than 70 locations across New York City. Since 2004, the organization has

taught over 12,500 free classes while training over 8,500 individuals, and given away more than

1,300 free computers to seniors and community centers.

Since September 2010, OATS has been implementing the City of New York's Broadband

Technology Opportunities Program (BTOP) deliverables for older adults, including 23 Public

Computer Centers sited at senior centers, the provision of 3,000 training sessions, the creation of

a mobile (vehicular) lab, the nation's first technology-themed community center for seniors, and

Senior Planet, a digital community of 26,000 that is being totally redesigned and will re-launch

in September 2012. With all of OATS current programs, and digital literacy training, Xchange is

certain that this partnership will help ensure a broad adoption of the lifeline pilot program.

Xchange is partnering with CUNY-CS to provide digital literacy training. CUNY-CS is a

premier educator in the City of New York, and will provide access to CUNY schools that are

located within the test area.

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Xchange will utilize its diverse community contacts, many of which partnered with Xchange in

2010 in order to apply for a grant under BTOP. A few of those letters are attached to the

application. These community partners will help with outreach and overcoming any community

stigma to broadband.

12) Design, Data Gathering and Evaluation of the Pilot

The pilot design arises as a collaboration between Xchange and Baruch. All data gathered by the

joint team will be submitted to CUNY for analysis and data and results will be passed on to the

FCC.

Offerings among the several groups in terms of whether the discount will be applied to bundled

voice plans, or non-bundled plans, and the level of the discount, will be offered on a randomized

basis. Xchange will use randomization software to offer the programs to different groups at

different prices. In certain cases, however, different groups will have to be segregated

geographically, to account for the amount of cross-communicating of offers.

To sum, there will be three technology control groups based on geography: Fixed wireless, to be

offered in Borough Park; DSL, to be offered in Parksville, Kensington and Midwood, and DSL

provided over fixed P2P links, offered in NYCHA developments in Williamsburg.

In each of the three areas, there will be six randomized groups (in the case of Williamsburg,

randomized on a per-building basis). Each group will be offered either bundled or non-bundled,

and three tiers of discounts, from 10, 15 to 20 dollars a month. There will be a final control

group, in Rockland County, NY, that will not be offered any discounts and will not be advertised

regarding the discounts or the pilot at all.

We will also test whether digital literacy makes a difference by offering the CUNY-CS course to

a control group.

Based on the population of the project, several interesting controls will be able to be placed.

For example, since Xchange intends to “light up” several NYCHA developments for the project,

Xchange can control for cross-communication of offers by offering each development separate

discounts. The likelihood of a geographically separated group from one development to talk to a

development that is a half a mile away is thus lessened.

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15

To control for Randomization bias, wherein experimental sample is different from the target

population can be controlled because where Xchange offers to a NYCHA development, all

members of the development are equally eligible by virtue of them being housed in public

housing developments. Thus, any randomization will tend to reflect the target population. Using

these target populations as a whole again will tend to allow Xchange to avoid what has been

described as the “John Henry” effect, or where persons subject to the testing will try harder to

prove their worth – again, since all of the test subjects are inherently eligible for the end result of

lifeline broadband, there is little for them to gain in trying harder.

By using a segregated control group in Rockland County, NY, Xchange can test and control for

the amount of bleed-through in terms of the advertised message, and to what extent

advertisements in one market tend to spread to the other market.

Data Gathering

Xchange will gather the requisite data and pass it on to USAC in partnership with Baruch. For

any customer that joins the project, Xchange will require them first to fill out an online survey

the first time they access the internet, via a redirect to the survey. Additional questions will be

asked of them once they finish the USAC survey. Without filing out the survey, they will not be

able to access the internet. For any customer that does not fill out this survey, Xchange customer

service will contact them by phone within 90 days to conduct the survey. The online survey will

allow the customer to call in instead of filling out the survey online to fill out the survey by

phone.

Data Gathering of Non-Subscribers

Xchange and Baruch notice that the FCC plan neglects surveying of non-subscribers. Xchange

and Baruch both agree that while the surveys posed to subscribers are invaluable, it is equally

important for the FCC to find out why non-subscribers did not choose to subscribe. How can the

FCC discover whether a program is relevant to the public without asking people offered the

program why they didn’t join? We thus feel it is crucial to include this polling.

In addition, the exit survey is flawed in that it only polls subscribers that continued their

subscription to the end and does not poll those that end their relationship. Especially where

digital literacy training is provided, Xchange and Baruch feel that it is invaluable to know the

Page 17: Xchange Telecom Corp.

16

reasons why these customers left, and to what extent relevancy of the Internet service played a

part.

However, since such a telephone survey would not be reimbursed under the structure of the pilot,

Xchange cannot foot such a bill. Baruch estimates that such telephone surveys would cost an

additional $175,000 - $200,000. Accordingly, Xchange proposes that such surveys with

reimbursement to Baruch be added as a separate reimbursed cost.

Xchange and Baruch propose, if the FCC is willing to add such reimbursement, for any non-

subscribers (i.e., customers solicited via direct mailing who did not respond), Xchange will

conduct an initial telephone survey of those non-subscribers to find out why they did not

subscribe. This survey will allow Xchange and the FCC to discover, from a pool of people who

refused the discount, why they refused the discount. Since this group will be made up of

Xchange customers only, Xchange will conduct another similar telephone survey in the NYCHA

buildings, conducted from NYCHA phone lists. Xchange and Baruch would conduct a similar

telephone survey to supplement the end survey of the FCC for any customers that does not

respond to the survey request.

In addition to all the questions that are in the survey questionnaire provided by the FCC,

Xchange would ask other questions of interest, developed by Baruch and Xchange.

At the end of the pilot, Xchange will conduct a follow up survey of customers, asking the FCC

questions, via an email directing the subscribers to the USAC website. Xchange would also

solicit follow up information of questions of interest, developed by Baruch and Xchange.

Xchange would supplement the survey for the non-responders via a telephone survey.

Some of the points of interest that Xchange and Baruch would like to test, and formulate

questions regarding these points:

1) What factor does the offering of an ISP based filter have on people who are averse to the

Internet because of content issues?

2) What factor does consistency in speed play? Xchange can test this by selecting a

randomized group to adjust their speeds from what is advertised and see if the customer

retention is changed.

Page 18: Xchange Telecom Corp.

17

3) What effect does the trusted intermediary play in broadband adoption? Xchange can test

this by monitoring which customers are signed up via NYCHA, OATS or and agent

relationship.

4) By using agents, Xchange can also control for variations in the literature of the

advertising.

5) What factor does speed as compared to the competition play? Because Xchange is

offering in controlled groups specific speeds, Xchange can survey the non-subscribers to

find out whether the speed offered was the concern.

6) What factor does technology offered play? Because Xchange is offering several

technologies, we can text whether the technology offered has any impact.

7) What factor does digital literacy offerings play? Xchange will offer a limited digital

literacy program via OATS and CUNY-CS, and will monitor uptake and persistence of

the users.

As stated before, Brooklyn is a city in of itself. It is as diverse a community as it gets, and it is

the perfect microcosm of the United States. Different neighborhoods lend to testing different

results, some are more integrated, some are more ethnic. Since Xchange has been working in

Brooklyn for over 10 years, it will have no problem obtaining the sufficient sample size required.

Compliance with new rules

Xchange has adopted the policy attached hereto as Appendix G – Eligibility policy. Xchange

attaches a copy of the ETC’s certification form as Appendix D– Certification form. Since there

will be different form for bundled and unbundled plans, the form will be adopted accordingly to

comply.

Transition after Pilot

Transition after the pilot will depend on how long after the pilot the FCC will implement the

discounts. Xchange proposes that for the participants in the pilot, any discount implemented

should retroactively cover the pilot participants for the interim period between the end of the

pilot and the start of the Lifeline Broadband discount. This will prevent bill-shock to customers,

MGross
Typewritten Text
Page 19: Xchange Telecom Corp.

18

and discounts rising and falling. It will prevent the ETC that participated in the pilot from

having to take the effort to sign up the customer through two separate conquests.

A copy of a letter under such a program is attached hereto as Appendix E – Transition Letter to

Subscribers.

Either way, Xchange will notify the customer by mail at least 45 days before the end of the pilot,

but not more than 60 days, and take any action the customer would like, including ending the

service, changing the speed or any other adjustments.

Final Report

Xchange and Baruch will prepare and submit a final report that will test, among others, the

following hypotheses:

1) Many customers are loath to join the internet because of content, and having an ISP based

filter will help customers overcome that fear.

a. This is tested by the fact that Xchange can offer ISP based filtering, which cannot

be disabled by a savvy child at the home.

2) To What extent does consistency in speed play? Xchange can test this by selecting a

randomized group to adjust their speeds from what is advertised and see if the customer

retention is changed.

3) The effect does the trusted intermediary play in broadband adoption? Xchange can test

this by monitoring which customers are signed up via NYCHA, OATS or and agent

relationship, the extent that such customers stay when offered digital literacy training,

and the extent that the agent relationship is beneficial to consumer stickiness.

4) By using agents, Xchange can also control for variations in the literature of the

advertising.

5) What factor does speed as compared to the competition play? Because Xchange is

offering in controlled groups specific speeds, Xchange can survey the non-subscribers to

find out whether the speed offered was the concern.

6) What factor does technology offered play? Because Xchange is offering several

technologies, we can text whether the technology offered has any impact.

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19

7) What factor does digital literacy offerings play? Xchange will offer a limited digital

literacy program via OATS and CUNY-CS, and will monitor uptake and persistence of

the users.

Respectfully submitted,

July 2, 2012 Mordy Gross

General Counsel

Xchange Telecom Corp.

(646) 722-7285

[email protected]

Page 21: Xchange Telecom Corp.
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AppendixB–SamplesofCurrentAdvertisementmaterial

Page 23: Xchange Telecom Corp.

LifeLine BIGtalk Metro

Plan B

LifeLine BIGtalk Plans And Services

*Unlimited Local calls within your local calling areaXchange LifeLine plans apply to only to one line per eligible household. Telephone service must be listed in the applicant’s name.Price re�ects e-bill discount of $0.50, Autopay discount ($0.50 for BigTalk Local and Metro, $1.00 for Bigtalk USA), and $2.00/month new customer discount. New Customer discount expires after one year of service. One year service contract required, early termination fees may apply. Territorial restrictions apply. Free minutes are a promotion, and may be discontinued.**Free international minutes are limited to Western Europe and Israel 2

2 of 3

LifeLine BIGtalk USA

Plan C UnlimitedUnlimitedUnlimitedUnlimited

Monthly Charge

INCLUDES ALL TAXES & FEES

Monthly Charge

New York Metro Plans

Local Usage:Regional Usage:Intrastate Usage:Interstate Usage:

Local Usage:Regional Usage:Intrastate Usage:Interstate Usage:

Plan B includes FREE Feature Pack

Plan A includes FREE Feature Pack

LifeLine BIGtalk Local

Plan AMonthly Charge

$24.99*

Local UsageRegional UsageIntrastate UsageInterstate Usage

Unlimited$.099/min0.0690.045

UnlimitedUnlimited0.0690.045

Plan C includes FREE Feature Pack PLUS 200 Free International Minutes**

Feature Pack Includes OurSix Most Popular Features:

Optional LifeLine Add-Ons:Inside Wire Maintenance $2.49

VoiceMail $4.95

Premium Feature Package $5.95 Voicemail Call Forwarding

Single Features $2.95 (per feature) Anonymous Call Rejection with ID Directory Assistance Block Call Forward No Answer Ultra-Call Forward Call Forward Busy Call Forward Variable Speed Dial 8 Non-Published

BIGtalk Plan Add Ons

CallerID w/Name Call Waiting3-Way CallingAnonymous Call Reject *69-Call Return *66-Repeat Dial

As Low As:

INCLUDES ALL TAXES & FEES$23.99*As Low As:

INCLUDES ALL TAXES & FEES$27.99*

$31.49

$27.99

$26.99

As Low As:

Unlimited Local, Regional,

& USA Calling

Unlimited Local & Regional Calling

Unlimited Local Calling

*Available Discounts:-$2.00 : New Customer Sign-Up Bonus

( First 12 Months )-$0.50 : AutoPay Discount

-$0.50 : E-Bill Discount

*Available Discounts:-$2.00 : New Customer Sign-Up Bonus

( First 12 Months )-$1.00 : AutoPay Discount

-$0.50 : E-Bill Discount

*Available Discounts:-$2.00 : New Customer Sign-Up Bonus

( First 12 Months )-$0.50 : AutoPay Discount

-$0.50 : E-Bill Discount

All plans include BIGtalk fraud prevention at no charge. Fraud prevention prevents your long distance bill from unnecessary cost overruns by monitoring your toll calls. You can rest assured that your toll bill will never exceed the limit you set. After the limit is reached, a message will route the call to Customer Service to prevent fraudulent use.

Page 24: Xchange Telecom Corp.

