28819.mod.doc

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE PETITION OF THE
NORTH AMERICAN NUMBERING PLAN
ADMINISTRATOR FOR THE APPROVAL OF
NUMBERING PLAN AREA RELIEF FOR THE
208 AREA CODE. )
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) CASE NO. GNR-T-00-36

NOTICE OF MODIFIED PROCEDURE
NOTICE OF COMMENT DEADLINE

ORDER NO. 28819

On October 27, 2000, a Petition for telephone area code relief was filed by NeuStar, Inc., the North American Numbering Plan Administrator (Administrator, NANPA). The NANPA is appointed by the Federal Communications Commission (FCC) to manage the exhaustion and issuance of telephone area codes. In its Petition, the Administrator projected that Idaho’s “208” area code would run out of telephone numbers (i.e., “exhaust”) in the first quarter of 2003. In May 2001, NeuStar updated its projection to indicate that the supply of telephone numbers for the “208” area code will exhaust during the third quarter of 2003. The Administrator’s Petition represents that it was filed on its own behalf and that of “the Idaho Telecommunications Industry” (Industry), which the Petition states “is composed of current and prospective telecommunications carriers operating in, or considering operations within, the state of Idaho.” In this Order the Commission discusses the possibility of a technology-specific overlay, an option not presented in the Petition, as well as two preferred options to effectuate a geographic split of area codes in the event a technology-specific overlay is found to be infeasible or undesirable. The Commission directs that this case be processed under Modified Procedure and establishes a deadline for written comment.
THE PETITION
NeuStar projects that the supply of telephone numbers for the “208” area code will exhaust during the third quarter of 2003. The Petition asserts that the Administrator convened a telecommunications industry meeting in Boise on September 28, 2000, to review and discuss alternatives for relief of the “208” Number Plan Area (NPA). The meeting participants reviewed the various alternatives and reached consensus to recommend to this Commission an all-services distributed “overlay” plan as the preferred means of relief for the “208” area code or NPA. The Petition asserts the Industry members recommend the overlay alternative because telephone customers do not need to change their area codes, its projected life of 10 years is longer than the projected lives of the other alternatives, and it does not reduce the geographic size of the NPA. The overlay plan endorsed by NeuStar would require 10-digit dialing for all local calls within and between the 208 NPA and the new overlay NPA.
Two other viable alternatives discussed in the September 28, 2000 industry meeting proposed splitting the state geographically into separate area codes. Both of the plans call for the state to be divided south of White Bird in the north and on either the western or eastern edge of the Magic Valley in the south, thus separating southwestern Idaho from northern and eastern Idaho. Unlike the overlay plan recommended by NeuStar and the telecommunications industry, these plans would retain 7-digit dialing for local calls within each area code for the present time. It should also be noted that a plan to split northern and southern Idaho was initially considered, but was rejected because it did not meet federal NPA relief guidelines.
The Petition recommends, if the Commission approves the overlay plan endorsed by NeuStar and the Idaho Telecommunications Industry, that permissive 10-digit dialing begin on January 12, 2002, and the conversion to mandatory 10-digit dialing begin on July 13, 2002. The Petition states that adhering to the proposed time frame will avoid the denial or delay of services to telecommunications customers due to the unavailability of telephone numbers.
The Petition did not mention the possibility of a service-specific or technology-specific overlay, presumably because such an overlay is currently prohibited by the Federal Communications Commission (FCC). However, the FCC is reconsidering this prohibition. In its Second Report and Order on Reconsideration in CC Docket No. 96-98 and CC Docket No. 99-200, and Second Further Notice of Proposed Rulemaking in CC Docket No. 99-200, released December 29, 2000, the FCC said:
We conclude that we should revisit the prohibition against service-specific and technology-specific overlays. We are persuaded by commenters who argue that this action is warranted by changes in the use of numbering resources that have occurred since the Commission’s previous decisions. State commissions, in particular, have urged that we permit them to implement service and technology-specific overlays to address the escalating demand for numbering resources. They argue that there is widespread public support for such overlays, especially as a means of avoiding new area codes for home and business phones. By temporarily diverting a portion of the demand for numbering resources in existing area codes, implementation of service- or technology-specific overlays may help ease the transition to needed area code relief prior to the complete implementation of pooling, reducing end-user costs and inconveniences.

