20151102final_order_no_33414.pdf

Office of the Secretary
Service Date
November 2,2015
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF NEUSTAR,INC.FOR APPROVAL OF )CASE NO.GNR-T-15-06
NPA RELIEF PLAN FOR THE 208 AREA )
CODE )ORDER NO.33414
_________________________________________________________________________________________
)
On July 21,2015,Neustar filed an Application seeking approval to implement a
“Relief Plan”for Idaho’s 208 area code,which has been projected to run out of available
telephone numbers in the second quarter of 2018.Neustar is the neutral third-party administrator
of the North American Numbering Plan (“NANP”),and filed its Application on behalf of itself
and the Idaho telecommunications industry (“Industry”))Briefly,Neustar proposes to add a new
area code to the entire geographic area currently served by the 20$area code,with a 16-month
implementation period.The proposed relief plan would require ten-digit dialing for all local
telephone calls.The Federal Communications Commission (FCC)has delegated authority to the
Idaho Commission to review and approve area code relief plans.47 C.F.R.§52.19.
On August 6,2015,the Commission issued a Notice of Application and Notice of
Modified Procedure that set a comment deadline of October 5,2015.See Order No.33355.The
Commission received comments from the Industry representatives,the Idaho Telecom Alliance,
Commission Staff,and approximately 40 individuals.Based upon our review of the Application,
the different area code options,and the comments,we approve Neustar’s proposed Relief Plan.
THE APPLICATION
The NANP divides the United States into numbering plan areas (NPAs)that are
encoded numerically as three-digit prefixes,called area codes.The combination of a three-digit
area code and a seven-digit telephone number serve as routing addresses in the public switched
telephone network.Neustar serves as the NPA Relief Planner for Idaho.Idaho was assigned the
20$area code in 1947.Application,Exh.B.
Neustar reported that the available pool of telephone numbers in the 208 area code is
projected to “exhaust”during the second quarter of 2018.In April 2015,Neustar notified the
Industry that NPA relief needed to be addressed for the 20$area code.Thereafter,Neustar
The “Industry”is composed of current and prospective telecommunications carriers operating in,or considering
operations within,the 208 area code of Idaho.
ORDER NO.33414 1
conducted a conference call with Industry representatives to discuss relief alternatives.
Specifically,two relief options were discussed:(1)overlaying a new area code for all services
(“overlay”);and (2)splitting the state into two or more area codes (“split”).
A.Tite ReliefAlternatives
1.Area Code Overlay.By way of background,an overlay “would superimpose a new
[area code]over the same geographic area covered by the existing 20$NPA (the entire state of
Idaho).All existing customers would retain their [assigned]208 area code and would not have to
change their telephone numbers.”Application at 4.Notably,“however,ten-digit local dialing
would be required by all customers within and between NPAs in the affected rate areas.”Id.at 3.
Neustar calculates that the overlay has a projected life of 66 years.Id.at 4.
2.Area Code Split.Under the alternative split plan,Idaho would be divided,or split,
into two geographic areas and different area codes would be assigned to the areas formed by the
division,with one area retaining the 208 area code,and the other area being assigned a new area
code.Splits are intended to equally balance the assigned telephone numbers into two territories.
All split plans require ten-digit dialing between the different NPAs.However,seven-digit dialing
would be allowed within the each NPA.Id.Neustar stated in its Application that “the proposed
boundary line [for a split]would run along rate center boundaries starting at the Oregon border
between Riggins and New Meadows rate centers and [would continue]east and then turn
southward ending at the Nevada border between the Three Creek and Oakley rate centers.”Id.at
3-4.The split would create two areas:one generally comprised of southwestern Idaho,and the
other area being the remaining parts of the state.According to Neustar,the area north and east of
the boundary line has a projected life of 6$years,and the southwestern portion has a projected life
of 65 years.Id.Neustar has not proposed which geographic area would keep the 208 area code.
After reviewing the options,the Industry representatives (including incumbent local
wireline carriers,competitive local exchange carriers,cellular carriers,and broadband carriers),
Commission Staff,and Neustar Relief Planning experts,concluded uniformly that the Commission
should adopt the all-services overlay with a 16-month implementation schedule.
ORDERNO.33414 2
The recommended transition schedule is as follows:
EVENT TIMEFRAME DATE
Total Implementation Period 16 months -
Start Network Preparation and Customer Education 6 months TBD
Start of Permissive 7-digit and 10-Digit Dialing Period
(Calls within 208 NFA can be dialed using 7 or 10 digits)9 months TBD
and continued Customer Education
Mandatory dialing at the end of the Permissive Dialing -TBD
Period during 4Q20 17
first Code Activation after end of Permissive Dialing 1 month TBD
Period (Effective date for codesfrom new NFA)
See Exh.A at 7.Neustar indicates there is some flexibility concerning specific implementation
dates on the schedule.Neustar states that serious consideration should be given as to what time of
year is best to introduce dialing changes,as well as the length of time to allow for permissive
dialing.In particular,Neustar recommended that the transition schedule should avoid major
holidays and tourism seasons.Neustar recommended that mandatory dialing begin six months
prior to the forecasted exhaust date for the 208 area code,which would be fourth quarter 2017.
