Agenda Date: February 23, 2000 Item Number: Docket: UT-990219 - Area Code 360 Relief Plan UT-991627 - Telephone Number Conservation Company Name: Telecommunications General Staff: Glenn Blackmon, Assistant Director - Telecommunications Rebecca Beaton, Program Manager/Consultant - Telecommunications David Dittemore, Telecommunications Engineer David Griffith, Telecommuniciations Engineer Recommendation: 1. In Docket UT-990219, issue an order directing each code holder in the 360 area to report by March 15, 2000 the current utilization of each telephone prefix. 2. In Docket UT-990219, issue an order directing the numbering administrator to modify the 360 jeopardy procedures to reduce the base quantity of prefixes that may be assigned each month from 12 to 7. 3. In Docket UT-990219, issue an order suspending the July 29, 2000 implementation date for mandatory 10-digit dialing and directing the North American Numbering Plan Administrator to reconvene the 360 industry group for the purpose of establishing a new implementation date not earlier than February 1, 2001. 4. In Docket UT-991627, issue an order directing the Washington Exchange Carrier Association to submit by August 1, 2000 an implementation plan for a number pooling trial within the 360 area to take effect no later than October 1, 2000. Discussion Last year the telecommunications industry determined that it was running out of three-digit prefixes within the 360 area code, which itself had been created only four years earlier. The industry developed a "relief plan" in which a new code, 564, would be overlaid on the 360 area starting July 29, 2000. The WUTC accepted the plan at its September 29, 1999 meeting. The WUTC has continuing jurisdiction over the implementation of the relief plan. Federal rules state: 47 CFR 19 Area code relief. (a) 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; Dockets UT-990219/UT-991627 February 23, 2000 Page 2 establishing necessary dates for the implementation of area code relief plans; and directing public education and notification efforts regarding area code changes. Staff continues to believe that the decision last year to use an overlay for area code relief was appropriate. An overlay avoids the need for any customer to change a telephone number. A split would have required that half the customers change their numbers, and under current industry guidelines there would have been no assurance that customers would not have had to change numbers again within a few years. While an overlay remains in western Washington's future, several developments since last year's decision lead Staff to believe that the overlay should be delayed for six months. Staff believes it is worthwhile to take advantage of this opportunity because doing so will (a) postpone the burdens on customers of 10-digit dialing and a new area code, (b) provide the telecommunications companies with an opportunity to demonstrate that it is making every reasonably effort to use efficiently the telephone prefixes they already have, and (c) permit greater coordination of the public education efforts in other areas of western Washington where 10-digit dialing is on the horizon. Recent Developments Since the 360 area code relief plan was prepared last year, the industry and regulators have taken steps to improve the efficiency of telephone prefix use and have learned more about the pace at which telephone prefixes are being reserved. These developments include: • Rate center conservation efforts - In November, the WUTC ordered the telecommunications industry to investigate the possibility of consolidating rate centers. With rate center consolidation a telephone prefix can be spread over a larger geographic area. • Improved use of rate centers - On February 1, U S WEST dropped a requirement that interconnecting companies have a different prefix in each rate center. Many local calling areas include multiple rate centers, and eliminating this requirement will permit entrants to use a single prefix to serve an entire local calling area. • Number consumption - The industry adopted a rationing procedure in April 1999 to slow the exhaustion of the 360 prefixes. Since that procedure was put in place, the requests for prefixes has actually been slightly lower than the ration level. • Prefix exhaustion in the rest of Washington state - In November, the number administrator notified the industry and the WUTC of the need to begin relief planning for the 206 and 425 area codes. In January, the industry adopted an overlay plan for the entire central Puget Sound area (206, 425, and 253). Finally, on February 14, the number administrator notified the industry and the WUTC of the need to begin relief planning for the 509 area code. • Number pooling - The Federal Communications Commission last fall began granting states additional authority to require that the telecommunications industry pool or share telephone prefixes. The WUTC petitioned in December for such authority. In addition, the industry has made considerable progress in developing both operating guidelines and software for number pooling. With these changes, it is more likely that number pooling could be implemented in the 360 area. Public Education Considerations Staff recognizes that a change in the relief plan to postpone the 564 implementation date could engender confusion among the public about when 10-digit dialing will become mandatory. The industry has already begun its educational effort on the need for 10-digit dialing and the introduction of a new area code. The need to avoid confusion and additional education efforts must, however, be balanced against the burden that will be placed on consumers and businesses once mandatory 10-digit dialing and a new area code are imposed. Even if this burden is inevitable – and it appears that it is in western Washington – it should be imposed only after the industry has taken all reasonable steps to use the existing supply of numbers efficiently. Moreover, Staff believes that the educational effort can be coordinated among the four western Washington area codes, since all now face the prospect of mandatory 10-digit dialing. Whether the new 564 area code is applied as an overlay to all four existing area codes or separate overlays are used, it may be much easier to prepare customers for the change if the implementation for 360 is coordinated with the implementation for 206/425/253. Finally, Staff notes that, even if the mandatory date is postponed, any changes that customers make in anticipation of that date, such as reprogramming automatic dialers, will still be effective since permissive 10-digit dialing has already started. Any customer who has already prepared for mandatory 10-digit dialing will not have to undo those preparations. Proposed Actions Reduced allocation of prefixes - By restricting the number of prefixes issued each month from 12 to 7, implementation of 10-digit dialing can be postponed until February 2001. Under the prefix rationing rules adopted by the industry, new companies would get priority in the assignment of the remaining prefixes. If more companies requested prefixes than could be allocated in a month, the prefixes would be assigned by lot. Staff believes that prefix rationing could impose some hardship on the industry but that these hardships will not be unreasonable. Increased reporting of number utilization - The number utilization report will determine how companies are using the telephone numbers they have already received. If each company carefully assesses its store of numbers, some may find that prefixes are not being effectively used and could be returned to the pool. It is particularly important that companies review their prefix assignments in light of the recent rate center changes noted above, since these could enable companies to return prefixes to the pool. Number pooling implementation plan - Finally, Staff believes that the industry should begin preparing now for implementation of number pooling in the fall. The industry has made considerable progress in recent months in developing the general guidelines for number pooling and for improving the software used to pool numbers. However, this work has been done at the national level, and work needs to begin now to prepare for implementation in western Washington. The WUTC has already established an industry work group, which operates through the Washington Exchange Carrier Association, and this group should be given the charge to prepare for an October 1, 2000 implementation date. Conclusion Staff has actively monitored the progress of telephone number conservation efforts at both the national and state level. Staff continues to believe that an overlay is the best method of providing area code relief, but it should happen only when it is necessary. With aggressive action by the WUTC and by the industry, it is reasonable to postpone implementation of mandatory 10-digit dialing in the 360 area until next year. Attachment