Complete y �rme la página 1.Además, haga una copia de su tarjeta de bene�cios del programapor el cual está recibiendo asistencia actualmente o uncomprobante de ingresos en el hogar.Luego, puede utilizar estos medios para enviar estos datos aXchange para que los procesen:

Fax: 212.321.3600

Correo postal:Dollar Phone Enterprise, Inc.232 BroadwayBrooklyn NY 11211

Correo electrónico: [email protected]

LifeLine By Dollar Phone

IMPORTANTE

Page 25: Xchange Telecom Corp.

Solicitud del servicio adherido al programa LifeLine de Dollar Phone(Servicio telefónico con descuento en Metro NY)

Nombre del solicitante Número de teléfono particular(Incluya el código de área)

(_____) ______-___________Número de teléfono en el que pueden encontrarme para organizar el servicio

(_____) ______-___________

REQUISITOS

Proporcione su Número de Seguro Social

Proporcione el número de identi�cación de su tarjeta de bene�cios

LEA Y FIRME LA SIGUIENTE DECLARACIÓN

Estoy recibiendo asistencia de: (Marque solamente un programa)

Cupones para alimentos (FS)

Medicaid

Asistencia de la red de protección social

Adjunte una fotocopia de su tarjeta de beneficios.

(No envíe la original)

No envíe documentación original.

(apellido) (primer nombre) (inicial del segundo nombre)

(número) (calle) (número de apartamento, si corresponde)

(ciudad o pueblo) (estado) (código postal)New York

Fax: 212.321.3600Comuníquese con nosotros al: 212.321.3300 www.LifeLineNuevaYork.com

1of 3

Pensión para cónyuges supérstites de veteranos de guerra (SSP),

Pensión por discapacidad para veteranos de guerra

Programa Nacional de Almuerzo Escolar,

ELIJA UN PLAN (Consulte la página 2 para ver los detalles del plan)

Asistencia a la familia

Seguridad de Ingreso Suplementario (SSI)

Programa de Asistencia de Energía para Hogares (HEAP)

Es elegible por los ingresos (IE) pero no está recibiendo los bene�cios. Proporcione pruebas de ladocumentación de ingresos. Consulte el cuadro en la página 3.

Plan A LifeLine Dollar Phone Básico

Paquete de funciones Plus Agregar números privados ($2.95) Plan C LifeLine Dollar Phone EE. UU. Plus

Plan B LifeLine Dollar Phone Local

Método opcional de pago � Master Card � Visa � Discover � Amex � Cheque electrónico

Nombre_________________________________________ N. ° decuenta______________________________________________________________

Fecha de vencimiento________________________________________ Número CVV_______ Número de recorrido del cheque/número ABA_______________________________

1

ENVÍE POR CORREO O POR FAX LA SOLICITUD FIRMADA Y EL COMPROBANTE DE ELEGIBILIDAD A:

Funciones adicionales: _______________________________________________________________________________

Proveedor telefónico actual ______________________________________

DIRECCIÓN Y NÚMERO DE TELÉFONO DEL CLIENTE

Domicilio

Dollar Phone Enterprise, Inc., 232 Broadway, Brooklyn, NY 11211

Carta de autorización: Mediante mi �rma al pie, autorizo a Xchange Telecom Corp a convertirse en mi nuevo proveedor de servicios telefónicos para reemplazar mis servicios de telecomunicaciones actuales en el suministro del servicio local, interurbano (intraLATA), intraestatal (larga distancia) e interestatal de larga distancia. Autorizo a Dollar Phone Enterprise, Inc. y a Xchange Telecom Corp a actuar como mis representantes para efectuar este cambio, e indico a mis servicios de telecomunicaciones actuales que trabajen con el nuevo proveedor designado para realizar el cambio. Comprendo que sólo es posible seleccionar a un proveedor para cada tipo de servicio. Autorizo a Xchange Telecom Corp a suministrar los servicios locales, interurbanos (intraLATA), intraestatales (larga distancia) e interestatales de larga distancia tal como se indica previamente. Certi�co que he leído y comprendo esta Carta de Representación. Asimismo certi�co que tengo dieciocho años de edad o más y que estoy autorizado para cambiar de empresa de telefonía para los servicios de los números de teléfono mencionados.

Cumplimiento de requisitos: Asimismo, certi�co que:. No soy dependiente de otra persona a los �nes de los impuestos federales sobre la renta.. Mi servicio telefónico está registrado a mi nombre.. La dirección que �gura es mi domicilio principal, no una dirección secundaria ni una empresa.. Nadie en mi casa actualmente recibe asistencia de LifeLine a través de otro proveedor telefónico, incluso un proveedor de telefonía celular.. Declaro que se ha incluido toda prueba de ingresos combinados para este hogar. (Consulte el cuadro en la página 3).. Si resulto inelegible para los bene�cios o algunas de las condiciones detalladas anteriormente, me comunicaré inmediatamente con Xchange Telecom, Dollar Phone Enterprise, Inc. y sus subsidiarias y asociadas para informarles que no soy elegible para los servicios de LifeLine.

Términos y condiciones: Certi�co que toda la información anterior es correcta y autorizo a la O�cina de Asistencia Temporaria y Discapacidad de Nueva York, a otros administradores de los programas anteriores, a Xchange Telecom y Dollar Phone Enterprise, Inc., y a sus subsidiarias a intercambiar toda información necesaria para veri�car mi derecho a la tarifa con descuento del servicio LifeLine de Dollar Phone. Comprendo que cuando ya no cumpla los requisitos, si esto ocurre, mi servicio LifeLine de Dollar Phone cambiará a la tarifa residencial regular. Asimismo acepto los términos de servicio publicados en http://www.xchangetele.com/termsofservice.aspx y entiendo que pueden cambiar. En caso de no estar de acuerdo con el cambio, inmediatamente dejaré de utilizar el servicio y me comunicaré con Dollar Phone Enterprise, Inc. Acepto que la continuación del uso del servicio después de la revisión implica la aceptación de dichos términos de servicio. Asimismo acuerdo suscribirme al servicio de limitación de llamadas con tarifa especial de Xchange ("TLS") que bloqueará todas las llamadas con tarifa especial que excedan $_ (si aparece un espacio en blanco, $25.00) por mes. Selecciono el bloqueo de las llamadas con tarifa especial. No opto por TLS.

Firma____________________________________________________ Fecha________/________/________ Identi�cación del agente__________________

(Para Plan A/ Plan B)

Todos los planes incluyen prevención del fraude sin costo. La prevención del fraude evita que su factura de larga distancia tenga cargos adicionales innecesarios controlando sus llamadas a números con tarifa especial. Puede estar seguro de que su factura de llamadas a números especiales nunca excederá el límite que usted �je. A partir de ese límite, un mensaje derivará la llamada a Atención al Cliente para evitar un uso fraudulento.

Page 26: Xchange Telecom Corp.

Productos Complementarios Opcionales de LifeLine Dollar Phone:

Planes y servicios de LifeLine

Planes de New York Metro

*Llamadas locales ilimitadas dentro de su área de llamadas locales.Los planes de LifeLine de Dollar Phone se aplican solamente a una línea por vivienda elegible. El servicio telefónico debe estarregistrado a nombre del solicitante.

Plan ABásico

$1.00/ mes

Plan BLocal

$10.15/ mes

Plan CEE. UU. Plus

$28.60/ mes

$.09/llamada

$.099/minuto

$.069/minuto

$.045/minuto

$1.16estimado conimpuestos

Uso Local

Uso Regional

Uso Intraestatal

Uso InterStatal

Ilimitado

$.099/minuto

$.069/minuto

$.045/minuto

$11.90estimado conimpuestos

Ilimitado

Ilimitado

Ilimitado

Ilimitado

$33.54estimado conimpuestos

Agregar Paquete de funciones por solo $13.95 El Plan C incluye el Paquete

de funciones GRATIS

¡Agregue un Paquete de funciones por solo $13.95

mensuales! El paquete de funcio-nes incluye nuestras cuatro funcio-

nes más populares:

Productos opcionales LifeLine:Mantenimiento de cableado interno $2.49

Buzón de voz $4.95

Paquete de funciones Premium $5.95Buzón de voz Desvío de llamadas*69-Retorno de llamada *66-Rellamada automática

Funciones simples $2.95 (por función) Rechazo de llamadas anónimas con identi�cación Bloqueo del servicio de información telefónica Desvío de llamadas sin respuesta Desvío de llamadas Ultra Desvío de llamadas por línea ocupada Desvío de llamadas variables *69-Retorno de llamada *66-Rellamada automática Marcación rápida 8 Número privado

Identi�cación de llamadas con nombre Llamada en esperaLlamada tripartitaRechazo de llamadas anónimas

Page 27: Xchange Telecom Corp.

· Cupones para alimentos (FS)· Medicaid· Asistencia de la red de protección social· Asistencia a la familia· Seguridad de ingreso suplementario· Programa de asistencia de energía para hogares· Asistencia temporaria para familias necesitadas (TANF)· Pensión para cónyuges supérstites de veteranos de guerra · Pensión por discapacidad para veteranos de guerra· Programa de almuerzo gratuito del Programa Nacional de Almuerzo Escolar

¿Su ingreso doméstico es igual o inferior al 135% del Nivel de Pobreza Federal?

Integrantes de la familia Ingreso mensual bruto

1 $1,2182 $1,6393 $2,0604 $2,4815 $2,9016 $3,3227 $3,7438 $4,164Cada miembro adicional suma $421

Los servicios de LifeLine de Dollar Phone le proporcionan lo siguiente:

· Línea telefónica con descuento mensual.· Sin necesidad de depósito.

Para solicitar el servicio telefónico con descuento, complete la solicitud y envíela junto con el comprobante de elegibilidad. Tiene la obligación de comprobar su elegibilidad cuando se suscribe a servicios de LifeLine.No envíe documentos originales. Con la solicitud, puede enviar una fotocopia de su tarjeta de bene�cios.Si solamente recibe HEAP, envíe una copia de su aviso de aprobación o una copia de una factura reciente de servicios públicos en la que aparezca su bene�cio de HEAP.

La documentación que comprueba los ingresos incluye lo siguiente:

· Copia de su declaración más reciente de impuestos estatales o federales.· Recibos de pago del último mes.· Declaración de bene�cios del seguro social.· Declaración de bene�cios de la Administración de Veteranos de Guerra.· Declaración de bene�cios por desempleo/indemnización laboral.· Una sentencia de divorcio o documentos de manutención de los hijos(no envíe sus originales).

La documentación que comprueba el programa incluye lo siguiente:

· Una fotocopia de su tarjeta de bene�cios (no envíe sus originales).· Una declaración de bene�cios de jubilación/pensión.

3

3 of 3

El servicio de LifeLine de Dollar Phone hace que el servicio telefónico sea accesible para hog-ares de bajos recursos. Si está inscripto en uno de los programas que se detallan a continu-ación, cali�ca automáticamente para inscribirse en uno de nuestros planes telefónicos con descuento.

Servicio de LifeLine por Dollar Phone

¿Qué es el servicio de LifeLine y cómo cali�co?

· Bloque gratuito de los números 900 y 976.· Restricciones a llamadas gratuitas.

Page 28: Xchange Telecom Corp.

Appendix C – Letters from Previous Community Partners

Page 29: Xchange Telecom Corp.

03/22/2010 20:54 7182306770 BPL OLT PAGE 02/02

BrooklynPublicLibrary

March 22,2010

Dear BTOP Grant Proposal Review Committee:

SS^3^5^K35?£S»^.-

salpxborough's largest WiFi network. P access comPute^ and the

1 access and ski:

Sincerely,

Dionne Mack-HarvinExecutive Director

Of'fkc ofrhc Exccurivi- Dirc«or

Grand Army Ptafca

Brooklyn, New York 11238-5619

www.brookljmpubli c\ i btary.org

Page 30: Xchange Telecom Corp.
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March 24, 2010

Mr. Alfred West

President and CEO

Xchange Telecom Corp.

3611 14th Avenue

Suite 215

Brooklyn, NY 11218

Dear Mr. West,

Thank you for informing us of the proposed high-speed broadband access network that

your company, Xchange Telecom Corp., is proposing to construct in Brooklyn, NY. Agudath

Israel of America understands your proposal and supports you in the development of this network.

Agudath Israel of America and its Brooklyn-based community service affiliates provide a

variety of religious, educational, social and charitable services in Flatbush and Boro Park, which

are within your proposed service area. In addition, there are several Agudath Israel synagogues in

these neighborhoods.

Your proposed network would be of great benefit to these Agudath Israel entities and

activities, as well as numerous other charitable organizations, schools and institutions throughout

the proposed service area. The quality of the current broadband service in this area leaves much to

be desired. An enhanced broadband connection will give us the opportunity to provide our

members and service providers with a better system in which to communicate, which would be

critical to their ongoing effectiveness.

It will be our pleasure to work with Xchange as you partner with other Community

Anchor Institutions on a coordinated request for funding in support of this network proposal to the

Broadband Technology Opportunities Program of the National Telecommunications and

Information Administration. Please feel free to contact us for any information you may need to

support our participation in this effort.

