20150922Joint Telecommunications Comments.pdf

CENTURYLINK
I 600 7th Av.nuc, Room 1 506
Ssattle, Wmhington 98191
(206) 73&5178
Maura E. Reynolds
Paralegal
Rogulatory Law
September 21,2015
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VA OWRAAGHT DELIWRY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
4T2WestWashington
Boise, D 83702-5983
RE: Docket No. GI\R-T-15-06
Joint Telecommunications Carriers' Commglts
Dear Ms. Jewell:
Enclosed for filing with this Commission are an original and seven (7) copies of the Joint
Telecommunications Carriers' Comments in the above-referenced docket.
If you have any questions, please feel free to contact me. Thank you.
/mer
Enclosures
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
COMMENTS OF THE JOINT TELECOMMUNICATIONS CARRIERS
The Joint Telecommunications Carriers,l representing a coalition of
telecommunications carriers, submit the following comments in support of the
application filed by Neustar, Inc. ("Neustar"), the North American Numbering Plan
Administrator ("NANPA") with the Idaho Public Utilities Commission ("Commission")
seeking approval of the industry consensus recommendation for an all-services
distributed overlay as the preferred form of relief for the impending exhaust of the 208
area code, and the industry recommended implementation schedule.
' The telecommunications carriers collectively referred to herein as the "Joint Telecommunications
Carriers" are: AT&T Corp., Teleport Communications America, LLC, SBC Long Distance,LLC, Cricket
Communications, LLC, New Cingular Wireless PCS, LLC dlbla AT&T Mobility, Frontier
Communications Northwest Inc., Citizens Telecommunications Company of Idaho, Qwest Corporation
d/b/a CenturyLink QC, CenturyTel of Idaho, lnc. dlbla Centurylink, and CenturyTel ofthe Gem State, Inc.
d/b/a CenturyLink, CenturyLink Communications, LLC, Verizon Wireless, MCImetro Access
Transmission Services LLC dlbla Verizon Access Transmission Services, Time Warner Cable Information
Services (Idaho), LLC dlbla Time Warner Cable, Sprint Spectrum L.P., T-Mobile West LLC, XO
Communications Services, LLC.
IN THE MATTER OF THE
APPLICATION OF NEUSTAR, INC.,
ON BEHALF OF THE IDAHO
TELECOMMUNICATIONS
INDUSTRY, FOR APPROVAL OF
NUMBERING PLAN AREA RELIEF
FOR THE 208 AREA CODE
Case No. GNR-T-15-06
Joint Telecommunications Carriers
Comments
[Corrected Page I -9122/2015]-l -
I. Overview
On July 2l,20l5,the NANPA filed an application2 with the Commission seeking
approval of the industry's consensus recommendation for an all-services distributed
overlay plan as the preferred form of area code relief for the 208 area code. On August 6,
2}l5,the Commission issued a Notice of Application, Notice of Modified Procedure,3
providing the opportunity for interested parties to file comments within 60 days of the
August 6,2015 Commission order date.
II. The All-Services Overlay Plan is The Best and Most Equitable Approach
The Joint Telecommunications Carriers strongly support NANPA's overlay
recommendation as stated in the NANPA's Jlly 21,2015 application. An overlay will
significantly minimize inconvenience to consumers and support the continuing trend
throughout the United States to use the overlay method as the preferred form of area code
relief.
An overlay is the most equitable and least disruptive method of relief because it
does not require any telephone number changes, which is particularly important to
business concerns. An overlay has significantly fewer technical implernentation issues
than a split, and can be effectively and efficiently implemented. The Joint
Telecommunications Carriers' collective experience attests to the fact that when an
' July 21,2015, NANPA application, http://www.puc.idaho.gov/fileroom/cases/summary/GNRTl506.html
3 August 6,2015 Commission Order No. 33355,
htp://www.puc.idaho.gov/fileroom/cases/summary/GNRT I 506.htnl
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overlay is implemented, most consumers view the required 1O-digit dialinga for all local
calls5 as a minor inconvenience to which they easily adapt. The overlay has been the
preferred and selected method for area code relief over the last 10 years, with 38 of the
last 39 area code relief decisions and/or implementations in the United States being
overlays.6 (See Exhibit A.) The industry has become very skilled at educating
consumers and businesses to dial 10-digits for local calls, and customers have ultimately
been satisfied with the overlay method.T ln2Ol3,the North American Numbering
Council's ("NANC") Local Number Portability Administration ("LNPA") working group
issued its recommended "best practices," which supports an overlay as the best solution
for area code relief. (See Exhibit B.)
