BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION In the Matter of Permissive 11-Digit ) DOCKET NO. UT-001275 Dialing for Local Calls to Become ) Effective by October 2001, ) Implementing in the Seattle Local ) ORDER DIRECTING Calling Area by January 1, 2000 ) IMPLEMENTATION OF ) PERMISSIVE 11-DIGIT ) DIALING FOR LOCAL CALLS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ) BACKGROUND On August 14, 2000, Ms. Patricia Atkinson of Woodinville filed a request that telecommunications carriers be directed to offer permissive 11 (eleven) digit dialing. Currently, if a customer places a local call by dialing 1 plus the area code and telephone number, the customer receives a message stating that the call was dialed incorrectly and must be redialed. Permissive 11-digit dialing would allow local calls to go through even if dialed with a 1. Toll charges would not apply to such a call. In this state, as in most of North America, the initial 1 is used as the " toll indicator" on direct dialed calls. While the initial 1 is not needed for the telecommunications companies to route a call to the correct destination, it is required to make sure that customers understand that they are making a call for which tolls will apply. This use of a toll indicator protects consumers from incurring unintended charges, and it protects telecommunications companies from having to collect or write off charges that the customer refuses to pay. The proposed change would not alter the direct dialing method for long-distance calls, for which the initial 1 must be dialed. This proposal is precipitated, in part, by the upcoming move to mandatory 10- digit dialing in western Washington. By order dated October 20, 1999, the Commission implemented area code relief for area code 360.1 The area code relief plan approved by the Commission for area code 360 was an overlay of a new area code, 564. The Commission on May 10, 2000, approved a modified plan in which the 564 overlay code also would be implemented in the 206, 253, and 425 areas. Mandatory ten-digit dialing is scheduled to begin on October 20, 2001.2 Finally, the telecommunications industry on June 8, 2000, proposed an area code overlay B and mandatory ten-digit dialing B for the 509 area code in eastern Washington.3 The Commission has jurisdiction over the implementation of area code relief. FCC rules provide that: 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 area code, 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). The Commission has jurisdiction pursuant to RCW 80.36.610, which authorizes the Commission to conduct proceedings and take actions contemplated for action by state commissions under the Telecommunications Act of 1996. That act, as implemented by the Federal Communications Commission, authorizes state commissions to address issues surrounding area code relief plans. 47 U.S.C. § 251(e)(1); 47 C.F.R.§ 52.19(a). Permissive 11-digit dialing commonly has been implemented in areas where an area code relief plan calls for an overlay to an existing area code. See, e.g. , Colorado, Georgia, Maryland, Massachusetts, and Minnesota. Permissive 11-digit dialing for local calls will ease the impending transition from seven to mandatory ten-digit local dialing as required by the Commission's decisions described above. Mandatory ten-digit dialing is scheduled to begin on October 20, 2001. Even in circumstances outside area code relief, states historically have been involved in the implementation of local dialing plans. The Uniform Dialing Plan (No. 97-0131- 017) endorses the minimum standard to allow 11-digit dialing on a permissive basis as an adjunct to an overlay to existing state dialing plans. See also National Association of Regulatory Commissioners Resolution Concerning a Minimum Standard Dialing Plan (March 1994). The Commission has jurisdiction over telecommunications companies doing business in the state of Washington. RCW 80.01.040. MEMORANDUM At the Commission's September 27, 2000, open meeting, the Staff recommended that permissive 11-digit dialing for local calls be implemented by October 20, 2001, the date on which the 564 area code overlay will be implemented. Staff also recommended that the Commission establish an intermediate milestone of January 1, 2001 for implementation in the Seattle local calling area. According to the Staff, this change in dialing plan would more closely align the state's dialing plan with the telecommunications industry's recommended dialing plan. Staff also said that permissive 11-digit dialing would ease the transition to mandatory 10-digit local dialing by reducing the number of rejected calls. Staff noted that 11-digit permissive dialing has been part of overlay area code plans in several other states. Public Counsel, Verizon, and the Washington Independent Telephone Association (WITA) each asked that the Commission defer action on the proposal to permit further study. They raised a concern that this would weaken the "toll indicator" function of the initial 1, because some consumers may fall