Agenda Date: September 27, 2000 Item Number: 2A Docket: UT-001275 Telecommunications General Staff: Betty Erdahl, Policy Research Specialist Dave Dittemore, Telecommunications Engineer Glenn Blackmon, Assistant Director, Telecommunications Recommendation: 1. Issue an order directing all local exchange companies to implement permissive 11 (eleven) digit dialing for local calls to become effective by October 20, 2001, implementing in the Seattle local calling area by January 1, 2001. 2. Grant a waiver where permissive 11-digit dialing is not technically feasible for CenturyTel of Washington, Inc.s’ Cowiche and San Juan switches, on a temporary basis, until the switches are upgraded to include this capability. Background: On August 14, 2000, Patricia Atkinson filed a request that telecommunications carriers allow permissive 11 (eleven) digit dialing. Currently, if a customer makes a local call using 1, a message is received stating that the call was dialed incorrectly and must be redialed. Permissive 11-digit dialing would allow a local call to go through even if dialed with a 1, however toll charges would not apply. Regardless, to make a long distance call, a 1 must be dialed. Therefore, if a consumer would like to avoid making a toll call or be able to determine whether a call is long distance, they could dial without the 1 first and if the call is not completed, it would have to be redialed using a 1 and toll charges would apply. Requiring permissive 11-digit dialing to be implemented by companies will make dialing easier for those consumers who are indifferent to whether toll charges are incurred or who have automated dialers. Automatic dialers, when reaching a busy signal will redial, but do not know what to do when reaching a redial message. Permissive 11-digit dialing has been implemented where there was an overlay to an existing area code in Atlanta, Denver, California, Maryland, Minnesota and New Jersey. Staff analysis: Staff supports this petition. In fact, the Industry Numbering Committee’s Uniform Dialing Plan (No. 97-0131-017) endorses the minimum standard to allow 11-digit dialing on a permissive basis, while maintaining the ability to determine whether a call is toll or local. See NARUC (National Association of Regulated Utilities) Resolution Concerning a Minimum Standard Dialing Plan dated March 1994. With this in mind, staff believes the Commission should adopt this new dialing plan in the State of Washington. Staff believes that permissive 11-digit dialing ties in well with the upcoming mandatory ten-digit dialing in the state (October 20, 2000). Upon the 564 area code overlay of Western Washington, a customer will not necessarily know whether a 564 phone call is a toll call or a local call. Staff believes that a bill message along with media coverage is sufficient customer notice and that additional customer notice could be rolled into the 564 education plan which is currently being developed. Interested parties’ positions: Public Counsel is concerned about whether consumers would become accustomed to dialing 11-digits and later be surprised by the toll charges on their phone bill. This could lead to increased consumer complaints. Qwest has first had experience with implementation of permissive 11-digit dialing in California, Denver, Colorado and Minneapolis/Saint Paul area of Minnesota. The Company did very limited (if any) advertising. Qwest reports no negative customer reaction in the states where the dialing plan was changed to allow 11-digit permissive dialing. Additionally, as toll prices decrease, many consumers are indifferent to whether a call is toll or local. Public Counsel and the companies have raised questions and concerns regarding this request. Although they are sympathetic to the frustration and confusion customers may feel, they are concerned that in trying to address this issue we may create new or unintended problems. Public Counsel recommends the Commission conduct further review of this issue before adopting permissive 11-digit dialing as a solution. In addition, some local companies have raised a concern about the cost of changing their switches. No additional equipment or software is required, but company personnel would have to spend several hours per switch to set up the permissive 11-digit dialing method. Qwest has estimated a cost of $100,000 to complete this translation work in conjunction with the work they are doing to get ready for the 564 area code overlay in October 2001. CenturyTel of Washington, Inc. has two Stromberg switches that are nearly technically incapable of permissive 11-digit dialing. These switches are in Cowiche and the San Juan exchanges. The San Juan switch is scheduled to be replaced in 2001. Other small independent telephone companies may have this type of switch, too. If so, they would need a waiver until such switches were upgraded. Customer Comments: The Commission received eighteen letters urging the Commission to approve the petition to allow 11-digit dialing for all local calls. The customers who commented experience confusion and frustration when dialing numbers and hearing messages from the phone company saying that they must redial since the number they are trying to dial is either long distance or local. The customers believe that if 11-digit dialing is permitted, they will waste less time. The customers also believe that, with the addition of another area code, the problem will become worsen. Conclusion: 1. Staff recommends the Commission issue an order directing all local exchange companies to implement permissive 11-digit dialing for local calls to become effective by October 2001, implementing in the Seattle local calling area by January 1, 2001. 2. Grant a waiver where permissive 11-digit dialing is not technically feasible for CenturyTel of Washington, Inc.’s Cowiche and San Juan switches, on a temporary basis, until the switches are upgraded to include this capability.