III. There Are No Losers With An Overlay
The Commission has two primary choices for area code relief, an overlay or an
area code split. The detriment to the public interest, consumers and businesses are well
known with an area code split, and the Idaho 208 area code is no exception. Unlike an
overlay, an area code split would not treat consumers who have the 208 telephone
number today in an equitable manner. A split would force the Commission to make a
difficult decision: to determine the geography pursuant to which all customers in that area
a +z crR $52.r9 (c)(3)(ii).
s An Overlay does not change the existing local calling areas.
o On a national level since 2005, there have been 32 overlays and only I split implemented (the split
occurred in New Mexico in 2007), another 6 overlays are scheduled to be implemented by the end of the
first quarter of2017.
7 The industry helps to educate its customers and consumers about an area code overlay, which includes a
permissive dialing period where callers can get used to dialing 10 digits for local calls prior to the
implementation of the overlay. During the perrrissive dialing period, callers may complete calls with either
7- or l0-digits. When mandatory l0-digit dialing is implemented, callers attempting a7-digit local call will
receive a recording advising them to hang up and dial l0 digits.
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would be forced to change their telephone numbers to reflect the new area code.8 The
consumers and businesses on the losing side of the split would have to change their
numbers and they would be faced with numerous adverse impacts related to the number
change. For example, those consumers on the losing side would be required to notifu
family, friends, business associates, doctors, dentists, schools and others who call or text
them that the area code portion of their telephone number has changed. Business owners
and operators would be required to update their company stationery, business cards,
texting information, internet-related sites, social media, and advertisements - in addition
to contacting existing customers to inform thern of a new area code for their business
phone number. This can have a significant negative economic impact on businesses
which will not happen with an overlay. These concerns were key factors that persuaded
the West Virginia Commission to reverse its order from a split to an overlay in 2008.e
At the time West Virginia determined to reverse course from a split to an overlay, it was
a single area code state like Idaho.
Additionally, there are numerous non-telephony databases that use full l0-digit
telephone numbers as the search criterion, such as databases for airlines, doctors, utilities,
8 Initially some consumers support a split because they assume the other side of the split will be required to
do the number changes. However, if they understand that they may be required to change their number and
accept the burden of notifying everyone they know of their new number, many then support an overlay
because they do not want the unnecessary aggravation of a number change. Additionally those who
support a split, often do so because they want to retain the ability to dial 7- digits for local calls. However,
with the proposed split option in Idaho, some areas will need to dial 7-digits for some local calls and l0-
digits for other local calls, because the local calling area in which they reside would be split between the
two area codes
e West Vtsinia PSC (Case No. 00-0953-T-PC). Februarv 13. 2008. Order Granring Pelllron -for
Reconsideration and Ordering an Overla!for the 304 Area Code ('the Commission was persuaded by two
key themes that were repeated in the requests to reconsider the Order: (i) the geographic split would have
imposed a disproportionate economic burden on that portion of the state being required to switch to the new
area code and (ii) those individuals and businesses familiar with the ten-digit dialing requirements imposed
by other overlay plans in adjoining or other states indicated that the current technology and programming
of phones and cellular phones alleviated most of the problems that formerly existed with ten-digit dialing
and that ten-digit dialing becomes second nature within a short period of time."