into a habit of dialing all calls with 11 digits and then find that they made some long-distance calls while thinking that they were making local calls. Public Counsel is concerned that such consumers will then have to pay high toll bills, while Verizon is concerned that the consumers will not pay those bills but instead ask for bill adjustments. WITA argued that some small companies need additional time to determine whether their switches and billing systems can accommodate permissive 11-digit local dialing. Besides Ms. Atkinson, the Commission received comments from several other consumers who supported the proposal to permit 11-digit local dialing. The Commission is persuaded that requiring permissive 11-digit dialing to be implemented by companies would make dialing easier for those consumers who are more concerned about the inconvenience of rejected calls than about the cost of the call should it be rated as long-distance. Over recent years, the cost of long-distance calls has decreased, the number of telephone prefixes in any given locality has increased, and the size of most local calling areas has also increased. In addition, the number of applications using automated dialers, including caller ID units, alarm systems, and computer modems, has increased. These factors all contribute to a need to make the dialing plan more flexible and forgiving. Permissive 11-digit dialing would not remove the ability of those consumers who are sufficiently concerned about toll charges to limit or avoid long-distance calls, because the toll indicator will remain a required element of any direct-dialed long-distance call. The Commission is persuaded that the implementation of permissive 11-digit dialing for local calls will make the transition to the impending new dialing patterns as simple as possible. The Commission will order the industry to implement this new dialing plan by October 20, 2001, the same date that mandatory ten-digit local dialing begins in western Washington. Permissive 11-digit dialing for local calls shall be implemented in the Seattle local calling area by January 1, 2001. CenturyTel of Washington, Inc. has identified technical obstacles to this dialing method relative to its Cowiche and San Juan switches and the Commission will grant a waiver of the requirements of this Order until such time as those switches are upgraded or replaced. The Commission will act expeditiously on other requests for waiver if small companies identify other implementation issues. FINDINGS OF FACT 1. The practice of rejecting local calls dialed with 1 and the area code and telephone number places an unnecessary burden on consumer and business customers. 2. Implementation of permissive 11-digit local dialing will not remove the ability of consumers to avoid unintended toll charges, because the toll indicator will remain a required element of any direct-dialed long-distance call. 3. Permissive 11-digit local dialing will facilitate the transition to mandatory ten-digit local dialing, which has been approved for western Washington in October 2001, and proposed for eastern Washington in 2002. 4. It is in the public interest to implement permissive 11-digit dialing by October 20, 2001. A waiver may be granted where permissive 11-digit dialing is not technically feasible. Under those circumstances, permissive 11-digit dialing should be made available upon switch upgrade or replacement. CONCLUSIONS OF LAW 1. The Commission has jurisdiction pursuant to RCW 80.36.610, which authorizes the Commission to conduct proceedings and take actions contemplated for action by state commissions under the Telecommunications Act of 1996. That act, as implemented by the Federal Communications Commission, authorizes state commissions to address issues surrounding area code relief plans. 47 U.S.C. § 251(e)(1); 47 C.F.R. § 52.19(a). 2. The Commission has jurisdiction pursuant to RCW 80.01.040. ORDER THE COMMISSION ORDERS: 1. All local exchange companies doing business in the state of Washington shall implement permissive 11 (eleven) digit dialing for local calls by October 20, 2001. Permissive 11-digit dialing for local calls shall be implemented in the Seattle local calling area by January 1, 2001. 2. The Commission grants a waiver of the requirement set forth in 1. above to CenturyTel of Washington, Inc. for its Cowiche and San Juan switches where permissive 11-digit dialing is not technically feasible until such time as those switches are upgraded or replaced. DATED at Olympia, Washington, and effective this ____ day of September, 2000. WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION MARILYN SHOWALTER, Chairwoman RICHARD HEMSTAD, Commissioner WILLIAM R. GILLIS, Commissioner Footnotes 1) In the Matter of Area Code Relief for the 360 Number Plan Area, Docket No. UT-990219 (October 20, 1999). 2) In the Matter of Area Code Relief for the 206, 253, 425 Number Plan Area, Docket No. UT-991535 (May 10, 2000). 3) In the Matter of Area Code Relief for the 509 Number Plan Area, Docket No. UT-000202 (June 8, 2000).