Sincerely,

Rabbi David Zwiebel

Executive Vice President

RDZ/bp

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03/15/2010 10:53 718-8728901 PSC HEAD START PAGE 02/02

PROJECT SOCIAL CARE HEAD START, 1NC,

590214Ave.« Brooklyn,NYH219. Phone:718-871-3100. Fax:718-871-8901

Alfred West

President and CEO

Xchange Telecom, Corp.

3611 14m Avenue,

Suite 215,

Brooklyn, NY 11218

Dear Mr. West,

This letter of support is in reference to the proposed high-speed broadband

access network that your company, Xchange Telecom Corp., is planning to constructin Brooklyn, NY. Project Social Care Head Start understands what you are proposingand supports you in this project which will greatly assist the schools, libraries, Medicaland healthcare providers, public safety entities, community colleges and other

institutions of higher education, and other community support organizations in Brooklyn.

Project Social Care Head Start mission is to provide quality, comprehensive early child

development programs and family services to meet the needs of children and families

from three through five years of age in Brooklyn.

Your proposed network will greatly facilitate Project Social Care Head Start's

activities. We currently need a high-speed connection to the Internet to conduct

research in the various aspects of the continuously updated regulations of Head Start.

The current "broadband" provider in our area, Verizon, provides a level of service that is

insufficient for our needs.

We wish to work with your company as you partner with other Community

Anchor Institutions on a coordinated request for funding in support of this network

proposal to the Broadband Technology Opportunities Program (BTOP) of the National

Telecommunications and Information administration (NTIA). We will provide information

necessary to support our participation in such an effort, including information about

current broadband capacity, spending on broadband services, current proposed

network intensive projects, and current contractual commitments.

PTiilip Klein

Executive Director

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TVH

cSznLox Ultlzzm

817 c^TtuE-nus. c?T

Bxootyn, JVflf. 11230

(718) 434-867O

Alfred West

President and CEO

Xchange Telecom, Corp.

3611 14th Ave.Suite 215

Brooklyn, NY 11218

Dear Mr. West,

This letter is in reference to the proposed high-speed broadband access network that

Xchange Telecom Corp. is planning to construct in Brooklyn, NY. Brookdale Senior

Center understands what you are proposing and supports you in the development of a

community-wide high-capacity broadband network proposal serving schools, libraries,

medical and healthcare providers, public safety entities, community colleges and other

institutions of higher education, and other community support organizations. Brookdale

Senior Center is a daytime facility where seniors congregate for lunch, activities and day

trips.

Your proposed network will greatly facilitate Brookdale Senior Center's activities. We

currently use a high-speed connection to the Internet for our government program.

We wish to work with your company as you partner with other Community Anchor

Institutions on a coordinated request for funding in support of this network proposal to

the Broadband Technology Opportunities Program (BTOP) of the National

Telecommunications and Information Administration (NTIA). We will help provide any

information necessary to support our participation in such an effort.

Sincerely,

Rabbi Aron Heineman

Director

Oi.xas.L of c^j-

tL tJVljC 2>efit. fox tL

Page 37: Xchange Telecom Corp.
Page 38: Xchange Telecom Corp.

Appendix D – Current Xchange Compliance with Eligibility Rules

Page 39: Xchange Telecom Corp.

Please complete and sign page 1.

currently receiving assistance for or proof of household income.

You may then submit these to Xchange for processing by:

Fax: 718 663 0202

Mail:Lifeline ServicesXchange TelecomP.O. Box 190433Brooklyn, NY 11219-0433

E-mail: [email protected]

IMPORTANTPlease complete and sign page 1.

In addition, please make a copy of either your bene�t card or for the program you arecurrently receiving assistance for or proof of household income.

Xchange is responsible for ensuring that USAC, the administrator of the Federal Lifeline Program, has the necessary information required to determine your continued eligibility. This information includes:

. Your Name and Residential Address,

. Your Telephone Number,

. The last four digits of your Social Security Number

. The program based on which you are claiming eligibility, and if income eligibility is being claimed.

You may then submit these to Xchange for processing by:

Fax: 718 663 0202

Mail:Lifeline ServicesXchange TelecomP.O. Box 190433Brooklyn, NY 11219-0433

E-mail: [email protected]

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NEW SERVICE APPLICATION FOR XCHANGE TELECOM LIFELINE

(DISCOUNTED TELEPHONE SERVICE)

Name of Applicant

Home Address

My home telephone number(Include area code)

(_____) ______-___________

Telephone number where I can be reached to arrange service(_____) ______-___________

Please provide your Social Security Number

Please Choose One:

Signature____________________________________________________ Date________/________/________ Agent ID: ____________________________

MAIL OR FAX SIGNED APPLICATION AND PROOF OF ELIGIBILITY TO:

PLEASE READ AND SIGN THE FOLLOWING STATEMENT

Medicaid

Food Stamps (FS)

Safety Net Assistance

Attach a photocopyof your benefit card.Do not send original.

(Last) (First) (Middle initial)

(Number) (Street) (Apartment number if applicable)

(City or town) (State) (Zip code)New York

Billing Address(Number) (Street) (Apartment number if applicable) (City or town) (State) (Zip code)

Fax: 718.663.0202Contact Us: 718.705.9900 Email: [email protected] www.BigTalkNY.comLifeline Services Xchange Telecom P.O. Box 190433 Brooklyn, NY 11219-0433

Veteran’s Surviving Spouse Pension (SSP)

Veteran Disability Pension

National School Lunch Program

Letter of Authorization: My signature below authorizes Xchange Telecom Corp to become my

new telephone service provider in place of my current telecommunications utility (ies) for the

provision of local, local toll (intraLATA), intrastate (long distance), and interstate long distance services.

I authorize Xchange Telecom Corp to act as my agent to make this change happen, and direct my

current telecommunications utility (ies) to work with the new provider designated above to e�ect the

change. I understand that only one provider may be selected for each service type. I authorize Xchange

Telecom Corp to provide local, local toll (intraLATA), intrastate (long distance), and interstate long

distance services as indicated above. I certify that I have read and understand this Letter of Agency. I

further certify that I am at least eighteen years of age, and that I am authorized to change telephone

companies for the services to the telephone numbers listed above.

Family Assistance

Supplemental Security Income (SSI)

Home Energy Assistance Program (HEAP)

Income Eligible (IE) but not receiving bene�ts. ____ number of individuals in my household Please �ll out proof of income documentation. See eligibility requirements on page 3.

AUTOPAY DISCOUNT Master Card Visa Discover Amex e-Check

Name_________________________________________ Account#________________________________________________________

Exp. Date____________________ CVV Number_______ Check Routing Number/ABA Number_________________________________(For e-check only)

Add Non-Published ($2.95)

Check here to select e-billing through your email address for an additional $0.50 monthly discount!

Additional Features________________________________________________________________________________________________________________

Current Telephone Provider _____________________________________________E-mail_____________________________________________

How did you hear about us? __________________________________

Plan C LifeLine BIGtalk USAPlan A LifeLine BIGtalk Local Plan B LifeLine BIGtalk MetroPLEASE CHOOSE ONE PLAN.

(SEE RATE SHEET)

QUALIFICATIONS

CUSTOMER ADDRESS &

PHONE NUMBER

OPTIONAL PAYMENT METHOD

Certi�cation of Eligibility: Additionally I Certify, under penalty of perjury, that:. I understand that Lifeline is a federal bene�t and that willfully making false statements to obtain the bene�t can result in �nes, imprisonment, de-enrollment or being barred from the program. I am not claimed as another person’s dependent for federal income tax purposes.. My telephone service is listed in my name.. The address listed is my primary residence, not a secondary home or business.. My household will receive only one Lifeline service, and that, to the best of my knowledge, no one in my household currently receives lifeline support through another phone carrier including a cell phone provider. I further understand and acknowledge that violation of this one-per-household limitation constitutes a violation of the FCC’s rules and will result in my de-enrollment from the lifeline program.. I declare that that all combined income proof for this household has been included. If I become ineligible for bene�ts or any of the conditions listed above change, I will immediately contact Xchange Telecom within 30 days to let them know I am no longer eligible for LifeLine Services.. If I change my address, I will provide Xchange Telecom with a new address within 30 days. If I provided a temporary address above, I will provide Xchange Telecom with a veri�cation every 90 days of my temporary address. I understand that Lifeline is a non-transferable bene�t and that I cannot transfer the bene�t to any other person.. The information contained in my subscription for is true and correct, to the best of my knowledge,. If I am qualifying on behalf of a dependent or member of my household, I certify that the person whose bene�t card is attached is my dependent or a member of my household. That I can be required to recertify my eligibility at any time, and that my failure to recertify will result inde-enrollment and termination of my lifeline benets.

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1

(Includes Feature Pack)(Includes Feature Pack)(Includes Feature Pack)

RVSN: 05232012

To get up to $1.50 o� your bill!

Pursuant to Heter Iska

I A member of my household My dependent (If a dependent or member of household, please indicate name: ___________________________ )

am/is receiving assistance from: (Check only one program)

D.O.B / /

The address stated above is my: Permanent Address Temporary Address

Terms & Conditions: I certify that all the above information is correct and I authorize the New York O�ce of Temporary and Disability Assistance, other agencies administrating the above programs and Xchange Telecom, its subsidiaries to exchange any information necessary to verify my eligibility for the discounted rate Xchange LifeLine Service. I understand that if/when I am no longer eligible, my Xchange LifeLine Service will be changed to the regular residential rate.I further agree to be bound by the terms of service posted at http://www.xchangetele.com/termsofservice.aspx. I understand that they are subject to change. If I do not agree with the change, I will immediately cease use of the service. I agree that my continued use of the service after revision is an acceptance of those terms of service.I further agree to subscribe to Xchange's toll limitation service ("TLS") which will block all toll calls over $_ (if left blank, $25.00) a month I elect toll blocking I opt out of TLSIf I selected e-billing above, I agree to accept any bills and other correspondence sent to the email address that I provide above or any other email address that I provide as if it was physically mailed to me. If I would like to opt out of e-bill, I understand that I must contact Customer Service.

Billing Address (if di�erent than home address)

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LifeLine BIGtalk Metro

Plan B

LifeLine BIGtalk Plans And Services

*Unlimited Local calls within your local calling areaXchange LifeLine plans apply to only to one line per eligible household. Telephone service must be listed in the applicant’s name.Price re�ects e-bill discount of $0.50, Autopay discount ($0.50 for BigTalk Local and Metro, $1.00 for Bigtalk USA), and $2.00/month new customer discount. New Customer discount expires after one year of service. One year service contract required, early termination fees may apply. Territorial restrictions apply. Free minutes are a promotion, and may be discontinued.**Free international minutes are limited to Western Europe and Israel 2

2 of 3

LifeLine BIGtalk USA

Plan C UnlimitedUnlimitedUnlimitedUnlimited

Monthly Charge

INCLUDES ALL TAXES & FEES

Monthly Charge

New York Metro Plans

Local Usage:Regional Usage:Intrastate Usage:Interstate Usage:

Local Usage:Regional Usage:Intrastate Usage:Interstate Usage:

Plan B includes FREE Feature Pack

Plan A includes FREE Feature Pack

LifeLine BIGtalk Local

Plan AMonthly Charge

$24.99*

Local UsageRegional UsageIntrastate UsageInterstate Usage

Unlimited$.099/min0.0690.045

UnlimitedUnlimited0.0690.045

Plan C includes FREE Feature Pack PLUS 200 Free International Minutes**

Feature Pack Includes OurSix Most Popular Features:

Optional LifeLine Add-Ons:Inside Wire Maintenance $2.49

VoiceMail $4.95

Premium Feature Package $5.95 Voicemail Call Forwarding

Single Features $2.95 (per feature) Anonymous Call Rejection with ID Directory Assistance Block Call Forward No Answer Ultra-Call Forward Call Forward Busy Call Forward Variable Speed Dial 8 Non-Published

BIGtalk Plan Add Ons

CallerID w/Name Call Waiting3-Way CallingAnonymous Call Reject *69-Call Return *66-Repeat Dial

As Low As:

INCLUDES ALL TAXES & FEES$23.99*As Low As:

INCLUDES ALL TAXES & FEES$27.99*

$31.49

$27.99

$26.99

As Low As:

Unlimited Local, Regional,

& USA Calling

Unlimited Local & Regional Calling

Unlimited Local Calling

*Available Discounts:-$2.00 : New Customer Sign-Up Bonus

( First 12 Months )-$0.50 : AutoPay Discount

-$0.50 : E-Bill Discount

*Available Discounts:-$2.00 : New Customer Sign-Up Bonus

( First 12 Months )-$1.00 : AutoPay Discount

-$0.50 : E-Bill Discount

*Available Discounts:-$2.00 : New Customer Sign-Up Bonus

( First 12 Months )-$0.50 : AutoPay Discount

-$0.50 : E-Bill Discount

All plans include BIGtalk fraud prevention at no charge. Fraud prevention prevents your long distance bill from unnecessary cost overruns by monitoring your toll calls. You can rest assured that your toll bill will never exceed the limit you set. After the limit is reached, a message will route the call to Customer Service to prevent fraudulent use.