(Paragraph 128)
PROCEDURAL HISTORY
Following receipt of NeuStar’s Petition on November 9, 2000, the Commission issued a Notice of Petition on January 2, 2001. The Notice set an intervention deadline of January 29, 2001. Century Telephone of the Gem State, Century Telephone of Idaho, Potlatch Telephone Company, Troy Telephone Company, Idaho Telephone Association, Qwest Corporation, Verizon Northwest Inc., and Verizon Wireless requested and were granted intervenor status. IDAPA 31.01.01.071 and -.075.
METHODS OF AREA CODE RELIEF
Geographic Split
The geographic split relief option would draw a line through the existing area code, assigning a new area code to telephone customers on one side of the line and retaining the existing area code for customers on the other side of the line.
All-Services Overlay
To implement an all-services overlay area code, a second area code would be added to the same geographic area as the existing area code. All existing phone numbers would retain the original area code, but new telephone customers for local phone service assigned in the same geographic area would receive the new overlay area code. Thus, no one would have to go through all the expense of printing new stationary and contacting all their customers and friends with their new phone number. However, all telephone calls made in the overlay area would require 1+ 10-digit or 10-digit dialing – even calls currently dialed with seven-digits in the same area code.
Technology-Specific Overlay
A technology-specific overlay would allow some technologies to keep the current 208 area code while requiring others to change. This option could, for example, allow all wired telephone customers in Idaho to retain area code “208,” while wireless (e.g., cellular) telephones and pagers would have a new area code. This option, if allowed by the FCC, would likely allow wired telephone customers more years of area code stability and would allow several other number conservation efforts time to further expand area code lives. This option might also require 10-digit dialing to differentiate between the two area codes.
Preliminary Commission Finding
The Commission preliminarily finds that the technology-specific overlay may offer the most benefits for least costs to the public. Nevertheless, it has at least three problems. First is the FCC’s current prohibition, second is the question of whether it can be implemented before the “208” area code is exhausted and third is the probability that some wireless carriers may believe it will disadvantage them. We ask that all parties interested in this option, either pro or con, comment on it.
Of the other two options presented to us, i.e., an all-services overlay and a geographic split, we note that the Petition correctly states that the overlay alternative would not cause any current telephone customers to change their “208” area code, would have a longer projected life than any of the geographic splits, and would not reduce the geographic size of the NPA. The Commission received approximately 111 public comments responding to the Notice of Petition issued on January 2, 2001. Although the Commission had not yet initiated a formal comment period, those who responded almost unanimously objected to the prospect of 10-digit dialing for local calls that would be required by an all-services overlay. Given this public sentiment and the fact that Idaho’s telecommunications providers would not be significantly harmed by a geographic split, the Commission preliminarily finds that a geographic split is the better of these two alternatives. However, proponents of an all-service overlay may still present evidence in their comments to persuade the Commission to alter its preliminary findings. We now turn to a more detailed discussion of specific geographic split options.
GEOGRAPHIC SPLIT OPTIONS
Before it will assign a new area code, the FCC requires that the relief plan approved by the Idaho Public Utilities Commission comply with the constraints set forth in its “NPA Code Relief Planning & Notification Guidelines.” For example, the FCC requires that geographic NPA boundaries follow rate center or exchange boundaries. Furthermore, the relief options must extend for a period of at least five years beyond the predicted exhaust date. The FCC also mandates that the relief plan shall result in the most effective long-term use possible of all area codes serving a given area. Ideally, the area codes in given geographic splits should exhaust about the same time. Although this may not be possible in practice, the FCC requires that severe imbalances resulting in a difference in NPA lifetimes of more than 15 years be avoided. The FCC also recommends that customers who undergo number changes not be required to change again for a period of 8 to 10 years.
On September 28, 2000, the Administrator, Commission Staff and Industry members reviewed the following geographic split options:
Option #1: A two-way geographic split running from the White Bird to the Malta rate centers, separating the southwestern portion of the 208 NPA from the rest of the NPA. The projected exhaust of the southwestern portion (including the Magic Valley) of the 208 NPA is 8 years, while the rest of the NPA is projected to exhaust in 13 years. For more information, please consult the map labeled as “Attachment 1.”

