Agenda Date: November 29, 2000 Item Number: Docket: UT-991627 – Telephone Number Conservation Company Name: Telecommunications General Staff: David Dittemore, Telecommunications Engineer Betty Erdahl, Policy Research Specialist Glenn Blackmon, Assistant Director-Telecommunications Recommendation 1. Issue an order directing the telecommunications industry to implement a number pooling trial in the Spokane metropolitan statistical area by July 8, 2001. 2. Direct Staff to solicit comments and reply comments on cost allocation and cost recovery issues associated with number pooling. Background At its November 8, 2000 meeting, the WUTC considered a recommendation from Staff to implement a number pooling trial. This memorandum updates the information and recommendation made at that meeting. The telecommunications industry was scheduled to meet on November 28, 2000 to discuss the issues raised at the November 9, 2000 open meeting. The open meeting schedule required that Staff prepare its recommendation before this industry meeting. Staff's initial recommendation had been to implement number pooling in western Washington. Staff no longer recommends that the WUTC pursue pooling in this area but instead focus its efforts on the 509 area code in eastern Washington, starting with the Spokane metropolitan statistical area, which consists of Spokane County. The telecommunications industry has projected that area code 509 will run out of prefixes in April 2002 and has recommended that the WUTC approve an overlay area code there. Public education for any area code relief would likely begin in fall 2001. Number pooling can be expected to extend the life of the 509 area code, because it allows companies to use more of the telephone numbers within each prefix. Staff cannot estimate the expected life of the area code with number pooling, but more efficient use of the existing supply of telephone numbers could well permit area code 509 to avoid relief for several years. Under the implementation schedule developed by the industry, number pooling could be implemented on July 8, 2001. This would provide several months for the WUTC and the industry to assess the effectiveness of number pooling before having to decide whether to start the public education campaign for a new area code. Basis for Revised Recommendation The reasons for this change in recommendation include: · Pooling is more likely to be effective in area code 509 – At the Nov. 9 meeting, several telecommunications industry representatives cautioned the WUTC that number pooling in western Washington would not eliminate or even significantly delay the need to require 10-digit dialing in October 2001. The industry argues that, because area code 360 has reached virtual exhaustion, it is inevitable that area code relief will be needed at least within that area. Most industry members did not object to number pooling in western Washington but did not want the WUTC to delay the 10-digit-dialing date. By contrast, area code 509 is further from exhaustion, so there is a greater chance that number pooling would be effective in avoiding or delaying area code relief. · Pooling in area code 509 can be implemented on a more reasonable schedule – The recommended implementation plan for western Washington is very tight because of the need to complete implementation before the new area code is introduced in October 2001. The schedule requires that companies implement pooling in four area codes over several months and leaves essentially no room for delay or for assessment of whether number pooling is effective. In particular, any delay in the release of new number pooling software would endanger successful implementation of the western Washington plan. Number pooling in eastern Washington could start later and would be less sensitive to schedule delays, particularly since it involves only one area code and significantly fewer switches. · Much of western Washington will be covered by the national pooling plan – The Federal Communications Commission's national pooling plan will include large parts of western Washington, namely Island, King, Snohomish, Pierce, Clark counties. A state pooling program in western Washington would only result in earlier implementation in those areas. Spokane is not part of the national pooling plan, so implementation of a state program there would result in pooling that would not occur as part of the national plan. · The cost of a pooling program will be less in area code 509 – Area code 509 has fewer switches and therefore lower costs than the four western Washington area codes. If the WUTC decides to proceed with number pooling in eastern Washington, that would not preclude it from ordering number pooling in western Washington. Depending on the FCC's progress at developing a national schedule, the WUTC might consider number pooling for the new 564 overlay area code when it is implemented in western Washington. Conclusion Staff believes that number pooling in western Washington is not the most effective use of the resources of the WUTC and the industry and could distract from the necessary effort to implement the 564 area code overlay and 10-digit dialing. The focus of number pooling should instead shift to eastern Washington. _______________________________________ The industry may have different views on whether the entire 509 area code should begin pooling on July 8 or whether the initial area should be only metro Spokane area. Staff recommends that the WUTC order only the Spokane area at this time and address the remainder of 509 only if the industry does not agree to include it in the initial implementation. In any event, only those rate centers where local number portability is implemented would be included in any number pooling plan.