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gocery reward programs and frequent shopper programs, pharmacies, national missing
children databases, and many others. Each of these would need to be updated with the
new area code for the telephone number should they be in the area designated to be
assigned the new area code if a split were chosen. Since consumers and businesses have
become increasingly attached to and are identified by their telephone numbers, a split
with the required area code number change would be significantly more burdensome than
it might have been 10 years ago.
If the Commission were to select a split, about one-half of the consumers and
businesses'o irr ldaho would have to suffer the cost and inconvenience of changing the
area code of their telephone numbers.
IV.Consumers Easily Adapt To An Overlay
In earlier years, some state commissions may have expressed concerns about the
inconvenience of consumers having to dial l0-digits for local calls within the same area
code. However, state commissions and consumers alike have since realized that the
possibility of an area code change and the resulting burdens and costs associated with that
change far outweigh the inconvenience of l0-digit dialing. For example, in 2008, the
California Public Utilities Commission, which had originally selected a split for the 760
area code, changed its decision and ordered an overlay because a vast majority of
customers did not want to change the area code of their telephone number.ll
'0 The Idaho PUC has received comments from some individuals recommending a split. Many of these
comments recommend a split that would not be balanced, such as a split with the time zone boundary as the
split boundary. An imbalanced split is inconsistent with the industry guidelines requirements for area code
relief and will not be permissible (See section 5.0 of the ATIS NPA Relief Planning and Notification
Guidelines at https://www.atis.org/docstore/product.aspx?id:278 88).rr Decision Granting Petition for Modification of Decision 08-04-058 and Ordering an Overlay for the 760
AreaCode,Application of the North American Numbering Plan Administrator, on behalf of the California
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Recent experience shows that consumers easily adapt to making oolocal" calls by
dialing l0 digits as part of their routine calling patterns. The growing use of wireless
devices, and in particular smart phones, as a consumer's primary phone means that
"dialing" for many consumers consists of highlighting a contact and choosing the called
party's number rather than dialing 10 digits. Thus, the concern that dialing l0 digits will
be a burden for consumers when an overlay is implemented will have even less validity
going forward.l2
V. An Overlay Can Be More Easily Implemented and Avoids the Technical
Problems Associated With a Split
An additional benefit of an overlay is that implementation avoids technical
problems carriers could experience in complying with customers' local number
portability ("LM"'; requests. These technical problems proved to be a significant issue
with the split in New Mexico that was completed in 2007.
Specifically, there are significant technical LNP challenges during the permissive
dialing period of an area code split.l3 Urder federal rules, the Number Portability
Administration Center ("NPAC") houses all of the ported and pooled number data.
During the night on which permissive dialing is implernented, NPAC personnel must
Telecommunications Industryfor Relief of the 760 Numbering Plan Area, Application 07-06-018,
California PUC (Oct. 21,2008), slip op. p.4 ("The extensive public response to our decisionfocused on the
inconvenience and expense of changing telephone numbers, as compared to the relatively minor burden of
L0-digit dialing. Customers explained in great detail the expenses that will be incurred by businesses, the
lost contacts for individuals, and the use of "speed dial" features on modern telephones that can offset the
impact of l0-digil dialing. ffl] We have considered the volume and substance of these comments and have
detennined that we should grant the petitionfor modification and adopt a geographic overlay. This will
allow customers to retain their existing telephone numbers, which we understand to be the highest priority
for customers.").''2 Moreouer, t0 digit dialing is a necessary precursor to a transition to all Intemet Protocol (IP) networks.
'3 During the permissive dialing period, in an area code split, a customer can be contacted through either
the old or the new area code used with their telephone number.
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update the NPAC database to include both the old and new area code. On the same night,
all carriers operating in the area code must update their operational support systems
("OSS") with the new and the old area code so that port requests will complete within the
designated porting intervals. Port requests can fail or create a backlog ifthe carriers'
OSS is not in sync with the NPAC's database. [f such coordination fails, calls can also
be misrouted or denied, leading to consumer dissatisfaction and undermining the
competitive and consumer benefits of LNP.la
Also, when implernenting a split, all carriers, nationwide, on the night that
permissive dialing is implemented, must activate the new area code in order for calls to
complete to both the existing 208 area code and the new area code.
