Agenda Date: May 10, 2000 Item Number: Docket: UT-991535 - Area Code 206/253/425 Relief Plan Company Name: Telecommunications General Staff: Glenn Blackmon, Assistant Director-Telecommunication David Dittemore, Telecommunications Engineer David Griffith, Telecommunications Engineer Betty Erdahl, Policy Research Specialist Recommendation: Approve a single all-services overlay for the 206, 425, and 253 area codes using the 564 area code that is already planned for implementation in the 360 area code, with implementation of mandatory 10-digit dialing on October 20, 2001. Background The telecommunications industry in February 2000 asked the WUTC to approve a new overlay area code for the central Puget Sound region (parts of King, Pierce, and Snohomish counties). Under the industry plan, customers would be required to begin dialing the area code and phone number on all local calls starting March 16, 2002. The new area code would be put into service about two months later. The industry is planning for an additional area code in this area because it anticipates running out of telephone prefixes. Additional prefixes are being used as customers sign up for additional services and as more companies make plans to offer telecommunications service in the area. At its March 10, 2000 open meeting, the WUTC deferred action on the industry plan and directed it to consider alternative plans. The WUTC did not take issue with the proposed use of an overlay area code, because further splits of these area codes would be impractical. However, the WUTC said that the industry should consider using a single overlay for all of western Washington or even the entire state, alternatives that were not given sufficient consideration at the single meeting in January 2000 at which an area code relief plan was developed. In addition to the proposed new area code for central Puget Sound, western Washington also faces the prospect of area code changes in the 360 area. The WUTC has approved an overlay plan for the 360 area, and the new area code will be 564. This new area code is currently scheduled to begin service in February 2001. While the WUTC's jurisdiction over the use of telephone prefixes and numbers is generally limited, it has jurisdiction over the implementation of relief plan such as the one currently before it. 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)] Benefits of a Single Overlay for Western Washington Since the March 10 open meeting, Staff has engaged in informal discussions with the telecommunications industry on the question of whether the 564 overlay code should be applied to all of western Washington or whether a second overlay code should be used for the central Puget Sound region. In addition, because the 509 area code in eastern Washington is now also scheduled for relief, Staff has discussed the possibility of using a single overlay area code for the entire state. These alternatives were discussed with the industry at a meeting on April 28. Based on these discussions, Staff believes that the WUTC should adopt a plan in which the 564 area code is used as an overlay area code for all of western Washington instead of approving the industry plan to use separate overlay area codes. The benefits of this integrated approach to area code relief in western Washington are • A single new area code for western Washington is easier to explain to consumers and businesses. The industry faces a difficult task of educating its customers on the need for 10-digit dialing of all local calls and the fact that multiple area codes are being used in a single area. This task would be further complicated if the "new" area code will vary from one locality to the next. Ease of explanation was cited as a reason by the industry to recommend a single overlay for the three central Puget Sound area codes. Staff believes that same factor argues for extending the overlay to include all of western Washington. • Using a single overlay code will postpone and possibly eliminate the need for a sixth area code in western Washington. The telecommunications industry is under orders from federal and state regulators to improve the efficiency with which it uses telephone numbers. Those efficiency measures, such as allocating numbers to companies in smaller blocks and having prefixes cover wider geographic areas, will reduce the need for additional area codes. If the WUTC permits the addition of two more area codes now, at least one of those could end up being redundant because of increased efficiency, but there would be no practical way to cancel it. Under the worst-case scenario, in which the industry makes no efficiency improvements, the sixth area code still could be delayed for about three years. • Using two overlay codes would not preserve any meaningful geographic or political distinction within western Washington. Opinions vary on this point, but Staff does not believe that the 360 area is distinct from the 206/425/253 area. The 360 area was split from what is now the 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. News and advertising coverage extends well beyond the central Puget Sound area into portions of 360. The Puget Sound region includes cities such as Olympia and Bremerton, and smaller towns such as North Bend, Monroe, Black Diamond, and Poulsbo, that today have the 360 area code. The region's daily economic, social, and educational activities routinely cross the boundary between the 360 area and the area served by 206, 253, and 425. Adjustment to Implementation Dates The industry relief plan for 206, 425, and 253 recommends that mandatory 10-digit dialing become effective on March 16, 2002, and that customer notification begin on June 16, 2001. Staff recommends that these dates be moved forward, so that mandatory 10-digit dialing begins on October 20, 2001. Staff believes that the industry should adopt a single plan for educating consumers and businesses in western Washington on the use of overlay area codes and the need to perform 10-digit dialing. A coordinated education and advertising plan will be more effective and efficient if all parts of the region are converting within the span of a few months. In addition to recommending an earlier implementation date for 206/425/253, Staff believes the WUTC should continue to pursue efforts that could permit further delay to the current February 2001, date for area code 360 to begin mandatory 10-digit dialing. The FCC has recently adopted a rule that, when it becomes effective, will permit the WUTC to require that telephone companies return prefixes that have not been put into use. A second reason for advancing the date of the overlay area code in central Puget Sound is that the industry expects to be implementing an area code relief plan in eastern Washington in early 2002. The industry last month decided to recommend a separate overlay area code for the 509 area code. The industry has advised Staff that it would be better to avoid implementing new area codes on both sides of the state in the same time period. This concern can be alleviated by moving the 206/425/253 overlay ahead several months. Education and Permissive Dialing Plans Staff recommends that the industry be directed to develop a coordinated education plan consistent with the use of a single overlay for western Washington. While Staff believes the use of a single overlay will make it easier to explain this change to the public, it still will not be an easy task. The use of ten-digit dialing for local calls represents a fundamental change in dialing patterns for many consumers, especially those outside the 206 and 425 areas of King County. Staff recommends that the industry develop an education plan and submit it for WUTC approval by July 1, 2000. The normal industry practice is to begin "permissive" ten-digit dialing six months before the ten- digit dialing becomes mandatory and to begin customer education efforts at about the same time. In this case, however, Staff believes that the standard six-month interval is not appropriate. Customers in central Puget Sound will be exposed to news and advertising messages on ten-digit dialing as early as September 2000, which is when the education efforts for 360 are likely to begin. The industry should be prepared to complete any ten-digit local call in western Washington when the initial public education effort begins. Conclusion This fall the telecommunications industry will begin a major effort to introduce 10-digit dialing in western Washington. Staff believes that this effort can be more successful if the new dialing methods and area code definitions are introduced on a consistent basis. This is best accomplished by: (1) using a single area code, 564, for all areas of western Washington and (2) adjusting the implementation schedule to narrow the interval between the time 10-digit dialing begins in area code 360 and the time it begins in the 206, 253, and 425 areas.