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· Food Stamps (FS)· Medicaid· Safety Net Assistance· Family Assistance· Supplemental Security Income· Veteran’s Surviving Spouse Pension · Veteran Disability Pension· Home Energy Assistance Program· Temporary Assistance for Needy Families (TANF)

· National School Lunch Program's free lunch program

Is your household income at or below 135% of the Federal Poverty Level?

Household Size Gross Monthly Income1 $1,2182 $1,6393 $2,0604 $2,4815 $2,9016 $3,3227 $3,7438 $4,164Each add’l member add $421

Xchange LifeLine Services Provides You With:

· Monthly discounted phone line· No Deposit Required

To apply for the discounted phone service, please complete the application and return it along with your proof of eligibility. You are required to prove your eligibility when subscribing to LifeLine services. Do not send original copies. You may send in a photocopy of your bene�ts card with the application. If you only receive HEAP, please send a copy of your approval notice or a copy of a recent utility bill showing your HEAP bene�t.

Proof of Income Documentation Includes:

· Copy of your most recent federal or state tax return· Pay stubs from the last month· Social security statement of bene�ts· Veteran Administration statement of bene�ts· Unemployment/Worker’s Compensation statement of bene�ts· A divorce decree or child support documents (Do not send your original)

Proof of Program Documentation Includes:

· A photocopy of your bene�t card. (Do not send your original)· A retirement/pension statement of bene�ts

3

3 of 3

Xchange LifeLine service makes phone service a�ordable for low income households. If you are enrolled in one of the programs listed below, you automatically qualify to enroll in one of our discounted phone plans.

What is LifeLine Service and How Do I Qualify?

· Free Blocking of 900 and 976 Numbers· Free Toll Restrictions

LifeLine BIGtalk Service By Xchange Services

Please remember:(i) Lifeline is a federal bene�t. Willfully making false statements to obtain the bene�t can result in �nes, imprison-ment, de-enrollment or being barred from the program;(ii) Only one Lifeline service is available per household;(iii) A household is de�ned, for purposes of the Lifeline program, as any individual or group of individuals who live together at the same address and shareincome and expenses;(iv) A household is not permitted to receive Lifeline bene�ts from multiple providers;(v) Violation of the one-per-household limitation constitutes a violation of the Commission’s rules and will result in the subscriber’s de-enrollment from the program; and(vi) Lifeline is a non-transferable bene�t and the subscriber may not transfer his or her bene�t to any other person.

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To whom it may concern,

I am hereby affirming, under penalty of perjury, that my household monthly income is $______________, and that neither myself, my dependents, nor a member of my household are currently enrolled in any of the programs needed to qualify for Lifeline. With the income stated above, I am eligible for Lifeline home telephone service from Xchange Telecom.

I Certify that I have ___ members in my household.

To prove my eligibility, I have attached one of the following documents:

_ Prior year's state, federal, or Tribal tax return_ Current income statement from an employer or paycheck stub (please attach 3 months)_ Social Security statement of benefits _ Veterans Administration statement of benefits_ Retirement/pension statement of benefits

I understand that if/when I am no longer eligible, my Xchange LifeLine Service will be changed to the regular residential rate.

I also give Xchange Telecom the right to access my tax records if required.I further agree to be bound by the terms of service posted at http://www.xchangetele.com/termsofservice.aspx. I understand that they are subject to change. If I do not agree with the change, I will immediately cease use of the service. I agree that my continued use of the service after revision is an acceptance of those terms of service.

I attest that the information contained in my application and this letter is true and correct to the best of my knowledge and I acknowledge that providing false or fraudulent information to receive Lifeline benefits is punishable by law.

Print Name:___________________________ Date:____________

Signature:____________________________

_ Unemployment/Workers' Compensation statement of benefit_ Federal or Tribal notice letter of participation in General Assistance_ A divorce decree, child support award, or other official document containing income information.

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Appendix E – Transition Letter to Subscribers

[NAME]

[Account Number]

[ADDRESS BLOCK]

[DATE – at least 45 days before end of program]

Re: Lifeline Broadband Transition

IMPORTANT NOTICE – DO NOT DISCARD

Dear Xchange Customer,

As you are aware, you signed up to be a participant in Xchange’s pilot program with the FCC to

test Lifeline Broadband discounts. The pilot is ending on [pilot end date], and your discount will

end at that time.

We will be transitioning into the new discount approved by the FCC, for [$ amount of FCC

broadband discount]. During the transition period, which will end by [date when FCC discount

will be offered], we will provide you with the new discount as a courtesy for up to three months.

Unless you contact us, we will make no changes to your account other than the discount. If you

want to change your service, please contact us M-Th, 8AM-9PM, and Fr 8AM-4PM, by calling

us at (877) 353-3443.

Sincerely,

Xchange Customer Service

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Appendix F – CVs

MGross
Typewritten Text
Micheline Blum Micheline Blum is Distinguished Lecturer and Director of Baruch College Survey Research, overseeing all BCSR surveys for the School of Public Affairs. An expert in public opinion research, Ms. Blum is also the President of the New York Chapter of the American Association for Public Opinion Research. Baruch College Survey Research has conducted many large and complex surveys, including public opinion surveys of New York City, New York State, Connecticut and Chicago, and targeted surveys of , public housing residents, executive Directors of Non-Profit Organizations, potential employers of Professional Science Masters graduates, National Urban Fellows alumni over 40 years, CUNY employees, and CUNY students. BCSR clients include the New York City Department of Health and Mental Hygiene, the New York City Housing Authority, the Institute for Children, Poverty and Homelessness, NY1 News, the United Jewish Appeal, National Urban Fellows, Hunter College School of Public Health, the Human Services Council, the Campaign Finance Institute, New Yorkers for Parks, the New York State Department of Health, and the Long Island-Hudson Valley Anti-Tobacco Coalitions. As an expert in questionnaire design and public opinion polling, Ms. Blum has taught the NYAAPOR “Meet the Masters” question writing workshop for survey researchers, published invited “Ask the Experts” election polling analysis in AAPOR’s online publication, Survey Practice, served on the national AAPOR Council and is an elected member of the Market Research Council. Ms. Blum appears frequently on TV as a polling and election analyst, including as a regular panelist for WPIX News Close-Up on Sunday mornings. She was the NY1 pollster for 13 years and has moderated and presented at many public forums and professional conferences. As President of Blum & Weprin, her clients included NY1, The Daily News, The Dallas Morning News, Newsday, NBC News, The New York Times Magazine, The Star-Ledger, the New York Yankees, the NY State Dept. of Health, Public Agenda, Yale University and the National and NY Urban Leagues. Before founding her own firm, Ms. Blum was Manager of Polling & Election Operations at NBC News for eleven years. Ms. Blum teaches Research and Analysis in the MPA program and recently established a new undergraduate minor in Survey Research, for which Principles of Survey Research and Public Opinion and Public Policy. She is also a member of the CUNY Institutional Review Board. Her M.A. and certification toward a Ph.D. in Psychological Measurement, Evaluation and Statistics are from Teachers College, Columbia University. David Birdsell, Dean of the Baruch College School of Public Affairs, has centered his academic work on the nexus of communication, media, and information technology in politics, government and nonprofit administration. He studies public access to information technology and advises nonprofit and governmental institutions on their communication and technology programs. His recent work on developing public sector leaders has led to the creation of more than 20 leadership programs offered in partnership with government and nonprofit organizations in New York. An expert on political debating and widely published on communication theory and practice, David is a regular guest commentator on debates and other aspects of political communication for local, national, and international television and print media. His work has been supported by the Pew Charitable Trusts, the IBM Endowment for the Study of Business and Government, the Lyndon Baines Johnson Foundation, the New York Community Trust, the JPMorganChase Foundation, the United Way of New York City, the Markle Foundation, and other funders. David serves on the New York City Broadband Advisory Committee, chairs the board of VCG Governance Matters, and is on the board of the New York Census Research Data Center. He is a member of the National Association of Schools of Public Affairs and Administration’s Executive Council and chairs that organization’s Data Committee. He received his BA and MA degrees from the University of Virginia and his Ph.D. in Public Communication from the University of Maryland.
MGross
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MGross
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BLUM, MICHELINE

EDUCATION:

Teachers College, Columbia University Teachers College, Columbia University

Psychological Measurement, Evaluation & Statistics Psychology

All but dissertation, Ph.D. program MA

1976-1979 1976

Connecticut College New York University

Sociology BA Credits toward BA

1967

ACADEMIC EXPERIENCE

Distinguished Lecturer,School of Public Affairs, September 2007- present

Baruch College, CUNY

Current Courses: Research and Analysis II (PAF9172); Principles of Survey Research(PAF 3105); Public Opinion, Public Policy and Management (PAF 3106)

PROFESSIONAL EXPERIENCE:

Director, Baruch College Survey Research,

School of Public Affairs, Baruch College, CUNY September 2007-present

Oversee all BCSR surveys, BCSR staff, 30 telephone CATI center, proposals, budgets, questionnaire construction, project management, data analysis, reports and presentations.

Design,direct and analyze telephone, online, mail, intercept and mixed-mode surveys for government agencies, nonprofit organizations, media and academic partners on wide range of public affairs topics.

Recent clients/projects: NYC DOHMHClean Air Survey;CUNY Student Surveys; Baruch NYC Poll: NYPD; DOHMH Restaurant GradingPolls;CUNYFirst Employee Surveys; DOHMH HIV, Testing, Sex Practices Poll; DOHMH Heat Warning/Behavior Survey,Long Island/Hudson Valley Smoking Surveys; CUNY PSM Employer Survey; Baruch NYC Poll: Immigration; Inst. for Children, Poverty & Homelessness NYC & Chicago polls; NYCHA Resident Surveys; NY1 News polls.

President, Blum &Weprin Associates, Inc. 1990-present

Designed, directed, and analyzed 500+ surveys. Oversee all aspects of public opinion research. Specialize in polling for media and non-profit clients. Clients include: Dallas Morning News; NY1 News; Daily News; New York Times; NBC News; Star-

Ledger; Public Agenda; Newsday; New York Yankees, Yale University, NY State and NYC agencies Manager, Polling & Election Operations, NBC News Election Unit 1979-1990

Directed operation of telephone and exit polling for NBC News, including monthly NBC News/Wall Street Journal polls, all pre-primary, pre-election and exit polls.

Oversaw all sampling, data collection,and poll and election operations. Hired/managed5FT and 200 PTin-house staff, plus up to 5000 exit poll/vote reporters; responsible for multimillion dollar budgets.

Editor, Psychological Corporation, Harcourt Brace Jovanovich 1978-1979

Wrote, selected and edited test items, manuals and directions for abilities and achievement tests. Performed statistical item analyses, normed test data, prepared technical data. Alexander G. Wesman Fellow, Teachers College, Columbia University / 1977-1978

Psychological Corporation, Harcourt Brace Jovanovich

Wrote/editeditems forabilities, and intelligence tests& wrote chapter test items for HBJ textbooks. Senior Research Assistant, National Science Foundation Jury Project,

Bureau of Applied Social Research, Columbia University 1974-1976

Managed jury study:supervised 5 assistants, hired lawyers, judges, recruited 1000 jurors in Queens

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MICHELINE BLUM 2

Experimental design, questionnaire, attitude scale construction, data analysis. Designed measure to analyze jury deliberations; presented findings to NSF, May 1975.

PUBLICATIONS:

Blum, M. (2008). “Evaluating the 2008 Pre-Election Polls and Examining the ‘Convergence Mystery,'” The Experts Reply to the Poll Convergence Mystery. Survey Practice/ American Association for

Public Opinion Research(December 2008). www.surveypractice.org Blum, M. (2001)."State of Black America" (pp. 43-64 and 218-220). The State of Black America

2001/National Urban League Publication. Blum, M. (1994)."Four Pollsters Discuss 1994 Elections and Public Opinion (pp. 78-82). America at the

Polls 1994/Roper Center publication. Blum, M., Muzzio, D. "NYCHA Satisfaction and Perception Survey of Public Housing and Section 8

Residents"(2010). NYC: Sponsored by New York City Housing Authority. Krauskopf, J., Blum, M., Litwin,R., Hughes, J. & Browne, A. “The Helpers Need Help:New York City’s

Nonprofit Human Service OrganizationsPersevering in Uncertain Times”(2009).Sponsored by Human Services Council of New York City

Smith, R., Blum, M. National Urban Fellows (NUF) 40th Anniversary Alumni Survey: “The Changing

Face of Public Service Leadership"(2009). PRESENTED PAPERS, LECTURES, PANELS, PUBLIC APPEARANCES:

Blum, M., Muzzio, D., Kim, M., Mantsios, A., Tsoi, B. “Sex Practices, HIV, and the Knowing-Doing Gap: A Survey of New York City Adults,” American Association for Public Opinion Research Conference, Orlando, FL, May 18, 2012.

Blum, M., Pollster and Election analyst: NY1 News 1997-2010. Blum, M., Political, Polling and Election Analyst: WPIX/CW11 News Close-UP : 2004-Present Blum, M., “Meet the Masters,” NYAAPOR, “You Get What You Ask For: Asking Good Questions.”