In addition, ffiffiy carriers have implernented newer network routing technologies
such as Voice over Internet Protocol ("VoIP"). These technologies would require
significant operational developments and coordination to accommodate an NPA split.
Many VoIP call routing platforms routinely operate on a lO-digit basis already, and the
industry is moving toward these new technologies in increasing numbers as traditional
telephone networksls are retired and replaced. Finally, there are a number of other
technical implementation problerns that can arise for wireless customers when an area
code split is implemented. These include, but are not limited to:
o Caller ID Customer Confusion - During the permissive dialing period, the
called party's Caller ID device or handset may indicate that a received call
ra See Exhibit A - From 2005 to the present day, 38 ofthe last 39 areacode reliefdecisions and/or
implementations in the United States have been overlays. Since the New Mexico split in 2007, carriers
have not had to do the diflicult OSS coordination with the NPAC database related to a split. New carriers
since 2007 have never been through a split and do not have the experience of coordinating their OSS with
the NPAC database for a split. This could be a very significant issue with a split.
15 Time Division Multiplexing ("TDM") Network Technology.
-7 -
originates from a number with the new area code even though the caller is still
using a number in the old area code. Although this issue does not technically
affect the ability of the call to complete, it can lead to confusion on the called
party's part. The called party may choose not to answer the call because the
indicated originating number or the new area code is not recognized, or the stored
contact list in the called party's device or handset has not been updated. There is
no such problem with an overlay because no customers are forced to change their
numbers.
Text and Multi-Media Messaging Completion - Some wireless systems
currently are able to handle only one lO-digit telephone number for text and
multi-media (e.g.picture) messaging. Therefore, if during the permissive dialing
period the calling party inputs a different l0-digit number (i.e. using the new area
code) than the one which is in the called party's wireless provider's system (i.e.
the old area code number), the message will fail and not be delivered.
Smart Phone Applications Impacts With the growing proliferation of smart
phones, wireless customers have the ability to add various tlpes of third-party
applications to their phones. These applications, which can run into the hundreds
or even thousands depending upon the smart phone's storage capacity, often
perform various user authentications via a text message sent to the customer's
existing lO-digit number. As a result, changing a customer's area code in a split
would likely impact the customer's ability to receive such text messages, and the
operation of many of these advanced data applications. At the very least, a split
will require a customer to update his/trer number in his/her user profile in each
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application that uses the customer's number as an identifier or authentication
criterion.l6
\ilireless Phone Reprogramming Issues - When implernenting a split, most
wireless providers will change the area code of affected customers' phones over-
the-air, if the handset is over-the-air capable, to avoid manually reprogramming
each handset.lT But when customers with handsets that are not over-the-air
capable do not bring their handsets in to the provider for manual programming, or
are military personnel or other customers living abroad whose phones are outside
the range of over-the-air reprogramming, these customers' new area code will not
be re-programmed before mandatory dialing begins. As a result, they will not be
able to receive calls because their handsets will still have the old area code as part
of their lO-digit telephone number and calls made to the new area code will not
get to them.
o Administrative Number Impacts - Most wireless carriers have various
administrative numbers in their networks, and those numbers can be affected by a
split as well. For example, Temporary Local Directory Numbers ("TLDNs") in a
network are used to facilitate the delivery of calls to customers who are roaming
on that network. If TLDNs are in central office codes where the area codes has
changed, then wireless cariers have to take great care in changing those numbers
during the permissive dialing period of the split to avoid negatively impacting call
16 Customers may not immediately know which applications use their phone numbers so some updates
could be inadvertentlv missed.
17 Over-the-air capabie handsets can be remotely reprograurmed by the wireless provider with the new
telephone number and the activity does not require interaction with the customer, if the customer is being
served by the wireless provider's network at the time the over-the-air reprogramming is initiated. If a
customer is roaming on another network, the reprogramming may fail.
