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Home My WebLink About20151005Idaho Telecom Alliance, Inc. Comments.pdfGtvENS PunsLEY,," Attorneys and Counselors at Law 601 w. Bonnock Sireel PO Box27n Boise, lD 83701 Telephone: 208-388-l 200 Focsimile: 208-38&l 300 M.givenspuEley.com October 5,2015 Via Hand Deliverv Jean Jewell, Secretary Idaho Public Utilities Commission 472W. Washington Boise,Idaho 83702 RE: CASE NO. GNR-T-15-06 IDAIIO TELECOM ALLIAI\CE, INC. COMMENTS Dear Ms. Jewell: Please find enclosed for filing with the Idaho Public Utilities Commission one original and seven unbound copies of the Idaho Telecom Alliance, Inc.'s Comments in the above- referenced case. Please feel free to contact me with any questions. Sincerely, r{furt,u,- Kenneth R. McClure KRI!,I/SLW Enclosures Deboroh E. Nelson w. Hugh O'Riordon, LL.M. Michoel O. Roe P. Mork Thompson Jeffrey A. Wor Roberl B. While Angelo M. Reed, of counsel Retired: Kenneth L. Pu6ley Jomes A. Mcclure l19u-n111 Roymond D. Givens 119r7-2@8) Gory G. Allen Peter G. Borlon Christopher J. Beeson Clinl R. Bolinder Erik.J. Bolinder ..letf W. Bower Preston N. Corter Jeremy C- Chou williom C. Cole Michoel C. Creomer Amber N. Dino Thomos E. Dvorok Jeffrey C. Feredoy Morlin C. Hendrickson Brion J. Holleron Don E. Knickrehm Neol A. Koskello Deboro K. Kristensen Michoel P. Lowrence Fronklin G. Lee Dovid R. Lombordi Kimberly D. Moloney Kenneth R. Mcclure Kelly Greene Mcconnell Alex P. McLoughlin Melodie A. McQuode Chrislopher H. Meyer L. Edword Miller Po'trick J. Miller Judson 8. Monlgomery f\ta=, C,,rI Offi tTlr(Bctt m - l:rf--1r\r (,lra, G I :_&#k re,( r^"" @;:.: 5.rrgt-'::: 6{tfr6z" BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF NEUSTA& INC., ON BEIIALF OF THE IDAIIO TELECOMMUNICATIONS INDUSTRY, FOR APPROVAL OF NUMBERING PLAI\ AREA RELIEF FOR THE 208 AREA CODE CASE No. GNR-T-15-06 g ts =GIDAHo TELECOM ALLIffE, BC.;ETCOMMENTS ffi -{ rttvzV1. r t")C,; (' f II@.: -2 =F* ir6t, a*scolturNts on tnp Ioano trclncovt.u,t tAxcr. tNC. z I. INTRODUCTION The Idaho Telecom Alliance, Inc. ("ITA") is an ldaho not-for-profit corporation representing fifteen rural Incumbent Local Exchange Carriersl providing broadband and basic local exchange services in services territories throughout southern Idaho. [TA mernber companies provide service in some of the most rural geographic areas in the continental United States. All ITA members are Eligible Telecommunications Companies and Carriers of Last Resort within their certificated service territories. [n addition, some ITA mernbers provide Competitive Local Exchange Carrier services in ldaho and other states. ITA mernber companies all are Rural Companies as that term is defined in the Telecommunications Act of 1996, 47 U.S. Code $ 153(44), but also are the least densely populated and the smallest companies providing telecommunications and broadband services in this State. The largest ITA member company has 6,100 lines. The smallest member company has 81 lines. Five ITA member companies are mernber-owned cooperatives.2 This is by way of saylng we have the unique opportunity to know our customers well. They are our neighbors, our t Albion Telephone Company lnc., CTC Telecom, Custer Telephone Cooperative, Direct Communications, Farmers Mutual Telephone Company, Filer Mutual Telephone Company, Fremont Communications, lnland Telephone Company, MTE Communications, Oregon-ldaho Utilities, Project Mutual Telephone Cooperative Association, lnc., Rural Telephone Company, and Silver Star Communications. 2 Fremont Communications, Custer Telephone Cooperative, Farmers Mutual Telephone Company, Filer Mutual Telephone Company, and Project Mutual Telephone. COMMENTS OF THE IDAHO TELECOM ALLIANCE, NC.Page I families and members of our communities. We believe we can speak not only on behalf of ITA member companies but on behalf of our customers and communities as well. Representatives of ITA member companies were involved in the [ndustry meetings convened by Neustar3 and concur in the consensus recommendations made by Neustar in this Application. ITA recommends and endorses the adoption of Alternative 1, the "all services distributed overlay'' as superior to Alternative2, the "geographic split." II. DISCUSSION Neither Alternative I nor Altemative 2 is ideal. Both involve inconvenience and disruption to customers. We acknowledge the need for one or the other, and believe both are superior altematives to other possible choices not recommended by Neustar. While Alternative l, the Overlay will cause the need for ten digit dialing, wo believe that the disruption caused by Alternative 2, requiring every telephone number in approximately one half of the state to be changed, is a greater disruption to telecommunications and broadband customers in Idaho. Alternative l, the Overlay, will cause everyone in the state (equally) to incur the minor