Agenda Date: March 10, 2000
Item Number:

Docket:  UT-991535 - Area Code 206/253/425 Relief Plan
   
Company Name: Telecommunications General

Staff:   Rebecca Beaton, Program Manager/Consultant  
   Glenn Blackmon, Assistant Director
   David Dittemore, Telecommunications Engineer
   David Griffith, Telecommunications Engineer

Recommendation:

Direct the North American Numbering Plan Administrator, NeuStar, to reconvene 
the telecommunications industry group to give further consideration to area 
code overlay options that include the 360 and/or 509 area codes with area codes 
253, 206, and 425.  

Background

On February 15, 2000, the North American Numbering Plan Administrator (NANPA), 
NeuStar, in its role as the neutral third party NPA Relief Planner for 
Washington, filed with the Commission the final plan to relieve the anticipated 
shortage of telephone numbers in the central Puget Sound area (area codes 206, 
253, and 425).  The 1999 Central Office Code Utilization Survey (COCUS) 
projections for code use indicate the 206 NPA will exhaust during the second 
quarter of 2002, the 425 NPA will exhaust during the fourth quarter of 2003, 
and the 253 NPA will exhaust in the second quarter of 2006.  

The industry developed this relief plan after discussing relief options at a 
single meeting, on January 5, 2000. WUTC staff attend relief planning meetings 
and participate in discussion of alternatives and issues.  WUTC staff do not 
vote on the relief alternatives,  NANPA presented nine relief alternatives, 
including five options that were suggested by Commission Staff.  The industry 
reached consensus to recommend to the Commission the use of a single overlay of 
a new area code over the 206, 425, and 253 areas.

Under the recommended relief plan, a single new area code would be used in all 
areas where 206, 425, and 253 currently apply.  Prefixes from the new area code 
would be assigned across the three areas as the "native" prefixes are used up.  
The remaining 206, 425, and 253 prefixes would be used only within the 
geographic boundaries already defined for each of the three area codes. 


Docket UT-991535
March 10, 2000
Page 2

All existing customers would retain their existing 206, 425, and 253 area 
codes, and they would not be required to change their telephone numbers.  
Consistent with the current FCC regulations, the industry reached consensus to 
recommend the implementation of a ten-digit local dialing plan within and 
between the existing area codes and the overlay area code.

The industry recommends that the customer notification period begin on June 16, 
2001, and mandatory ten-digit dialing begin on March 16, 2002.  Activation of 
the first central office code in the new area code will occur approximately 
sixty days after the beginning of mandatory dialing.

The WUTC has jurisdiction over the implementation of the relief plan.  FCC 
rules state:

State commissions may resolve matters involving the introduction of new area 
codes within their states.  Such matters may include, but are not limited to: 
Directing whether area code relief will take the form of a geographic split, an 
overlay, or a boundary realignment; establishing new area code boundaries; 
establishing necessary dates for the implementation of area code relief plans; 
and directing public education and notification efforts regarding area code 
changes.
  [47 C.F.R. 52.19(a)]

Discussion

Staff concurs with the industry decision to reject any geographic split of the 
existing 206, 425, and 253 area codes.  A split would have required that about 
half the customers change area codes, and given current industry planning 
guidelines, even those customers who had to change numbers would have faced the 
possibility of another number change within a few years.  Given that the larger 
surrounding 360 area is using an overlay, a split of any of the central Puget 
Sound areas was not a reasonable alternative.

However, Staff does not believe that larger overlay options were given 
sufficient consideration.  The industry group decided not to consider overlay 
options that would apply a single new area code to all of western Washington 
(360 plus 206, 253, and 425) or to all of Washington state (including 509).  
This decision was based, at least in part, on the fact that prefix holders in 
the 360 and 509 areas had not been notified that these area codes might be 
involved in a relief plan.

Staff believes that many of the reasons that led the industry to recommend a 
single overlay for 206, 425, and 253 would apply equally well to the use of a 
single overlay for all of western Washington and perhaps even a single overlay 
for the entire state.  Western Washington is already scheduled to get a new 
area code, 564, next year as an overlay in the 360 area.  Using that same area 
code to serve the central Puget Sound area may simplify customer education 
efforts, reduce the risk of wasteful use of scarce area codes, and promote 
consistent dialing among all consumers in western Washington.  

The 360 area was split from what is now 206/253/425 area in 1995, but there is 
little to distinguish the two areas from each other or to suggest that the 
distinction created in 1995 should persist now that overlays are being used 
instead of area code splits.

After the 206/253/425 plan was developed, the number administrator announced 
the need to begin relief planning for the 509 area.  The administrator will 
convene a meeting on April 6 to develop a relief plan. The notice issued by the 
number administrator stated that this would be the only meeting for developing 
a 509 relief plan.  Staff believes this is an unreasonable expectation, 
particularly considering that eastern Washington has not shared in the western 
Washington experience of receiving four new area codes since 1995.  It is far 
from certain that an overlay plan will be the preferred option for 509.  
Moreover, even if an overlay is recommended, the arguments in favor of using a 
single overlay area code weaken as it is extended to include eastern 
Washington.  However, Staff believes the all-Washington option should be given 
more analysis and consideration than has been possible so far.

Staff believes that the industry should, in addition to considering whether to 
include more areas in a single overlay plan, consider how best to coordinate 
the customer education efforts and the timing of each area code relief plan.  
It may not be feasible to implement the overlay code(s) for all of western 
Washington at the same time, but a well-coordinated implementation and 
education effort could reduce the burden on consumers and businesses.

As part of this coordination effort, Staff recommends that the industry 
consider implementing optional 10-digit dialing for all areas of western 
Washington as soon as possible.  It has been the custom to start optional 
10-digit dialing about six months before mandatory 10-digit dialing is 
scheduled to begin.  However, this means that a business may not be able to 
reprogram its dialers in the 425 area at the same time that it reprograms 
dialers in the 360 area.  Some companies have already started optional 10-digit 
dialing in all areas of western Washington.

Conclusion

Staff recommends that the Commission direct the industry to consider the 
broader overlay options discussed above and to coordinate education and 
implementation efforts among the various area code relief plans.

Attachment