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completion for roaming customers. Carriers have to do extensive testing before
the start of permissive dialing and again before mandatory dialing in a split to
ensure that changing the area code of any administrative number in the network
will not negatively impact a customer's ability to receive calls. There are no such
concerns with an overlay because none of the existing administrative numbers
would need to change. Additionally the SMS 800 Database, which houses all of
the underlying l0-digit geographic routing numbers for toll free numbers, would
need to be changed for all numbers affected by - area code split.
vr.Conclusion
For the forgoing reasons and consistent with the NANPA's July 21,2015
application, the Joint Telecommunications Carriers respectfully request that the
Commission adopt an all-services overlay and the recommended implementation
schedule. By doing so, the Commission will implernent area code relief in a manner that
limits customer inconvenience and other negative impacts on existing consumers and
businesses.
Submitted this 18ft day of September, 2015.
Respectfu lly submitted,
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Z./ a
Lisa A. Anderl
Associate General Counsel
1600 7th Avenue, Room 1506
Seattle, WA 98191
Tel: [phone]
Fax: [phone]
Li sa.Anderl @C ertwyLink. com
Attorney for the C enturyLink C ompanies
Jesris G. Romiin
Assistant General Counsel
2535 West Hillcrest Dr.
Tel: [phone]
Fax: [phone]
Jesus. g. rom an@v eizon. com
Attomeyfor Verizon Wireless and Yerizon
Acces s Transrnis sion Services
David J. Miller
General Attorney
2150 Webster Street, 8tr Floor
Oakland, CA94612
Tel: [phone]
Fax: [phone]
[e-mail]
Attorney .fo r AT&T Companies
- l1-
Lisa A. Anderl
Associate General Counsel
1600 7th Avenue, Room 1506
Seattle, WA 98191
Tel: [phone]
Fax: [phone]
[e-mail]
Attorney for the CenturyLink Companie s
}"a &,q*
Jesfs G. Rom6n
Assistant General Counsel
2535 West Hillcrest Dr.
Tel: [phone]
Fax: [phone]
Jesus. [e-mail]
Attorneyfor Yerizon Wireless and MClmetro
Access Transmission Services dba Verizon Access
David J. Miller
General Attorney
2150 Webster Sireet, 8e Floor
Oakland, CA94612
Tel: [phone]
Fax: [phone]
dav idi mil le r (d att.com
Attorney for AT&T Compcnies
- ll -
Lisa A. Anderl
Associate General Counsel
1600 7th Avenue, Room 1506
Seattle. WA 98191
Tel: [phone]
Fax: (206) 3$-4A40
Lisa.Anderl @ CenturyLink.com
At n rney .fb r t he C e ntury Link C ornp cui e s
Jesds C. Romdn
Assistant General Counsel
2535 West Hillcrest Dr.
Tel: [phone]
Fax: [phone]
Jesus.g.roman @ verizon.com
Atrurneyfttr Verizort Wireless cutd Veriion
Acce s s Trcutsmiss ion S e rv ice s
2150 Webster Street, 8th F'loor
Oaklarcl, CA 94612'Iel: [phone]
Fax: (?81) 664-c)178
[e-mail]
A tt a r ne:v .fit r A7' &'l- C r n npun,i.cs
tl-
David J. Mil
Geueral Attorney
Renee M. Willer
State Regulatory Manager
20575 NWVonNeumannDrive Suite 150
Beaverton, OR 97006
Tel: [phone]
Far: [phone]
[e-mail]
Kristin Jacobson
Cot'rsel, Regulatory Affairs West Region
201 Mission Street, Suite 1500
SanFrancisco, CA 94105
Tel: [phone]
Fax:[phone]
Kristin.L. Jacobson@sprint. com
Attorneyfor Sprint Spectrum L.P.