Invited: 2004, 2008. American Association for Public Opinion Research, National Conference, Session Chair, 1997-2010. OFFICES HELD IN PROFESSIONAL SOCIETIES AND RELATED POSITIONS

President, American Association for Public Opinion Research, New York Chapter, 2012-2013

IRB Member, Baruch and CUNY IRBs, September 2010 - Present. RELATED PROFESSIONAL ACTIVITIES

Baruch College Survey Research has conducted many large and complex surveys , including public opinion surveys of New York City, New York State, Connecticut and Chicago, and targeted surveys of executive Directors of Non-Profit Organizations, potential employers of Professional Science Masters graduates, public housing residents, National Urban Fellows alumni over 40 years, CUNY employees, and CUNY students. Sampling is supervised by Professor Martin Frankel.

Related BCSR surveys include: -Two mixed mode (online/telephone) surveys of 1000 CUNY students each in 2010 and 2012; -Online survey of purposive sample of potential NY area employers in 2011 -Telephone surveys of 1000-1600 NYCHA residents in 2010, 2011, 2012,. -Mixed mode(email, mail, telephone) survey of 400 National Urban Fellows alumni. -Online survey of 244 executive directors of social service non-profit organizations. -Large public opinion polls: 2500 NYC for DoHMH 2011; 3600-4500 in 9 NY counties 2008-2011

Blum & Weprin conducted 500+ polls plus many targeted surveys of businesses, municipalities, public officials, insurance agents, physicians, economists, Republican and Democratic national convention delegates

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David S. Birdsell 69 W. 9th Street, Apt. 5-B, New York, NY 10011-8958

Voice: 212-674-4301, E-mail: [email protected] EDUCATION Ph.D. in Public Communication, University of Maryland, 1986 MA in Speech Communication, University of Virginia, 1981 BA in History, University of Virginia, 1979

FULL-TIME ACADEMIC EMPLOYMENT

Baruch College, Dean, School of Public Affairs, 2006-Present Baruch College, Interim Dean, School of Public Affairs, 2005-2006 Baruch College, Executive Director of Academic Programs, School of Public Affairs, 1999-2005 Baruch College, Professor of Public Affairs, 1999-Present Baruch College, Associate Professor of Public Affairs, 1994-1998 Baruch College, Associate Professor of Speech, 1991-1994 Baruch College, Assistant Professor of Speech, 1986-1990 University of Virginia, Lecturer in Speech and Director of Forensics, 1981-1983

SELECTED CONSULTANCIES

New York Public Library, Institutional Research and Communication Technology, 1996-2005 New York Lawyers for the Public Interest, Communication Strategy, 2001-2006 Congressional Management Foundation, Capitol Hill Communication, 1984-2005 Bayer Center for Nonprofit Management, Improving Nonprofit Consulting, 2003-2004 Brooklyn Public Library, Patron and Staff Education for Online Research, 1998-2000, 2004 United States Information Agency, Political Debating, 1996-1998 Advice, Research and Reviews for the Carnegie Corporation, Clark Foundation, Markle Foundation, and New York Community Trust

PUBLICATIONS AND PRESENTATIONS

Books

The McGraw-Hill Guide to Presentation Graphics (New York: McGraw-Hill, 1997).

Carol Winkler, William Newnam, and David S. Birdsell, Lines of Argument: Core Volume (Dubuque: Brown and Benchmark, 1993).

Carol Winkler, William Newnam, and David S. Birdsell, Lines of Argument for Policy Debate (Dubuque: Brown and Benchmark, 1993).

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David S. Birdsell Page 2 of 15

Carol Winkler, William Newnam, and David S. Birdsell, Lines of Argument for Value Debate (Dubuque: Brown and Benchmark, 1993).

Kathleen Hall Jamieson and David S. Birdsell, Presidential Debates: The Challenge of Creating

an Informed Electorate (New York: Oxford University Press, 1988).

Journal Articles David S. Birdsell and Leo Groarke, “Outlines of a Theory of Visual Argument,” Argumentation

and Advocacy, 43 (Winter & Spring 2007), 103-113. David S. Birdsell, “George W. Bush’s Signing Statements: The Assault on Deliberation,” Rhetoric and Public Affairs, 10, 2 (Summer 2007), pp. 335-360. The Racine Group (David S. Birdsell, Diana P. Carlin, Shawn Parry-Giles, Edward Hinck, Kathleen Kendall, Michael Leff, Kathryn Olson, Michael Pfau and David Zarefsky), “The Future of Research on Presidential Debates,” Argumentation and Advocacy, (Fall 2002), pp. 1-28. David S. Birdsell, Douglas Muzzio, David Krane, and Amy Cottreau, “Web Users are Looking More Like America,” Public Perspective (April/May 1998), pp. 33-35. Douglas Muzzio and David Birdsell, “The 1996 ’Net Voter,” Public Perspective (December/January 1997), pp. 44-45.

David S. Birdsell and Leo Groarke, “Toward a Theory of Visual Argument,” Argumentation

and Advocacy, 33 (Summer 1996), pp. 1-10.

David S. Birdsell, Douglas Muzzio, Humphrey Taylor, and David Krane, “A New Political Marketplace: The Web Snares Voters,” Public Perspective (June/July 1996), pp. 33-36.

“Kenneth Burke at the Nexus of Argument and Trope,” Argumentation and Advocacy, 29 (Spring 1993), 178-185.

“Beyond the Debate Analogy,” Argumentation and Advocacy, 27 (Winter 1991), 97-99.

“Ronald Reagan on Lebanon and Grenada: Flexibility and Interpretation in the Application of Kenneth Burke's Pentad,” Quarterly Journal of Speech, 73 (1987), 267-279; also published in Bernard L. Brock, Robert L. Scott and James W. Chesebro, eds., Methods of Rhetorical

Criticism: A Twentieth-Century Perspective, 3/e (Detroit: Wayne State University Press, 1990), and in Carl R. Burgchardt, Readings in Rhetorical Criticism (State College, PA: Strata Publishing Company, 1995), 227-239.

Refereed Proceedings

“Using All There is to See: A Response to Mark Vorobej,” Proceedings of the Fourth Biennial Conference of the Ontario Society for the Study of Argumentation, CD-ROM, 1998.

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David S. Birdsell Page 3 of 15

David S. Birdsell, Douglas Muzzio, Richard Treitman, Kevin Shin Ogino, and Kevin Cancienne, “Using the World Wide Web to Facilitate Course-Related Communication,” Proceedings of the

1997 Ed-Media/Ed-Telecom Conference (Charlottesville, VA: Association for the Advancement of Computing in Education, 1997), 2034-2037, CD-ROM.

“Argumentation in Urban Public and Not-for-Profit Management,” in Sally Jackson and Scott Jacobs, eds., Proceedings of the Ninth Biennial SCA/AFA Conference on Argumentation (Annandale: The Speech Communication Association, 1996), pp. 71-74.

“Enthymemes in Intermediated Public Argument,” in Frans H. van Eemeren, Rob Grootendorst, J. Anthony Blair and Charles A. Willard, eds., Proceedings of the Third International

Conference on Argumentation Analysis and Evaluation Vol. II (Amsterdam: SicSat, 1995), pp. 158-167.

“An Enthymematic Approach to Response and a Responsive Approach to Enthymemes,” in Raymie McKerrow, ed., Argument and the Postmodern Challenge: Proceedings of the Eighth

Biennial SCA/AFA Conference on Argumentation (Annandale: SCA, 1993), 162-165.

“Thinking Globally, Acting Locally: A Response to Muir, Harris and Depoe,” in Donn W. Parson, ed., Argument in Controversy: Proceedings of the Seventh Biennial SCA/AFA

Conference on Argumentation (Annandale: SCA, 1991), 342-44.

“Critics and Technocrats,” in Bruce Gronbeck, ed., Spheres of Argument: Proceedings of the

Sixth Biennial SCA/AFA Conference on Argumentation (Annandale: SCA, 1989), 16-19.

Herbert W. Simons and David S. Birdsell, “What if Arguers Could as Easily Show as Tell?” in Bruce Gronbeck, ed., Spheres of Argument: Proceedings of the Sixth Biennial SCA/AFA

Conference on Argumentation (Annandale: SCA, 1989), 296-300.

Chapters in Books

“Political Debates,” in Kathleen Hall Jamieson and Kate Kenski, eds., The Oxford Handbook of

Political Communication (New York: Oxford University Press), in preparation. “Kathleen Hall Jamieson,” in Nancy Signorielli, ed., Women in Communication (Westport: Greenwood Press, 1996), pp. 228-235.

“The Technologies of Relatedness,” in Julia T. Wood and Richard B. Gregg, eds., The Future of

the Field (Cresskill, NJ: Hampton Press, 1995), pp. 81-100. “What Should Debates Be? Standards of Public Discourse,” in Arthur H. Miller and Bruce E. Gronbeck, eds., Presidential Campaigning and America's Self Images (Boulder: Westview Press, 1994), pp. 128-142.

“Carrie Lane Chapman Catt,” in Karlyn Kohrs Campbell, ed., Women Public Speakers in the

United States, 1800-1925 (Westport: Greenwood Press, 1993), 321-338.

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Government and Foundation Papers

David S. Birdsell and Douglas Muzzio, “Small Business Resource Center Final: National Telecommunications and Information Administration Technology Opportunities Program Grant Evaluation,” (New York Public Library, September 2006) David S. Birdsell and Douglas Muzzio, “Small Business Resource Center Wave 3: National Telecommunications and Information Administration Technology Opportunities Program Grant Evaluation,” (New York Public Library, July 2006) David S. Birdsell, “Funding for Civic Engagement Programs in New York City: Types of Programs, Patterns of Support, and Comparisons with National Efforts” (New York Community Trust, March 2005). David S. Birdsell and Douglas Muzzio, “The Science, Industry and Business Library’s ‘SmallBiz’: Demand for Small Business Services in New York City (New York Public Library/Technology Opportunities Program of the National Telecommunications and Information Administration, January 2005). David S. Birdsell and Douglas Muzzio, “The Next Leaders,” (United Way of New York City, October 2003). David S. Birdsell and Douglas Muzzio, “Bridging the Digital Divide: Click on @ the Library Workshop Participant Survey,” Wave 3 (New York Public Library/Picower Foundation: January 2003). David S. Birdsell and Douglas Muzzio, “Bridging the Digital Divide: Click on @ the Library Workshop Participant Survey,” Wave 2 (New York Public Library/Picower Foundation: July 2002). David S. Birdsell and Douglas Muzzio, “Bridging the Digital Divide: Click on @ the Library Workshop Participant Survey, Wave 1 (New York Public Library/Picower Foundation: January 2001). David S. Birdsell and Douglas Muzzio, “Branch Library Survey, 2001,” (New York Public Library: December 2001). David S. Birdsell and Douglas Muzzio, “Characteristics, Habits, and Opinions of Patrons Using the Research Collections of the New York Public Library,” (New York Public Library, December 2000). David S. Birdsell, Rapporteur’s Report, Markle Foundation Conference on Universal Access, February 11, 1999. Available online at http://www.markle.org/news/proj_index.html

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David Birdsell and Douglas Muzzio, “Universal Service Baselines,” Research Paper prepared for the Markle Foundation’s Conference on Internet Access, February 11, 1999. Available online at http://www.markle.org/news/proj_index.html David Birdsell and Douglas Muzzio, “Government Programs Involving Citizen Access to Internet Services,” Research Paper prepared for the Markle Foundation’s Conference on Internet Access, February 11, 1999. David S. Birdsell, “Universal Service Scenarios: New York Stories,” Research Paper prepared for the Markle Foundation’s Conference on Internet Access, February 11, 1999.

David S. Birdsell and Herbert W. Simons, “Basic Research Goals: A Comparison of Political Ideologies,” Washington, D.C.: Office of Technology Assessment, 1991, NTIS# PB91-166579.

Other Publications

David S. Birdsell and Douglas Muzzio, “WeTube the People,” The New York Times, April 20, 2008, Education Life, p. 34. David Birdsell and Leo Groarke (eds.), “Visual Argument Revisited,” special, double edition of Argumentation and Advocacy (Winter and Spring 2007). David Birdsell and Douglas Muzzio, “A ‘Customer’ Survey for the City,” (Gotham Gazette, April 9, 2007), http://www.gothamgazette.com/article/fea/20070406/202/2141. Review of Darin Barney, Prometheus Wired (University of Chicago Press, 2000), Contemporary Sociology, (Spring 2002).

David S. Birdsell and Rahima Wade, “Student Voices in the Community,” National Curriculum for the Annenberg Public Policy Center’s Student Voices Program, August 2002. “View News Critically,” The PBS Democracy Project, September 2000. Available online at http://www.pbs.org/democracy/readbetweenthelines/news.html

CivicExchange: A Policy Forum for the Nation, <http://www.baruch.cuny.edu/civicexchange>, co-developed with the Whitman Center for the Study of Democratic Culture. (Inactive site)

Vox New York: A Policy Forum for the City, <http://www.baruch.cuny.edu/voxnewyork>, co-developed with the BCTC and the Office of the Public Advocate of the City of New York. (Inactive site)

“No Room for Perot,” The New York Times, Op-Ed, September 18, 1996, p. A-21.