Option #2: A two-way geographic split running from the White Bird to the Grasmere Riddle rate centers, separating the southwestern portion of the 208 NPA from the Magic Valley and the rest of the NPA. The projected exhaust of the southwestern portion of the 208 NPA is 14 years, while the rest of the NPA is projected to exhaust in 8 years. For more information, please consult the map labeled as “Attachment 2.”

Option #3: A two-way geographic split running from the Leadore to the Grasmere Riddle rate centers, separating the northwestern portion of the 208 NPA from the rest of the NPA. The projected exhaust of the northwestern portion of the 208 NPA is 6 years, while the rest of the NPA is projected to exhaust in 18 years. For more information, please consult the map labeled as “Attachment 3.”

Option #4: A two-way geographic split running along the 652 Local Access and Transport Area (LATA) line near White Bird, separating northern Idaho from central and southern Idaho. The projected exhaust of the northern portion of the 208 NPA is 41 years, while the central and southern portion of the NPA is projected to exhaust in 3 years. For more information, please consult the map labeled as “Attachment 4.”

Option #5: A two-way geographic split running from the Weiser to the Malta rate centers, separating the southwestern portion of the 208 NPA from the rest of the NPA. The projected exhaust of the southwestern portion of the 208 NPA is 8 years, while the rest of the NPA is projected to exhaust in 13 years. For more information, please consult the map labeled as “Attachment 5.”

Option #6: A two-way geographic split running from the Weiser to the Malta rate centers, but includes more of central Idaho with the southwest than Option #5. The projected exhaust of the southwestern portion of the 208 NPA is 7 years, while the rest of the NPA is projected to exhaust in 14 years. For more information, please consult the map labeled as “Attachment 6.”

Option #7: A two-way geographic split running from the Weiser to the Three Creek rate centers, separating the southwestern portion of the 208 NPA from the rest of the NPA. The projected exhaust of the southwestern portion of the 208 NPA is 13 years, while the rest of the NPA is projected to exhaust in 8 years. For more information, please consult the map labeled as “Attachment 7.”

Option #8: A three-way geographic split, with a split line separating southwestern Idaho from the rest of the state and a split line separating the northern portion from the eastern and central portions of the state. The northern portion is projected to exhaust in 35 years, the southwestern portion in 13 years, and the central and eastern portion in 16 years. For more information, please consult the map labeled as “Attachment 8.”