inconvenience and annoyance of ten digit dialing. We do not expect anyone to be thrilled with that prospect. To a great extent that inconvenience will be mitigated by the use of "speed dial" and "smart phone" dialing. Pareto's Principal suggests that 80% of phone calls are made to 20Yo of the numbers in a person's phone directory.a The most frequently called numbers are most likely to be contained in a speed dial or smart phone directory of those customers who use one or the other. For these calls, no additional inconvenience will be encountered by the average user once the new area code information has been input into the speed dial or the smart phone directory. Moreover, the proliferation of numbers which has caused the 208 area code to be exhausted has been driven in no small part by the need for numbers for broadband connectivity and wireless devices. All of the computers and all of the cell phone handsets now in service 3 Exhibit A to Application for Modified Procedure of Neustar, Inc. filed by Neustar, Inc. with the Idaho Public Utilities Commission , July 21, 2015. n http://www.bsu.edu/libraries/ahafner/awh-th-math-pareto.html COMMENTS OF THE IDAHO TELECOM ALLIANCE,INC.Page2 contain capacity for dialing that originates from directories. Adapting to ten digit dialing for those calls as well will be a one-time inconvenience. People who still punch numbers and those who need to connect to numbers not programmed into speed dials or contained in a smart phone directory will have added inconvenience with ten digit dialing. There is no escaping that. They not only will have to rernember but also will have to dial the appropriate area code. Still, we believe that to be less disruptive than the alternatives. Some of our companies serve customers in other states in which overlays have been implemented. Very few complaints have been associated with the transition to ten digit dialing in those exchanges. We anticipate similar consumer acceptance in Idaho. If Alternative 2, the geographic split is chosen, more than half of the state will have very major disruption. The disruption with rernernbering one new number is manageable. If you are among half of the state unfortunate enough to be moved from the 208 area code to the new one, all of the local numbers you routinely call will be changed. Remembering all new numbers in your local area (where the vast majority of all calls are directed) will be a significant challenge. While it is true that the smart phone and speed dial capabilities that can ease the disruption of Alternative I also will ameliorate some of this concern, they will not be as seamless as they will be under Alternative l. The 20Yo of calls not contained in a speed dial or a directory will not just have a new area code to rernember. They may well have entirely new numbers, something that will be far more difficult to remember. Perhaps the most disruptive of all is the disruption to business (large and small) that has invested in a phone number that will have to be changed. Most business have good will associated with their phone numbers and have advertising, letterhead, webpages and the like that will have to be changed - - at no small expense. That change will take time for the old number to leave the public domain and be replaced by the new number. Until the old information has been replaced by new (not just by the business but by the person looking for the business' number) and the public has internalized those changes, members of the public will find it challenging to COMMENTS OF THE IDAHO TELECOM ALLIANCE, NC.Page 3 call the businesses with whom they do business. This is not just a nuisance. It has the potential to cause significant heartburn. For many ldahoans this is not just a business problem. Many of us have a strange attachment to our "own" telephone numbers, just like we do to our automobile license plate numbers. Admittedly this may be a stronger attachment in rural Idaho than elsewhere - - but that is where we (and our customers) live. III. CONCLUSIONANDRECOMMENDATION ITA member companies can implement either Alternative I or Alternative 2, although we are aware of concerns that Alternative2may be more challenging technologically. While it is tempting to say that someone else's area codes should be changed and that we should be "left alone" in our serice territories, that isn't responsible. That would simply foist the problem on someone else. In our view, the best choice provides the least disruption for all users of telecommunications and broadband senrices in Idaho, and that is Alternative 1, the "all services overlay." '-thSubmitted this 5 Tdayof october,2015. KennethR. McClure Givens Pursley LLP P.O. Box2720 Boise,Idaho 83701 Tel: (208) 388-1200 Fax: (208) 388-1300 krrn@givenspursl ey. com Attorneyfor ldaho Telecom Alliance, Inc. COMMENTS OF THE IDAHO TELECOM ALLIANCE, NC.Page 4