David Birdsell and Leo Groarke (eds.), “Visual Argument,” special, double edition of Argumentation and Advocacy (Summer and Fall 1996).

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Ed., “Presidential Debates: Beyond the Debate Analogy,” special edition of Argumentation and

Advocacy, 27 (Winter 1991).

“The Status of Minorities in Higher Education,” Reginald Wilson and Sarah Melendez, eds. (Washington, D.C.: The American Council on Education, 1984).

Selected Presentations & Public Programs

David S. Birdsell and William J. Ferns, “Now Ubiquitous, Not Yet Intensive: Results from Two Studies of NYC Nonprofits’ Use of ICT in 1996 and 2009,” Ghent University, March 20, 2012 (Earlier versions presented at Center for Nonprofit Strategy and Management, April 20, 2009 and as a LISC Webcast, June 3, 2009.) Convener and Moderator, “Executive Education Conference-within-a-Conference,” NASPAA Annual Conference, Kansas City, MO, October 21, 2011 “New Technologies and Political Participation,” two forums for Fulbright Scholars visiting the United States, New York University, June 21 and July 6, 2011 “The 2010 US Midterm Elections: The Vanishing American Consensus,” Ghent University-University College Ghent International Week, Belgium, November 30, 2010. “Interview with Siva Vaidhyanathan and Anya Kamenetz,” Baruch College, November 18, 2010. “Interview with Benjamin Barber,” New York City Technical College, November 16, 2010. Convener and Moderator, “Executive Education Conference-within-a-Conference,” NASPAA Annual Conference, Las Vegas, NV, October 1, 2010. “Beyond the Pipeline Metaphor,” the Rangel Center Symposium on Diversity in Public Service, New York, NY, October 30, 2009. “A Communication Curriculum for Nonprofit Administration,” Annual Meeting of the National Association of Schools of Public Affairs and Administration, Washington, DC, October 15, 2009. “Social, Political and Economic Forces in New York City and State: 2025,” City University of New York Conference on Financial Management, September 17, 2009. David S. Birdsell and Carol Kellerman, Moderators, NYC Comptroller Primary Debate, Sponsored by the Citizens Budget Commission and the Center for Innovation and Leadership in Government, September 9, 2009. David S. Birdsell and Angelina Delgado, “Non-Credit Partner Programs as a Degree Program Pipeline,” Annual Meeting of the National Association of Schools of Public Affairs and Administration, Charleston, SC, October 17, 2008.

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Panelist, “Investing in Emerging Leaders,” Panel convened by The New York Times, the New York Regional Association of Grantmakers, and the Support Center for Nonprofit Management, New York Times Auditorium, April 14, 2008. “The U.S. Presidential Primary of 2008,” Presentation to UN Security Council Senior Staff, New York City, March 25, 2008 “Presidential Primary Elections,” a Voluntary Visitors Project for Spain, Sponsored by the US Department of State, Baruch College, February 5, 2008. Testimony on the Impact of the New York State Commission on Higher Education Preliminary Report and Recommendations, New York City Council Committee on Higher Education, January 31, 2008. “Presidential Primary Debates,” Baruch Alumni Meeting, Boynton Beach, January 27, 2008. “The ‘Pipeline’ Metaphor and Professional Opportunity,” National Urban Fellows Mid-Year Conference, Minneapolis, January 2008. “Making Sense of the Nonprofit Leadership Literature,” Conference on Nonprofit Leadership, Center for Nonprofit Strategy and Management, Baruch College, December 2007 “The Difficulty of Assessing Public Demand: Broadband Provisioning in New York City,” Presented at the Shanghai Jiao Tong University Conference on Public Service Delivery, June 2007. Extended versions of paper presented in lectures at Tongji University and Shanghai University for Finance and Economics, July 2007. David S. Birdsell and Ann Ruecker, “Community Partnerships in Executive Education: Opening the Umbrella,” Annual Meeting of the National Association of Schools of Public Affairs and Administration, Minneapolis, MN, October 20, 2006. Testimony on Behalf of Int. 625-A, Establishing a Broadband Task Force, the New York City Council Committee on Technology and Government, June 10, 2005. Testimony on the DOITT/EDC Telecommunications Infrastructure and Economic Development Report, the New York City Council Committee on Technology and Government, May 2, 2005. Testimony on Use of New York City’s Publicly Owned Cable Television Outlets, The New York City Council Committee on Technology and Government, February 14, 2005. Respondent, “Trends, Technology and Communication in American Politics,” New York City Women’s Club, January 27, 2005. Testimony on Behalf of Int. 17 and Int. 27, The New York City Council Committee on Technology and Government, December 9, 2004.

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“New York’s Next Nonprofit Leaders,” Annual Meeting of the Alliance for Nonprofit Management, August 2004. “Globalization and Media,” Forum for Fulbright Scholars, June 28, 2004. “Nonprofit Leadership,” Bayer Center for Nonprofit Management, March 4, 2004. “Leadership Development,” Workforce Development Summit of the Addiction Technology Transfer Center Network, January 27, 2004. “The Next Leaders,” Joint Baruch College-United Way of New York City Conference on Executive Development in the Nonprofit Sector, October 23, 2003 “Trends in Executive Turnover,” The New York Regional Association of Grantmakers, June 6, 2003 “Consultant-Client Relationships: Who Expects What from Whom?” Bayer Center for Nonprofit Management, February 28, 2003. Panelist, Roundtable II: NCA White Paper on Presidential Debates, National Communication Association Convention, New Orleans, LA, November 24, 2002. “Assessing Community Technology Programs,” Community Technology Symposium, Columbia University, October 24, 2002. “Student Voices in New York City,” American Political Science Association, Boston, MA, August 31, 2002. “Who Expects What from Whom? Consultant-Nonprofit Relationships,” Alliance for Nonprofit Management, with Doug Muzzio, June 14, 2002. “Understanding Behaviors and Needs of Patrons at the Branch Libraries,” New York Public Library, with Doug Muzzio, March 2002. “Consultant-Nonprofit Relationships,” New York Nonprofit Network, December 13, 2001. Panelist, Presidential Debate Symposium, Racine, Wisconsin, September 20-23, 2001. Moderator, “Politicians and Media in the 2000 Election,” Teaching Matters, Inc., City Hall, New York City, October 2000. “The Internet in New York’s Service Delivery,” The City Club of New York, May 12, 2000. “Adapting the MPA Curriculum to E-Government” the American Society for Public Administration, Eastern Regional Meeting, New York, October 1999, with Dan Williams.

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“Access to the Internet at Public Sites,” the American Society for Public Administration, Eastern Regional Meeting, New York, October 1999.

“MN-Politics: Argumentative Practices on a Political Listserv,” Public Address in an Electronic Age: The Sixth Biennial Conference on Public Address, University of Iowa, Iowa City, IA, September 24-27, 1998. “Politics on the World Wide Web,” Forum for Fulbright Scholars, New York University, July 28, 1998 “Structured Political Argument on the World Wide Web,” presented at the Fourth International Conference on Argumentation, International Society for the Study of Argumentation, Amsterdam, the Netherlands, June 16-19, 1998. “It’s Not the Machine, It’s the Pedagogy: Rejecting Technological Determinism in Projecting Faculty Workloads,” presented at the NCSCBHEP Annual Conference, New York, NY, April 20-21. “The Internet: Looking More Like America,” presented at Government and Politics on the Web: Questions of Access, March 17, 1998.

David Birdsell and Douglas Muzzio, “Political Uses of the World Wide Web in the 1996 US Presidential Campaign,” Images of Politics, Amsterdam, October 23-26, 1997.

“Using the World Wide Web for Course-Based Collaboration,” 57th Street Computing Center, City University of New York, October 9, 1997.

David Birdsell, Douglas Muzzio, Richard Treitman, Shin Ogino, and Kevin Cancienne, “Using the World Wide Web to Facilitate Course-Related Communication,” The EDMEDIA/EDTELECOMM Annual Conference of the Association for Computing in Education, Calgary, Ontario, June 14-20, 1997.

“The Role of the New Media: The World Wide Web in Politics and Governance,” the Miller Center Policy Forum, University of Virginia, Charlottesville, VA, May 9, 1997.

“Response to Vorobej,” the Annual Meeting of the OSSA, St. Catherine’s, Ontario, May 14-17, 1997.

David Birdsell, Douglas Muzzio, Humphrey Taylor and David Krane, “The World Wide Web in Campaign ’96,” New York AAPOR, October 9, 1996.

“Personal, Political and Policy Identities on the World Wide Web in the U.S. Presidential Primary Campaign of 1996,” The ISSA-Wake Forest Conference on Argumentation, Venice, Italy, June 23-28, 1996.

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“The World Wide Web in the Social Science Classroom,” The BCTC Spring Computer Seminars, Baruch College, February 28, 1996. “Representation in Political Television: Expression and Denotation,” The Annual Meeting of the Speech Communication Association, New Orleans, LA, November 19-22, 1994. “Enthymemes in Intermediated Public Argument,” The Third International Conference on Argumentation, International Society for the Study of Argumentation, Amsterdam, The Netherlands, June 21-24, 1994.

“An Enthymematic Approach to Response and a Responsive Approach to Enthymemes,” The Eighth Biennial SCA/AFA Conference on Argumentation, Alta, Utah, August 4-8, 1993.

“Academic Envy: A Conversation With/Response to John Rodden,” The Art of Conversation, Temple University, Philadelphia, PA, March 25-27, 1993.

“The 1992 Presidential Debates: Argument and Visual Literacy,” The Annual Meeting of the Modern Language Association, New York, NY, December 27-29, 1992.

“Response to Burnett, et al.,” The Annual Meeting of the Speech Communication Association, Chicago, IL, October 28-November 1, 1992.

“Presidential Debates,” The New School for Social Research, July 6, 1992.

“Language and Visual Representations: Le Corbusier,” The University of Maryland Communication Lecture Series, April 24, 1992.

“Argument into Trope/Trope into Argument,” The Annual Meeting of the Speech Communication Association," Chicago, IL, November 1-4, 1991.

“Response to Muir, Harris and Depoe,” The Seventh Biennial SCA/AFA Conference on Argumentation, Alta, Utah, August 1-4, 1991.

“Architectural Principles and Built Form in the Work of Le Corbusier: Writing a New World,” The Annual Meeting of the Speech Communication Association, Chicago, Ill., November 1-4, 1990.

“Character Evidence in Presidential Debates,” The Annual Meeting of the Speech Communication Association, San Francisco, CA, November 18-21, 1989.

“Critics and Technocrats,” The Sixth Biennial SCA/AFA Conference on Argumentation, Alta, Utah, August 3-6, 1989.

Herbert W. Simons and David S. Birdsell, “What if Arguers Could as Easily Show as Tell?” The Sixth Biennial SCA/AFA Conference on Argumentation, Alta, Utah, August 3-6, 1989.

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“Character Evidence in Presidential Debates,” The Annual Meeting of the Eastern Communication Association, Ocean City, MD, May 4-7, 1989.

“Argumentation as a Framework for Analysis and Training in Business Communication,” The Eastern Regional Conference of the Association for Business Communication, New York, NY, March 31, 1989.

“Evidence and Format in Presidential Debates: Evolving Standards of Performance and Evaluation,” The Presidential Debates Symposium, University of Massachusetts, Amherst, MA, December 2, 1988.

“Interpreting Evidence in the 1988 Presidential Debates,” The Temple Conference on Discourse Analysis, November 11, 1988.

“The History of Political Debates: A Guide to Contemporary Practices,” The Wisconsin Colloquium, Department of Communication, The University of Wisconsin, Madison, WI, February 5, 1988.

“Narratives, Fantasy Themes and Argumentative Judgment,” paper presented at the Speech Communication Association Annual Convention, Boston, MA, November 6-8, 1987.

“Published Debate Judging Philosophies: The Ethics of Evaluation,” paper presented (by proxy; I was ill and could not attend) at the Eastern Communication Association Annual Meeting, Syracuse, NY, May, 1987.

“Issues and Images in the Presidential Campaign of 1984,” Paper presented at the Speech Communication Association Annual Convention, Chicago, IL, November 13-16, 1986.

“Tropological Dimensions of Evidence in Public Policy Argument,” Paper presented at the Conference on Case Studies in the Rhetoric of the Human Sciences, Temple University, Philadelphia, PA, April 10-12, 1986.

“The History of TV Political Spots,” Lecture presented at The American Film Institute's Faculty Development Workshop on Politics and the Media, Washington, D.C., June 17-21, 1985.

“A Synecdochic Approach to Burke's Master Tropes,” Paper presented at the Speech Communication Association Annual Convention, Chicago, IL, November, 1984.

“Act as Coordinating Term,” Paper presented at the Burke Conference, Temple University, April, 1984.

