20010109NANC EMail Letter Attachment.doc

IDAHO’S 208 AREA CODE RELIEF

Background: Idaho’s only area code, 208, is projected to exhaust in the third quarter of 2003. After seeking comment from Idaho’s telecommunications industry and the public, the Idaho Public Utilities Commission (IPUC) determined that area code relief would not be necessary if Idaho could optimize its 5.78 million unused telephone numbers through the timely implementation of thousand-block number pooling. The Federal Communications Commission (FCC) has not ruled upon the IPUC’s request to be moved up the pooling schedule and time is running short. If the FCC does not grant the pooling request, the IPUC has determined that a three-way geographic split is in Idaho’s best interest. NANPA estimated the projected lives of the three regions at 13, 17 and 40 years, respectively. Because the projected lives of the proposed number planning areas (NPAs) did not balance within 10 years per NPA Code Relief Planning Guidelines, NANPA rejected Idaho’s three-way split on December 17, 2001.

Why We Are Here: The IPUC seeks the North American Numbering Council’s support for a FCC waiver of the NPA Code Relief Planning Guidelines.

Why the IPUC Seeks a Waiver for the Three-Way Geographic Split:
The three-way split recognizes the three natural population centers that are formed by Idaho’s commerce and mountainous geography.
The division comports with the Local Access and Transport Area (LATA) boundary that divides northern and southern Idaho. LATAs were to encompass contiguous local exchange areas possessing common social, economic and cultural interests. As northern Idaho’s inclusion in the Spokane LATA recognized, our northern region is predominantly in the Pacific Time Zone and possesses common interests separate from the rest of the state.
The boundaries of the three-way split do not disrupt local calling areas.
Idaho citizens repeatedly requested this three-way split relief plan in written comments and at public hearings. It was frequently described as “logical” and “what makes sense.”
Honoring the wishes of the vast majority of public commentors, the three-way split maintains 7-digit local dialing.
The NANC and FCC have supported waivers of NPA Code Relief Planning Guidelines in states like Missouri and Florida, where NPA exhaust was projected to be 5 or less years. Idaho’s three-way split does not contain risks inherent in those instances.
It makes sense to implement comprehensive area code relief now rather than go through this process again later this decade. Under a two-way split alternative, Idaho is projected to need a third area code in just 8 years. Idaho was the 5th fastest growing state in the nation between 1990 and 2000. Although area codes are a limited resource, the three-way split would consume only the codes that Idaho will need in a few years anyway.
The NPA Relief Planning Guidelines state that the choice of relief plans is a local decision. The FCC has noted that “state commissions are uniquely positioned to determine when, and in what form, to implement area code relief” and that it relies on state commissions to “weigh the very local and granular information inherent in area code relief decision making.” After considerable comment, hearings and deliberation, the IPUC believes that this three-way split is in Idaho’s best interest.