Preliminary Commission Findings
After reviewing the geographic split options described above, the Commission preliminarily finds it reasonable to narrow the options under consideration to those most advantageous to a majority of Idahoans. The Commission agrees with Industry that Option #3 is not attractive because the projected lives of the resulting NPAs are unbalanced and would soon require a third area code. Although frequently favored in public comments, the Commission cannot consider separating northern and southern Idaho as set forth in Option #4. The FCC would not release a new area code to Idaho under Option #4 because it violates NPA Relief Planning Guidelines prohibiting NPA lifetime imbalances greater than 15 years and relief of less than 5 years.
The Commission also agrees with Industry that the geographic splits contemplated in Options Nos. 5 and 7 would disrupt existing extended area service routes and communities of interest. The projected lives of the NPAs created by Option #6 would be somewhat unbalanced and would split EAS routes, such as Midvale to Weiser. The three-way split envisioned by Option #8 is less desirable because it would disrupt current extended area service (EAS) routes, use an unnecessary third area code, and potentially cause more confusion than a two-way split. Consequently, the Commission preliminarily finds it reasonable to eliminate from consideration Option Nos. 3, 4, 5, 6, 7 and 8.
Option Nos. 1 and 2 are attractive because they have relatively balanced projected area code lifetimes, disrupt a minimum of existing EAS routes or communities with common interests, and preserve 7-digit dialing for local calls within each area code for the present time. Consequently, the Commission preliminarily finds that Option Nos. 1 and 2 deserve consideration and should be the focus of industry, Staff and public comments.
Persons favoring implementation of a geographic split should comment on: 1) whether a geographic split is preferable to a technology-specific overlay; 2) which geographic split option should be implemented; 3) whether a better geographic split exists that the Commission did not consider (e.g., one that better equalizes the projected lives of the two area codes while minimizing disruption to communities of interest and EAS); and 4) which region should retain the “208” area code. In regards to comments addressing which region should retain the “208” area code, commentors should address the appropriateness of implementing the FCC’s guideline that the area with the longest projected area code life after the split is the one that should have the initial area code change.
NUMBER CONSERVATION EFFORTS
Although number conservation may slow the need to implement a new area code, the FCC makes it clear that number conservation is not a substitute for area code relief. To this end, the Commission and its Staff are presently pursuing several number conservation measures in addition to establishing an area code relief plan.
Rate Center Consolidation
Calls are routed between rate centers, which represent specific geographic areas, much like the postal service uses zip codes to route mail. Although an area code contains many separate rate centers, prefixes are assigned to carriers for use within a single rate center to prevent improper billing or routing of calls. By consolidating rate centers, carriers are able to serve larger areas with fewer prefixes, thereby reducing the need for numbers. Although it may not postpone exhaust of the “208” area code, rate center consolidation is a foundation that defines the effectiveness of other number conservation efforts such as number pooling. Specifically, numbers are to be pooled for use by other carriers within a rate center.
The Commission has an open Qwest Rate Center Consolidation docket in Case No. GNR-T-99-21. If approved by the Commission, Qwest would reduce its number of southern Idaho rate centers from 48 to 19.
Number Pooling
Thousand-block number pooling allows phone numbers to be allocated to service providers in blocks of 1,000 numbers instead of the network-mandated 10,000 numbers, thus making the remaining 9,000 numbers in the prefix available to other providers in the same rate center. By conserving numbers and providing for more efficient number utilization, number pooling can significantly extend the life of an area code.
The Idaho Public Utilities Commission must receive delegated FCC authority to implement number pooling. Through its National Pooling Administrator, the FCC intends to begin number pooling in March 2002 in states that currently have delegated authority and are in the top 100 metropolitan statistical areas (MSAs). Because the Commission does not currently have delegated authority and is not in the top 100 MSAs, Idaho will not receive number pooling authority prior to the exhaust of the “208” area code. However, the Commission may petition the FCC for delegated authority to implement number pooling in Idaho and/or to move into the group that will receive number pooling more quickly.
Number Reclamation
Telecommunications industry guidelines specify a process by which the Administrator can reclaim prefixes that have been assigned to carriers but which are not in use. Upon giving 60-day notice to the Administrator, states can assume authority to reclaim prefixes that have been assigned but not activated by telecommunications carriers within 6 months. Because number reclamation postpones exhaust of the 208 area code, the Commission and its Staff intend to give notice to the Administrator that it will seek to assume reclamation authority.
NOTICE OF MODIFIED PROCEDURE
YOU ARE HEREBY NOTIFIED that the Commission has preliminarily determined that the public interest may not require a formal hearing in this matter and will proceed under Modified Procedure pursuant to Rules 201 through 204 of the Idaho Public Utilities Commission's Rules of Procedure, IDAPA 31.01.01.201 through .204.
YOU ARE FURTHER NOTIFIED that the Commission may not hold a hearing in this proceeding unless it receives written protests or comments opposing the use of Modified Procedure and stating why Modified Procedure should not be used. IDAPA 31.01.01.203.
YOU ARE FURTHER NOTIFIED that if no written comments are received within the time limit set, the Commission will consider this matter on its merits and enter its Order without a formal hearing. If protests or comments are filed within the deadline, the Commission will consider them and may set the matter for hearing or may decide the matter and issue its Order on the basis of the written positions before it. IDAPA 31.01.01.204.
YOU ARE FURTHER NOTIFIED that the Petition in Case No. GNR-T-00-36 together with accompanying exhibits and workpapers can be reviewed at the Commission’s office during regular business hours.
YOU ARE FURTHER NOTIFIED that the Commission has jurisdiction over this matter pursuant to the authority and power granted under Title 61 of the Idaho Code and the Commission’s Rules of Procedure, IDAPA 31.01.01.000 et seq.
NOTICE OF COMMENT DEADLINE
YOU ARE FURTHER NOTIFIED that the deadline for filing written comments or protests with respect to the Petition and the use of Modified Procedure in Case No. GNR-T-00-36 is Thursday, September 13, 2001. Reference IDAPA 31.01.01.202.02.
YOU ARE FURTHER NOTIFIED that given the preliminary findings made in this Order, the Commission specifically solicits comment from Commission Staff, the telecommunications industry and the public regarding:
1. The merits of a technology-specific overlay.
2. Which of the two proposed geographic split options should be adopted, and if split, which region should retain the “208” area code.