THE COMMENTS
A.Staff Comments
Staff recommended the Commission implement Neustar’s proposed plan of an all
services overlay.In reviewing national trends,Staff noted that overlay plans have been the
preferred alternative for nearly a decade,observing that it has been eight years since a geographic
split was last implemented.Staff suggested that time has proven that customers in locations that
implement an overlay plan have been able to adjust to ten-digit dialing much more readily than
states where a geographic split was used.Staff Comments 4-5.Further,Staff points to West
Virginia,where in 2008,the Public Service Commission of West Virginia reversed its decision to
implement a geographic split pointing to the economic burden of a split relief plan,and that
current technology generally “alleviates most of the problems [associated]with ten-digit dialing.”
See Order to Overlay 304 Area Code,Case No.00-0953-T-PC (West Virginia PSC,February 13,
2008)(available at:www.psc.state.wv.us).
Beyond single states,Staff observed that the FCC accepted the recommendation of the
North American Numbering Council2 to endorse overlay relief plans as a “Best Practice”in
2 The North American Numbering Council is a federal Advisory Committee created to advise the FCC on numbering
issues that foster efficient and impartial number administration.
ORDERNO.33414 3
implementing numbering relief.See FCC Order DA 14-842 (June 20,2014)(available at
https://apps.fcc.gov/edocs public/attachmatch/DA-14-842A1.pdf).Overlay relief is deemed a
best practice because nationally the vast majority of NPAs require mandatory ten-digit dialing,and
because most customers no longer “dial”numbers as most are stored in mobile phones or digital
devices,where most calls originate.Id.
Looking to the future,Staff pointed out that new technologies such as all internet
protocol (“IP”)networks and voice over Internet protocol (“VOIP”)telephone services are
increasingly utilizing ten-digit dialing.Staff opined that because of these advances,“there will
come a time where ten-digit dialing will [always]be required.”Staff Comments 5-6.Likewise,
Staff believes that it is beneficial for Idaho to move to ten-digit dialing in anticipation of future
technological advances.Id.
Staff summarized that an overlay eliminates the need for consumer number changes,
treats all consumers equally,is simpler to implement from a technical standpoint,and subsequent
relief is more easily implemented through an additional overlay.Staff also recommended that the
Commission direct the Industry to initiate a comprehensive educational program to educate Idaho
customers of the transition.Accordingly,Staff recommended the Commission approve the all-
service overlay presented in the Neustar’s Application.
B.Industry Comments
The Industry uniformly recommended that the Commission implement Neustar’s
proposed plan of an all-services overlay.The Industry provided comments in two filings.A
coalition of telecommunications carriers3 identifying themselves as the “Joint
Telecommunications Carriers”gave comments endorsing the proposed overlay plan.A second
group of smaller telecommunications carriers4 identified as the “Idaho Telecom Alliance”also
filed comments endorsing the overlay plan.
The telecommunications carriers collectively referred to herein as the “Joint Telecommunications Carriers”are:
AT&T;Teleport Communications America;SBC Long Distance;Cricket Communications;New Cingular Wireless
PCS,LLC dba AT&T Mobility;Frontier Communications Northwest;Citizens Telecommunications Company of
Idaho;Qwest Corporation dba CenturyLink QC;CenturyTel of Idaho dba CenturyLink;and CenturyTel of the Gem
State dba CenturyLink;CenturyLink Communications;Verizon Wireless;MClmetro Access Transmission Services
dba Verizon Access Transmission Services;Time Warner Cable Information Services (Idaho)dba Time Warner
Cable;Sprint Spectrum;T-Mobile West;and XO Communications Services.
Albion Telephone Company;CTC Telecom;Custer Telephone Cooperative;Direct Communications;Farmers
Mutual Telephone Company;Filer Mutual Telephone Company;Fremont Communications;Inland Telephone
Company;MTE Communications;Oregon-Idaho Utilities;and Project Mutual Telephone.
ORDERNO.33414 4
Both sets of the Industry comments noted the drawbacks and advantages of either an
overlay or a split plan.Ultimately,however,the carriers are uniform in their recommendation that
the Commission approve the overlay plan.They argued that the overlay is the more equitable,
least disruptive option,and will best minimize inconvenience and cost to customers.furthermore,
they contend that implementation of an overlay is simpler for the industry due to local number
portability rules.Notably,the Joint Telecommunications Carriers stated that they have “become
very skilled at educating consumers and businesses to dial 10-digits for local calls.”Joint
Telecommunications Carriers Comments at 3.