Vincent M. Paladini
Assistant Chief Counsel, Regulatory
Time Warner Cable
13820 Sunrise Valley Drive
Hemdon, YA 20171
Vincent. Paladini@twoable. com
Attorneyfor Time Warner Cable Information Services (daho), LLC dba Time Warner
Cable
- 12-
Krislin Jacobson 7077476ffi
Renee M. \Uiller
SureRegularory Manager
2A575 NW Von Neurnann Drive Suitc 150
B€avcrtonr OR 97006
Tel: (503) A45:7909
Falc (503) 62%0592
[e-mail]
Counsel, Regulatoqy Affairs West Regi,on
201 lvlissionStreet, Suirc 1500
SanFrancisco, CA 94105
Tel: 707-816:1583
Fax:415{84-?339
Kri stin. LJacobson@sprinl@m
Attomq: tar Spri nt Spechum L.P.
Vincent M. Paladini
Assisunt Chief Counsel, Regularory
Time Wamer Cable
13820 Sunrise Valley Drive
HemdonoVA 20171
Vinccnt Palsdin i@.trvcab lc.com
.lnorrsyfor Time Warner Cable In/ornntion Senices (Idaltu), LLC dbaTime Warnq
Cable
p.l
-t) -
Ogl18/2A15 2:$7PM (Gt{T-05:00)
Renee M. Willer
State Regulatory Manager
2O575NW Von Neumaoq fhivc Suite I 50
Beaverton, OR97006
reL (5Q3) 64s-7W
For: [phone]
renee.willerfBffr.com
Kdstin JacobsonCo l, fug,l"tpfyAtrairs lVestRegion
201 Mission SE-te[,. Suite, 1500
San Fmncisco, CA 94105
Tet 913-315-9108
Fax:[phone]
I(ristin L. [e-mail]
Vincent M. Paladini
d;il;i'6h#6r"Pr,Reguratoryri*i wa*o C.utt
Hemdon, VA 20171
[e-mail]
Attoqrqcyfor Time Wqner Cabte hdormation Serrices (Idato), LLC dbaTime Warner
Cable
.,12'
Teri Y. Ohta
Principal Corporarc Counsel, State Regulatory Affairs
12920 SE 38th Steet
Bellewe, WA 98006
Tel [phone]
Fax [phone] (fax)
Teri. ohta@t-mobile. com
Attorneyfor T-Mobile West LLC
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Teri Y. Ohta
Principal Corporate Counsel, State Regulatory Affairs
12920 SE 38th Street
Bellevue, WA 98006
Tel: [phone]
Fax: [phone] (fo()
[e-mail]
Attorneyfor T-Mobile llrest LLC
XO Communications Services, LLC
13855 Sunrise Valley Drive
Herndon, VA 20171
Tel: [phone]
For: 703.547.3665
kellv.faul(0xo.com
Dircctoi, Regulatory Affairs
- l3-
Exhibit A - Joint Telecommunication Carriers Comments
Case No. GNR-T-15-03
September 18,2015
Method of Area Code Relief in the United States Since 2005
Exhibit based upon information located at the NANPA website:
http://www.nationa I na n pa.com/enas/noaSince 1995Report.do
ln Service Dt .ocation New NPA )verlay?f,Id NPA NIPA Complex
3/LL12077 NY 680 Yes 315 31sl680
10117t2016 IN 463 Yes 317 317t463
711612016 NY 934 Yes 631 631/934
512312016 NC 743 Yes 336 3361743
212712016 OH 380 Yes 614 380/614
1011912015 SC 854 Yes 843 8431854
412212015 OH 220 Yes 740 2201740
312812015 TN 629 Yes 615 615/629
312112015 CA 628 Yes 415 4151628
31712015 IN 930 Yes 812 8121930
813012014 CT 959 Yes 860 860/9s9
71112014 TX 346 Yes 832 281134617131832
61312014 NV 725 Yes 702 7021725
313120't4 KY 364 Yes 270 2701364
't0t21t2013 PA 272 Yes 570 2721570
71112013 TX 737 Yes 512 5121737
1112012012 CA 669 Yes 408 408/669
413012012 NC 984 Yes 919 919/984
3t24t2012 MD 667 Yes 443 410t4431667
4116120',t1 NY 929 Yes 347 347171819171929
41112011 OK 539 Yes 918 539/918
3126t2011 NE 531 Yes 402 4021531
8114t2010 WI 534 Yes 715 5341715
711012010 AL 938 Yes 256 256/938
212612010 GA 470 Yes 678 404t47016781770
211012010 OR 458 Yes 541 4581541
1211212009 CT 475 Yes 203 2031475
1112112009 CA 442 Yes 760 4421760
1',U712009 IL 872 Yes 312 31217731872
5/18/2009 CA 747 Yes 818 7471818
3t29t2009 UT 38s Yes 801 385/801
312812009 WV 681 Yes 304 304/681
912312008 CA 657 Yes 714 6571714
10t7t2007 IL 331 Yes 630 331/630
101712007 NM 575 No 505
311712007 IL 779 Yes 815 7791815
812612006 CA 424 Yes 310 3101424
511612006 GA 762 Yes 706 7061762