Interested persons or parties who disagree with the Commission’s preliminary findings may object and explain their reasoning.
YOU ARE FURTHER NOTIFIED that the comment must contain a statement of reasons supporting the comment. Persons desiring a hearing must specifically request a hearing in their written comments. These comments should contain the case caption and case number shown on the first page of this document. Written comments concerning this Application shall be mailed to the Commission and the Applicant at the addresses reflected below:

Commission Secretary
Idaho Public Utilities Commission
PO Box 83720
Boise, ID 83720-0074

Street Address for Express Mail:

472 W. Washington St.
Boise, ID 83702-5983 Joe Cocke
Sr. NPA Relief Planner – Western Region
NeuStar, Inc.
North American Numbering Plan Administrator
1445 E. Los Angeles Avenue, Suite 301-N
Simi Valley, CA 93065
Email: [e-mail]

Kimberly Wheeler
Attorney at Law
NeuStar, Inc.
North American Numbering Plan Administrator
1120 Vermont Avenue, N.W., Suite 400
Washington, DC 20005
Email: [e-mail]
Persons desiring to submit comments via e-mail may do so by accessing the Commission’s homepage located at www.puc.state.id.us under the heading of “Contact Us.” Once at the “Contact Us” page, select “Email Case Comments or Questions,” fill in the case number as it appears on the front of this document, and enter comments. These comments should also be sent to the Applicant at the e-mail addresses listed above. IDAPA 31.01.01.012 and .203.
O R D E R
IT IS HEREBY ORDERED that this case be processed by modified procedure as set out in this Order.
IT IS FURTHER ORDERED that comments addressing the matters outlined herein be received by the Commission Secretary no later than Thursday, September 13, 2001.

DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this
day of August 2001.

PAUL KJELLANDER, PRESIDENT

MARSHA H. SMITH, COMMISSIONER

DENNIS S. HANSEN, COMMISSIONER

ATTEST:

Jean D. Jewell
Commission Secretary

O:GNRT0036_ln
Under this plan, a new area code is added or “overlaid” to the entire state currently served by the “208” area code. New customers are assigned to the telephone numbers using the new overlaid area code.
The description of the overlay and geographic split options in this paragraph was adapted from “An Introduction to Numbering” issued by the North American Number Plan Administrator (NANPA) on September 28, 1999.

47 C.F.R. § 52.19(c)(3)(ii).
NPA Relief Planning Guidelines at § 2.11.

NPA Relief Planning Guidelines at § 5(a).

NPA Relief Planning Guidelines at § 5(h).

NPA Relief Planning Guidelines at § 5(f).
NPA Relief Planning Guidelines at § 5.0(a), (h).
NPA Relief Planning Guidelines at § 5(f).

Pennsylvania Numbering Order, 13 FCC Rcd at 19027, para. 26 (September 28, 1998); see also Numbering Resource Optimization First Report and Order, 15 FCC Rcd at 7581, para. 7 (March 31, 2000).

The description of the conservation measures found in the following paragraphs was adapted from “An Introduction to Numbering” issued by NANPA on September 28, 1999.

A prefix is the first three numbers in a seven-digit local phone number and is known within the telecommunications industry as “NXX.”

Numbering Resource Optimization First Report and Order, 15 FCC Rcd at 7581, para. 117 (March 31, 2000).

NOTICE OF MODIFIED PROCEDURE
NOTICE OF COMMENT DEADLINE
ORDER NO. 28819 1

Office of the Secretary
Service Date
August 23, 2001