C.Public Comments
The Commission received 41 written comments from the public.Public comments
were mixed,with a preference for a geographic split:27 were in favor of a geographic split (66%),
and 12 favored an overlay (29%).Two commenters proposed options that are technically not
achievable.
The customers in favor of the geographic split generally expressed consternation with
ten-digit dialing.A number of commenters supporting a geographic split recommended that the
20$area code remain in the Boise/southwest Idaho area due to higher population and business
presence.Customers in favor of the overlay plan cite concerns with the estimated costs resulting
from a geographic split for businesses including:revising or replacing billing invoices,business
cards,advertisement,signage on vehicles,etc.None of the public comments addressed future
trends that could end seven-digit dialing altogether.
DISCUSSION AND FINDINGS
The Commission has been proactive in maximizing the life of the 20$area code.
Beginning in 2001,the Commission took action to stave off exhaustion of the 20$area code in
2003,including rate center consolidation,mandatory thousand-block-number pooling,and
reclamation of unused and uncontaminated numbers from carriers.Order No.28902.These
actions resulted in extending the life of the 20$area code for approximately 15 years.Because of
the Commission’s success in conserving the pool of available numbers for the 208 area code,
when now confronted with exhaustion,the Commission and the Industry are able to examine the
relief alternative with the benefit of copious national data.Our goal is to determine which
alternative and transition schedule best serves the public interest of Idaho and its citizens.
ORDER NO.33414 5
The Commission is sensitive to the public comments expressing favor for a geographic
split.Neither option is ideal.The overlay will create the need for statewide ten-digit dialing that
will cause some difficulties as the public transitions to this new requirement.On the other hand,a
geographic split will require about half of all telephone numbers in Idaho to change.
What is more,under a geographic split,businesses of all sizes that must change their
telephone area code will experience significant disruptions.Any goodwill of business
identification associated with existing phone numbers will be lost.Advertising,letterhead,
webpages,and business cards will all require changes.Furthermore,until the old contact
information has been replaced and people have internalized the area code change,the public in
half the state will be faced with a challenge every time they wish to call a business —a challenge
that will likely ripple far beyond any transition period.This is no small expense nor a minor
nuisance.
Furthermore,this Commission believes that developing technology and services that
utilize telephone numbers will eventually drive seven-digit dialing into obsolescence in the future.
Consequently,implementation of a geographic split may only serve to prolong seven-digit dialing
for a short period of time.Thus,any future dialing change and relief planning will be eased by the
implementation of ten-digit dialing now rather than later.Additionally,it must be noted that the
vast majority of phone number dialing is now done automatically by cellular phones,digital
devices,and computers,alleviating the need to remember numbers.The Commission sees these
trends continuing.
Conversely,an all-services overlay will cause everyone in the state to (equally)incur
the annoyance of ten-digit dialing.Beyond this inconvenience,an overlay will not cause a
disruption to current phone numbers.The inconvenience caused by ten-digit dialing will be
mitigated by education efforts,a permissive dialing period,and the use of automatic dialing
through cellular and other digital devices.
After a thorough review of the record in this case,the Commission finds it just and
reasonable,and in the public interest to approve implementation of an overlay relief plan for the
208 area code.The Commission finds Neustar’s proposed 16-month implementation schedule
(including a six-month permissive seven-and ten-digit dialing period)satisfactory when coupled
with the consumer education requirements.
ORDER NO.33414 6
ORDER
IT IS HEREBY ORDERED that Neustar’s proposal to implement an all-services
overlay and introduce a second area code covering the entire state of Idaho,is approved.
IT IS FURTHER ORDERED that the proposed 16-month schedule to implement use
of a second area code,including a six-month permissive seven-and ten-digit dialing period,is
approved.
IT IS FURTHER ORDERED that the implementation process shall begin within 30
days of the date of this Order.
IT IS FURTHER ORDERED that Commission Staff shall participate with the Industry
and Neustar in the generation of media releases,customer education,community involvement,and
public workshops to ensure the rapid and equitable implementation of the plan with adequate
customer education.
THIS IS A FINAL ORDER.Any person interested in the Order may petition for
reconsideration within twenty-one (21)days of the service date of this Order with regard to any
matter decided in this Order.Within seven (7)days after any person has petitioned for
reconsideration,any other person may cross-petition for reconsideration.See Idaho Code §*61-
626,62-6 19.
ORDER NO.33414 7
DONE by Order of the Idaho Public Utilities Commission at Boise,Idaho this
day of November 2015.
PAUL KJELLA4,T R,P SID]NT
MARSHA H.SMITH,COMMISSIONER
KRITINE RAPER,COI(1MISSIONER
ATTEST:
mmission Secretary
O:GNR-T-I 5-06bk3
ORDERNO.33414 $