The reply comments assert that the proposals put forth by the U.S. Catholic Conference in the Comments comport with Section 254(c)(1) of the Telecom Act for eligibility for universal support:
Effective communication with employers and service providers is essential to the education, public health and public safety of homeless persons and migrant farmworkers.
Represents a substitute for basic telephone service, which is widely subscribed to by over 94% of all residential customers.
Is widely deployed in the public telecommunications network.
Enables these groups to become fuller participants in society.
All providers of such service should be eligible for universal service support.
Access to basic phone and advanced communications services has profound effects on improving shelter service to clients.
Increases homeless persons' and migrant farmworkers' ability to communicate with employers, landlords, government officials, educational and medical facilities, emergency services and family members.
Basic phone service is initiated by and subscribed to by a majority of residential customers
Is consistent with the public interest through the service which is afforded to the constituencies.
Enables homeless persons and migrant farmworkers to obtain essential information regarding shelter availability, healthcare, education, etc.
Serves the public interest by making service providers more accessible to the people they serve.