PROFESSIONAL HONORS, PRIZES, FELLOWSHIPS Honorary Induction to Pi Alpha Alpha, 2008 Honorary Induction to Gold Key, 2007 United Way of New York City Community Partner Award (for SPA), 2007 Young Leaders Forum, American-Swiss Foundation, 2000

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Presidential Service Award, Baruch College, 1999 Presidential Teaching Award Nominee, 1989, 1996, 1998, 1999 Teaching Award, University of Maryland, 1985-86 Provost's Fellow, University of Maryland, 1983-85 Public Service Award, Virginia State University, 1980

GRANTS (as PI or Co-PI only) FIPSE/IFLE, North American Mobility Program Award, $358,000, 2010 The Achelis-Bodman Foundation, Free Institutions (with Thomas Main), $100,000, 2008 The Clark Foundation, Operating Support for Ctr. for Nonprofit Strategy & Mgt., $75,000, 2008 Graduate Research Technology Initiative, $130,000, 2008 The Clark Foundation, Operating Support for Nonprofit Group, $100,000, 2007 The New York Community Trust, Civic Spending by Foundations in NYC, 2005, $10,000 The United Way of New York City, Leadership Development, 2002-2004, $216,000 The Clark Foundation, Technology Programs for Nonprofits, 2003, $70,000 The Annenberg Foundation & Pew Charitable Trusts (subcontract), Revision of Student Voices

(Justice Talking) National Curriculum, 2002, $25,000 The Clark Foundation, Technology Programs for Nonprofits, 2001-2002, $75,000 The Annenberg Foundation & Pew Charitable Trusts (subcontract), Student Voices & Justice

Talking, 2001-2002, $393,000 The JPMorganChase Foundation, Lincoln Douglas Debates, 2001-2002, $50,000 Graduate Research Technology Initiative, $170,000, 2001-2002 The Clark Foundation, “Consultant Relationships in the Nonprofit Sector,” 2001, $57,000 The Clark Foundation, “Technology Planning for Nonprofits,” 1999-2000, $75,000 PricewaterhouseCoopers Fund for the Business of Government, “Internet Access in NYC,” 1999,

$7,500 The Markle Foundation (subcontract), Research Reports on Universal Service, 1999, $6,000 New York State Library (subcontract), Internet Access Training, 1998-1999, $120,000 The Clark Foundation, “The World Wide Web in Nonprofit Administration,” 1998-1999,

$25,000 The Markle Foundation (subcontract), CivicExchange, 1998, $5,000 Graduate Research Technology Initiative, “Laboratory for the Study of Computerization in

Nonprofit Management,” 1996, $100,000 with Baruch Match. Funded Research Incentive Award, Baruch College, Spring 1994, $1,500 Funded Research Incentive Awards (2), Baruch College, Fall 1992, $1,500 Moody Grant, the Lyndon Baines Johnson Foundation, 1987-88, $500 Graduate Research Grant, the University of Maryland, Spring 1986, $500 Graduate Research Grant, the University of Maryland, Fall 1984, $500 Graduate Research Grant, the University of Maryland, Spring 1984, $500 Provost’s Fellow, the University of Maryland, 9/83-6/85, $20,000 annually

Service (as a faculty member only)

TO SPA: Student Advisor, 2000-2005 Curriculum Coordinator, 1998-2004 Faculty Mentoring, 1996-2004

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Representative to College UG Coordinating Committee, 1996-2004 P&B Committee, 1994-2004 Executive Committee, 1994-2004 Representative to Weissman School of Arts & Sciences, 1994-2005 Curriculum Committee, 1994-2005 Curriculum Subcommittee Chair, 1994-98 Grants Coordinator, 1997-98 Moderator, New York Elections by the Numbers, October 1998 Graduate Curriculum Committee Representative, 1995-97 Chair, Technology Coordinator Search Committee, 1997 Chair, Director of Graduate Recruitment Search Committee, 1997 Design and Oversight of the Lab for Computerization in Nonprofit Administration, 1996-97 Faculty Search Committees (More than Two-Dozen Positions), 1994-2000 Formulation and Coordination of Communication Coursework for the Consortium for Worker

Education, 1996 Community School Board Project, 1996 TO BARUCH: Schwartz Institute Search, 2005 Chief Communication Officer Search 2005 Co-Chair, Facilities Task Force, 2004-2005 AVP for Facilities Search, 2005 College Parliamentarian, 1995-2005 Sexual Harassment Committee, 1995-2002 VP for Information Technology Search, 2001-2002 Public Relations Manager Search, 2001 Vertical Campus Technology Committee, 1995-2001 Management Information Team, 1998-2000 President Search, 1999-2000 Middle States Committee and Task Force Chair, 1998-2000 Member, Faculty Committee on Educational Computer Policy, 1999-2000 Chair, General Faculty Committee on Educational Computer Policy, 1997-1998 & 2000-2001 Vertical Campus Classroom Design Committees, 1997-2001 Panelist, Sexual Harassment Committee, 1995-2001 Chair, Communication Task Force, 1997-1998 Provost’s Committee on Departmental Labs, 1997-1998 Communication Intensive Course Project, Faculty Trainer and Liaison, 1997-1998 Ad-hoc Committee on the Media Center, 1995-98 College Committee on Public Affairs, 1995-97 Member, Task Force on Communication Skills, 1994-98 Search Committee for Director, BCTC, 1996 Open Systems Lab Development, 1995-96 Member, Middle States Interim Assessment, 1994-96 Co-Chair, Task Force II on the School of Public Affairs, 1994 Search Committee for a Media Analyst/Producer in Media Services, 1994 Search Committee for Associate Director of the Grants Office, 1994

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Search Committee for Coordinator of Training and Publications for the Computer and Technology Center, 1994.

Conference Director, "Globalization and Diversity: Challenges for Affirmative Action," 1994 Title III Committee, 1994 FIPSE Grant Proposal, 1994 (2 proposals) Task Force I on the School of Public Policy, 1993-94; Chair, Subcommittee on Structure, 1993-

94, and Co-author (with Douglas Muzzio) of the Joint Report of the Committees on Mission and Structure, January, 1994

Affirmative Action Committee, 1992-96; Chair, Conference Subcommittee, 1993-94 Weissman Center Director Search Committee, 1993 Baruch College Association, 1992-94 Title III Committee, 1992-93 FIPSE Grant Proposal, 1992 Liberal Arts Summer Advisement, 1987-92 Coordinator, Faculty-Student Debates, 1989, 1991, 1992 Baruch Scholar Review, 1987-97 FIPSE Grant Proposal, 1991 Title III Committee, 1990-91 AAC Grant Proposal, 1990 Associate Dean (SLAS) Search Committee, 1990

MEMBERSHIPS American Forensic Association Association for Public Policy and Management National Association of Schools of Public Affairs and Administration National Communication Association

OTHER PROFESSIONAL ACTIVITIES AND PUBLIC SERVICE Press Source and Commentator on Political Debates, Political Rhetoric, New York City Politics, and Political Uses of the Internet; Print citations include The New York Times; Newsday; The

New York Daily News, The New York Post, The Washington Post; The Los Angeles Times; The

Miami Herald, U.S. News and World Report; newspapers associated with the Reuters, Knight-Ridder and Newhouse services; The Cleveland Plain Dealer; The Philadelphia Inquirer; The

Houston Chronicle; The New Orleans Times-Picayune; The Omaha World Herald; the Raleigh

News and Observer; The St. Petersburg Times; The Hartford Courant, and The Atlanta Journal-

Constitution. International papers and magazines include Focus (Germany); Telerama (France); Weekendabisen (Denmark); The Yomiuri Shimbun (Japan). Appearances include CBS; CNBC; CNN; MSNBC; NBC; Fox News; New York 1; PBS; WABC-TV; Fox-5 TV; WB-11 TV; NPR; NBC Radio; International News Network; the Christian Science Monitor Broadcast System; Radio Pacifica; KFYI Radio, Phoenix, AZ; WTAE Radio, Pittsburgh, PA; KCBS Radio, Nashville, TN; WABC Radio, NY; WNWS Radio, Miami, FL; Bloomberg News Service. Advisory Boards:

Broadband Advisory Committee of New York City (Council Appointee) Computer Center for Visually Impaired People National Campaign to Restore Civil Rights, Media Committee

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Fiduciary Boards: VCG Governance Matters (Chair) New York Census Research Data Consortium (Executive Committee) FR 23 Road Association NASPAA: Executive Council (Co-chair, Data Committee)

Editorial Board: Communication Studies

COURSES TAUGHT AT BARUCH COM 1010 Speech Communication COM 3020 Communication and Advocacy in Business and Public Affairs COM 3061 Speech Composition and Delivery COM 3070 Persuasion COM 3071 Argumentation and Debate COM 3102 Speech for Executives PAF 3120 Communication in Public Organizations IDC 4050 Feit Seminar (Television and Politics) PAF 9103 Communication in Public Settings PAF 9108 Communication and Information Technology PAF 9137 Telecommunications Policy PAF 9139 Communication Strategy BUS 9550 Management Communication

REFERENCES Chris Cloud, Principal Constellation Advancement [email protected] Kathleen Hall Jamieson, Professor and Director Annenberg Public Policy Center University of Pennsylvania [email protected] Frederick Lane, Emeritus Professor School of Public Affairs Baruch College/CUNY [email protected] James McCarthy, President Suffolk University [email protected]

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Appendix G – Eligibility policy

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Xchange Telecom Lifeline Policies

Last Update: 7/2/12

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Lifeline Subsidy

The FCC has implemented a flat rate for Lifeline rate across all states. The Lifeline subsidy equals $9.25

per month beginning in August 1, 2012. In addition, Xchange is provided with a subsidy from TAF for

NY Lifeline

LinkUp Subsidy

As of April 2, 2012 there is no more linkup subsidy.

Marketing and Outreach Material

The FCC rule on advertising requires ETCs to “publicize the availability of Lifeline service in a manner

reasonably designed to reach those likely to qualify for the service”. ETCs must advertise voice

telephony service using general distributed media (newspapers, radio). Xchange currently advertises

using a mix of these medias. ETCs should target households that do not currently have telephone service,

and target members of any sizable non-English speaking population within their service area. The FCC

has implemented rules to “increase the quality of information ETCs must provide to potential customers.”

As of September 2012, ETCs must include specific marketing and uniform language in all of their

marketing materials and it must be presented in clear, easily understood language. The requirements

include explaining:

That the ETC’s offering is a “Lifeline supported service”; That only eligible customers may enroll in the program; What documentation is necessary for enrollment; That the program is limited to one benefit per household, consisting of either wireline or wireless

service; Lifeline is non-transferable; and That Lifeline is a government benefit program, and consumers who willfully make false

statements in order to obtain the benefit can be punished by fine or imprisonment or can be barred from the program.

**This requirement is currently on hold until OMB approval.

“Marketing materials” includes materials in all media, including but not limited to print, audio, video,

Internet (including email, web, and social networking media), and outdoor signage, that describe the

Lifeline supported service offerings, including application and certification forms.

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The following outreach methods are recommended:

Notices at public transportation areas, shelters, soup kitchens, and public assistant agencies. Public service announcements Toll free numbers in other languages Print media: Newspapers, direct marketing, telephone directories, etc. Door-to-door and television are proving very successful in some markets Social service agencies, tribal orgs, community centers, AARP, United Way, etc. Outreach material should contain state-specific eligibility criteria.

Under the new FCC rules, USAC will be conducting advertising compliance reviews. These will occur at

least once a year, and will check marketing materials to ensure they include the required language, and

that the eligibility criteria used is up to date. Lastly, USAC will look at the methods an ETC uses to reach

Lifeline eligible consumers. ETCs should not rely only on bill inserts and phone books because these are

sent to current customers with phone service, the ETC is not advertising to those without phone service.

Enrollment Certification & Verification

Every Lifeline prospect must be certified during the enrollment process. The goals of the certification

process are to verify prospect’s eligibility, comply with the FCC’s one-per-household/economic unit rules

and ensure that the prospect is not currently receiving Lifeline service from another provider.

In order to implement this, the Xchange policy is to

Confirm the prospect’s identity (see government issued picture ID or a copy) Confirm program or income eligibility (see proof of income form) Confirm valid household address (validate against USPS or other sources) Confirm that prospects not currently receiving a subsidy (ask prospect, and then perform a

duplicate check into an internal and pooled external database when it becomes available). When the online database becomes available, confirm the prospect against eh online e database.

The certification document remains the cornerstone of the enrollment process. Upload the certification

document only to the billing system. Do not include the supporting documentation, affirm to the system

that you have in fact viewed the documentation.

The following fields of customer information must be captured on the certification document: name,

home address (no PO Box), billing/mailing address if different (may be a PO Box), the government

assistance program(s) in which prospect is currently enrolled, last four digits of social security number

(full social may be required by certain states), date of birth, and prospect’s signature and date.

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The proof required for enrollment may be accepted in person, via fax, e-mail, or mail. USAC will be

providing ETCs with information on what documentation is sufficient as proof of participation. Upon

receipt of proof, an agent of the ETC must certify that they saw the documentation during the enrollment

process. An ETC should not retain the eligibility documentation provided by the prospect.

For income based eligibility, the acceptable documentation includes:

- Prior year’s tax returns - Current income statement or pay stub - Social Security statement of benefits - Veterans Administration statement of benefits - Retirement/ pension statement of benefits - Unemployment/ Workmen’s Compensation statement of benefits - General Assistance Tribal notice letter - Divorce Decree - Child Support Award - Any other official document with income information

The documentation must cover one full year or three consecutive months of the same document within the

previous twelve months.

