The worst parts of the Proposed Decision (& why)

Earlier posts gave a cursory summary of changes to the Teleconnect Fund, with special attention to CBO eligibility. On closer inspection, it looks worse: the 50% of mission requirement, and direct access vs. administrative use provisions.

  • If the “50% of mission” for CBOs is adopted, there will be plenty of wrangling over vagueness. But clarification will only serve to weed out the organizations with integrated programs, often the best deliverers of service.
  • The revenue limit ($5 million) may exclude very worthy organizations with effective programs. We’re all for the underdog, and small is beautiful, but this cap may not be appropriate. (Especially given that private schools are allowed endowments of up to$50 million!)
  • The board composition requirements are off-base. Board composition is not a measure of program value or social utility. In the nonprofit community, diverse boards are considered a best practice. (And don’t forget philanthropy.)
  • Removing voice and VoIP service eligibility shows a lack of understanding of both original intent and direct service nonprofits, particularly those serving disadvantaged communities that require telephones to connect the client population with their programs.

The big question is why.

The bigger question might even be “why do this at all?”  The overall economy is good, and the CTF program gets high marks for assistance to groups where help is needed.

Worst of all – the PUC isn’t sure of the effects – at least that’s what they say (emphasis ours):

“We adopt the cohort of program changes today, with the proviso that the financial impacts of these reforms should be assessed once experience with new practices yield enough data to be evaluated. This includes impacts on all stakeholders, ratepayers, CTF participants and their service-benefiting populations, telecommunications carriers and internet service providers.”

In other words, the proposal is to make the changes to eligibility now and then assess the impact later.  Isn’t the PUC already in a position to run some scenarios? We think the Commission should do more research before cutting programs – or share the data they have already.