311412005 MS 769 Yes 601 601/769
Exhibit B
Joint Telecommunications Carriers Comments
Case No. GNR -T-15-03
September 18,2015
NANC LNPA Best Practices - Sept 18,2013 NANC Meeting
Website Link: http ://www. nanc-chair'. org/docs/documents I 6-20 I 3.html
The All Services Overlay is the Best Solution for the Area Code
The LNPA WG supports the all-services overlay for Area Code Relief. This approach
minimizes inconvenience to consumers and supports the continuing trend in the United States to
utilize overlays as the preferred form ofarea code relief.
AREA CODE OVERLAY
The application of Area Code Relief methods has continued to evolve since the late 1990's.
Overwhelmingly, the preferred method of relief chosen is now the All- Services Area Code
(NPA) Overlay. [n fact, only one Area Code Split has been implernented in the last 5 years,
compared to over 25 Overlays. NPA Overlays have both practical and technical positive
implications for customers and service providers alike.
Benefits of All-Services Overlav
1. All current customers retain their existingarea code and telephone number; no
winners or losers.
2. No discrimination against customers on different sides of a boundary line, as does a
geographic split when determining which side gets the new area code.
3. Less customer confusion and easier education process.
4. Minimized financial impact on business customers since there is no need to change
signage, advertising, websites, checks and stationery (unless they currently show 7-
digit numbers rather than l0-digit numbers).
5. Residential customers are not forced to update personal printed material such as
checks or make changes to websites storing telephone numbers (e.g., banking,
insurance, credit cards), unless they currently show only 7-digit numbers.
6. Does not split cities or counties into different area codes, keeping communities of
interest intact.
7. No impact on some wireless customers that would otherwise require their handsets to
be manually reprogrammed.
8. No technical impacts to text messaging, multi-media messaging or smart phone
applications.
9. Provides the most efficient distribution of numbering resources by allowing
assignments to follow demand, not withstanding forecasts for growth.
10. Minimizes call routing issues, especially with ported numbers.
Exhibit B
Joint Telecommunications Carriers Comments
Case No. GNR -T-15-03
September 18,2015
11. No need for synchronization of old and new area codes in NPAC databases.
12. No technical impacts to number portability or toll-free number routing.
13. Missing and exploited children continue to be able to contact parents since their
parents' area code and telephone number would remain the same.
14. Deployed Military personnel continue to have service since their area code and
telephone number would not change.
15. No Caller ID confusion.
The All-Services Overlay is the Best Solution for the Area Code
Summarv
In addition to the benefits above, an overlay is the superior option for area code relief for the
following reasons:
o Most Equitable Approach - Treats all consumers the same
o Least disruptive for the consumer
o Easily implernentable, as demonstrated by the large number of successful U.S.
implementations since 2007
o Most consumers already comfortable with lO-digit dialing
o Avoids l,ocal Number Portability (LNP) database problerns associated with a split (e.g.,
updates to operational support systems with old and new area codes so port requests
complete within the designated porting intervals)
o Facilitates future area code relief efforts