Program based eligibility must also be proven via a current or prior year’s statement of benefits from a

qualifying program, letter of participation from the qualifying program, participation document (SNAP

card, Medicaid Card), voucher, or any other official documentation. For each lifeline applicant the ETC

enrolls that relies on eligibility documentation, the company must document the following information:

(1) Type of documentation reviewed, for example: (a) Award letter (b) Voucher (c) Benefits card (d) Income statement

(2) Date or expiration date of documentation (3) Identifying information about documentation submitted (for example, “blue SNAP card” or

“letter from State Health and Human Services Agency”); (4) Date reviewed; (5) Method the documentation was provided, for example;

(a) In person (b) By fax (c) By mail (d) Electronically

(6) Name of ID of employee or agent who reviewed documentation (7) Name on documentation demonstrating program eligibility (if different from name of the

applicant);

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(8) Certification that individual named on documentation demonstrating program participation is part of the applicant’s household (if different from name of applicant); and

(9) Certification that individual named on documentation demonstrating program eligibility does not already receive lifeline (if different from name of applicant).

ETCs may query state or federal social service or income databases to verify eligibility. The ETC must

retain the following records:

(1) The name of database queried; (2) The date the database was queried; and (3) A copy of the confirmation received, or certification by ETC’s employee that database confirmed

eligibility. Lastly, an ETC may rely on a state agency to verify the applicant’s eligibility. If verified this way, the

ETC must retain:

(1) The name of the agency consulted; (2) The agency contact (3) The date the confirmation of eligibility was received; and (4) A copy of the notice provided by the agency that confirms eligibility.

The certification form will include the following language that explains in plain, easy to understand

language:

Lifeline is a federal benefit. Lifeline Service is available for only one line per household. A household is defined, for purposes of the Lifeline Program, as any individual or group of

individuals who live together at the same address and share income and expenses. Households are not permitted to receive benefits from multiple providers. Violation of the one-per-household limitation constitutes a violation of the Federal

Communications Commission’s rules and will result in your de-enrollment from the program, and potentially prosecution by the United States Government.

The ETC must have the end user attest, under penalty of perjury, that:

The information contained in my application remains true and correct to the best of my knowledge and I acknowledge that willfully providing false or fraudulent information to receive Lifeline benefits is punishable by law and may result in me being barred from the program.

That I am a current recipient of the above program, or have an annual household income at or below 135 percent of the Federal Poverty Guidelines

I have provided documentation of eligibility if required to do so I attest to the best of my knowledge, that I and no one in my household are receiving a Lifeline

supported service from any other land line or wireless company. I understand that I can only receive one Lifelines subsidy

I understand Lifeline service is a non-transferable service, and that I may not transfer my service to any other individual, including another eligible low-income consumer.

I understand that if my service goes unused for sixty (60) days, I will no longer be eligible for Lifeline benefits and my service will be suspended subject to a thirty (30) day period during which I may use the service or contact the Company to confirm that I want to continue receiving Lifeline service from the Company

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I will notify my telephone company within thirty (30) days if I no longer qualify for Lifeline. I understand this requirement and may be subject to penalties if I fail to notify my phone company. Specifically, I will notify my company if: I cease to participate in the above federal or state program, or my annual household income

exceeds 135% FPG. I am receiving more than one Lifeline supported service; I no longer satisfy the criteria for receiving Lifeline support. I will notify my phone company within thirty (30) days of moving. Additionally, if my

address listed above is a temporary address, I understand that I must re-verify my address with my telephone company every ninety (90) days. if I fail to respond to my telephone companies’ address verification attempts within thirty (30) days, I may be de-enrolled from my Lifeline service.

I am head of household, and not listed as a dependent on anyone’s tax return. My telephone company has explained the one-per household requirement, and I understand that violation of the one-per-household requirement constitutes a violation of the FCC’s rules and will result in my de-enrollment from the lifeline program, and could result in criminal prosecution by the United States Government.

My telephone company has explained to me that I am required each year to re-certify my continued eligibility for Lifeline at any time, and that if I fail to do so within thirty (30) days, it will result in the termination of my Lifeline benefit.

One Per Household Requirement

The FCC has introduced requirements to provide guidance when multiple Lifeline-eligible subscribers

share a same address. Currently, Lifeline supported services are limited to one subsidy per “household,”

but until now there has not been a specific definition of what a household is. The FCC has defined a

“household” as “any individual or group of individuals who are living together at the same address as one

economic unit.” An economic unit consists of all adult individuals contributing to and sharing in the

income and expenses of a household. USAC has created a certification form to assist ETCs in providing

Lifeline to low income households sharing an address. USAC will also create print and web materials that

ETCs can use to educate customers about the one-per-household rule.

If a prospect is identified in the enrollment process as having the same address as a current Lifeline

customer, the ETC must have the prospect certify on a separate form that they are head of household and

understand the one-per-household rule.

Persons with Temporary Addresses

If a prospect identifies that their address is a temporary one, the ETC must verify with the end user every

90 days that he/ she continues to reside at that address. If an end user fails to respond to the ETC’s

request to verify his/ her address within 30 days, the subscriber must be de-enrolled from the lifeline

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program. Once the national database is in place, if an end user moves, the ETC must update the database

with the new information within 10 business days of receipt of the information.

** This requirement has been put on hold until future OMB approval.

Additional Enrollment Verification Recommendations

The ETC is responsible to use best practices to verify the general eligibility of the prospect. The questions

and methods above will go a long way to ensure this. The additional steps below are added for the

purpose of extra protection:

Establish and document fraud/abuse prevention processes, and fraud/abuse correction processes. Systematically monitor sales agent activity for fraudulent behavior. Identify what happens if fraud occurs. Identify what happens if fraud is found after reimbursement has been requested. What processes occur to return the subsidy, contact the end user, de-activate/de-enroll the account, gain back the phone, address the issue with the sales person/sales entity, improve internal processes, notify other ETCs if necessary, etc.?

Annual Certification/Verification

Rules:

All ETC designated companies must re-certify the eligibility of all Lifeline subscribers active on the date

of June 1, 2012, and must do so by the end of 2012. The results of the recertification effort must be

reported to USAC by January 31, 2013.

Beginning in calendar year 2013, ETCs must re-certify their entire base every 12 months, and may do so

on a rolling basis, throughout the year. Upon completion of the recertification process each year, ETCs

will be required to complete and submit the Lifeline ETC certification form to USAC. The form must be

signed by an officer of the company, certifying under penalty of perjury that the company has procedures

in place to confirm consumer eligibility, and that the ETC is in compliance with the certification

procedures and has obtained a valid certification form from each active Lifeline customer.

End users must be given at least 30 days to respond to the annual recertification request. If they fail to do

so they must be given a 30-day notice of pending termination. If they still fail to respond in the

prescribed 30 days, then they must be de-enrolled from the Lifeline program.

The recertification process includes the following requirements:

The end user’s identity must be verified through confirmation of the existing name, address and telephone number on the account.

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The process must capture the end user’s date of birth and last four digits of social security number. This information will be required for the eventual population of the national duplicate database.

The end user’s verbal responses or touch-tone responses must be captured and stored in a way that allows them to be retrieved on-demand.

Each end user must certify:

The information contained in my application remains true and correct to the best of my knowledge and I acknowledge that willfully providing false or fraudulent information to receive Lifeline benefits is punishable by law and may result in me being barred from the program.

That I am still a recipient of the specific eligibility program, or have an annual household income at or below 135 percent of the FPG.

I am an adult. I understand that I and my household can only have one Lifeline-supported telephone

service. My telephone company has explained the one-per household requirement. I understand that violation of the one-per-household requirement constitutes a violation of the FCC’s rules and will result in my de-enrollment from the lifeline program, and could result in criminal prosecution by the United States Government.

I attest to the best of my knowledge, that I and no one in my household are receiving a Lifeline supported service from any other land line or wireless company (such as Safelink, Assurance, or

Reachout Wireless).

I understand that if my service is unused for sixty (60) days, it will be suspended subject to a thirty (30) day period in which I may use the service or contact the Company to confirm that I want to continue receiving Lifeline service from the Company.

I will notify my telephone company within thirty (30) days if I no longer qualify for Lifeline. I understand this requirement and may be subject to penalties if I fail to notify my phone company. Specifically, I will notify my company if: I cease to participate in the above federal or state program, or my annual household income

exceeds 135% FPG. I am receiving more than one Lifeline supported service; I no longer satisfy the criteria for receiving Lifeline support.

I will notify my phone company within thirty (30) days of moving. If I fail to respond to my telephone companies’ address verification attempts within thirty (30) days, I may be de-enrolled from my Lifeline service.

My telephone company has explained to me that I am required each year to re-certify my continued eligibility for Lifeline, and that if I fail to do so within thirty (30) days of notification, it will result in the termination of my Lifeline benefit.

Best Practices:

There are a number of ways in which an end user can recertify: a call to customer service (inbound and

outbound calls), a call to an IVR, website, email, fax, mail, or text.

State Eligibility Dip:

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All active customers in a state that maintains a lifeline eligibility database can be recertified by way of a

successful dip into that database. Since the database is not yet set up, we will implement this for 2013.

Once Xchange dips, any customers whose eligibility is not confirmed by the database must be

disconnected. If the ETC is informed that a customer is no longer eligible via the state eligibility dip, the

ETC must send the end user a 30 day termination letter explaining that their lifeline credit will be

removed.

Outreach Process:

In consideration of the holiday season, Xchange will start recertification in October, for all remaining,

active subscribers:

1. Send them an email (if available) with instructions to call the IVR/Customer Service, or go to the company’s website to complete the recertification process. The email should only detail the certification requirements and encourage the end user to recertify at their choosing, it should not require the end user to begin the recertification process.

2. On November 1st, send a mailer to each active end user who has not yet recertified. This mailer should detail the recertification process and explain the options for recertifying. Each mailer should include a hard copy of the ETC recertification form that may be mailed back to the ETC at no expense to the end user. This mailer should also include language explaining to the end user that if they fail to respond in 30 days, their lifeline discount may be terminated. The letter should be highlight that this is a “final notice” in bold lettering to illustrate the significance.

3. On December 1st, any end user who has not responded to the recertification request must be sent a 30 day termination letter explaining that their lifeline discount will be terminated due to their failure to respond to the recertification request.

By December 31st, all end users who have not completed the recertification process should be removed

from the ETC’s lifeline platform and Form 497. The results of the recertification should be compiled and

must be reported to USAC by January 31, 2013.

De-enrollment

An end user must be de-enrolled from the Lifeline program for the following reasons:

End users are required to inform the ETC within 30 days if they no longer qualify for the Lifeline subsidy. If an ETC becomes aware that the end user no longer qualifies, they must de-enroll the end user from the Lifeline program and may not request reimbursement for the end user.

If an ETC has “reasonable basis” to believe that an end user no longer meets the eligibility criteria for Lifeline, the ETC must notify the subscriber of impending termination of service and allow the end user 30 days to demonstrate eligibility before terminating service.

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With the introduction of programs like the IDRP process, if USAC informs an ETC that a subscriber is a duplicate or that more than one of the subscriber’s household is receiving a Lifeline benefit, then the ETC must de-enroll the end user with 5 business days.

As mentioned above, if an end user does not respond to and ETC’s annual recertification attempts within 30 days, the ETC must send the subscriber a notice giving the end user another 30 days to demonstrate eligibility. If the end user fails to certify, they must then be de-enrolled from the program.

Non- Usage: only an issue for providers of no cost service or prepaid services. Since Xchange always

charges and bills post, the customer always receives a bill and has an incentive to notify if the service is

not relevant.

Bill Presentment

ETC must show all charges and all credits/subsidies on every bill so that the end user can be assured of

what they are receiving, even if the bill to the customer will be zero-rated. For example, the actual

monthly charge must be shown along with the Lifeline credit, and the actual activation fee must be shown

along with the Linkup credit.

Other miscellaneous fees and charges must not be included in, or lumped into, the tax section of the

invoice. They must be identified in their own section of the invoice and clearly detailed.

Carriers eligible for Lifeline must not charge Lifeline subscribers for the following:

Federal Universal Service Fee related to local calling charges Local Number Portability Fee Security deposit related to local service Toll Limitation Service (Toll Block or Toll Control)

Lifeline service cannot be terminated for outstanding charges related to long distance service, nor can

they be charged interest on billing installments.

ETC Annual Reporting

The FCC has mandated that ETC must annually report the company name, holding company, operating

companies, affiliates, branding or dba names, and USAC identifiers. This report must include:

all outages that lasted more than 30 minutes and potentially affected at least 10% of customers or 911 special facility;

number of complaints per 1,000 handsets

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certification of compliance with service quality standards and consumer protection rules; certification that the ETC can function in an emergency; and information describing the terms and conditions of any voice telephony service plan offerings

offered to Lifeline subscribers. This report will be required annually and must be sent to the FCC, USAC, and any State commission.

USAC will provide the format for these annual reports.