20150724Decision Memo.pdf

DECISION MEMORANDUM 1
DECISION MEMORANDUM

TO: COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSION SECRETARY COMMISSION STAFF LEGAL

FROM: BRANDON KARPEN
DEPUTY ATTORNEY GENERAL DATE: JULY 24, 2015

SUBJECT : 208 AREA CODE RELIEF PLAN, CASE NO. GNR-T-15-6
On July 21, 2015, Neustar filed an Application seeking approval to implement a
“Relief Plan” for the 208 area code, which has been projected to run out of available numbers in
mid-2018. Neustar makes this application in its capacity as the administrator of the North
American Numbering Plan (“NANP”), and on behalf of the Idaho telecommunications industry
(“Industry”).1 Neustar’s proposed Relief Plan includes the addition of a new area code
overlaying the geographic area currently served only by the 208 area code, with a 16-month
implementation period. The overlay relief plan requires ten-digit dialing for all telephone calls.
Neustar is represented by non-Idaho attorney Kimberly Miller, and local counsel
Mary Hobson. Miller has filed a Petition for Limited Admission to appear before the
Commission and has also requested that local counsel be excused from attendance at any
proceeding before the Commission. Miller has been granted pro hac vice admission by the Idaho
State Bar to participate in this matter on behalf of Neustar.
THE APPLICATION
The NANP divides territory under its management 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 a routing address in the public
switched telephone network. Neustar serves as a neutral third-party NPA Relief Planner for
Idaho under the NANP.
1 Industry is composed of current and prospective telecommunications carriers operating in, or considering
operations within, the 208 area code of Idaho.
DECISION MEMORANDUM 2
In April 2015, Neustar reported that the 208 NPA is projected to exhaust during the
second quarter of 2018. Due to the projected exhaust of numbers, Neustar notified the Industry
on April 14, 2015, that NPA relief needed to be addressed. On June 9, 2015, Neustar 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”).
The Overlay “would superimpose a new NPA over the same geographic area covered
by the existing 208 NPA. All existing customers would retain the 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 claims that the Overlay has a projected life of 66 years. Id. at 4.
Conversely, in a Split, Idaho would be split into two or more geographic areas and
new NPAs would be assigned to the areas formed by the split, and one area would retain the 208
NPA. All split plans require ten-digit dialing between different NPAs. However, within the
same NPA, seven-digit dialing would be permitted. Id. Neustar stated in its Application that
“the proposed boundary line 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. According to Neustar, the area north and east of the boundary line has a projected life of 68
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.
During the June conference call, Industry representatives discussed the attributes of
both alternatives. Participants on the conference call included incumbent local exchange
carriers, competitive local exchange carriers, cellular carriers, broadband carriers, Commission
Staff, and Neustar Relief Planning experts. See Exhibit A at 9. At the conclusion of the call, a
consensus was reached to recommend that the Commission adopt the all-services overlay with a
16-month implementation schedule.
The recommended schedule is as follows:

DECISION MEMORANDUM 3
EVENT TIMEFRAME DATE
(Calls within 208 NPA can be dialed using 7 or 10 digits) 9 months TBD
(Effective date for codes from new NPA)

Neustar has indicated that there is flexibility as to when the Commission assigns
implementation dates on the schedule. See Exhibit A at 7. Neustar has encouraged the
Commission to give serious consideration as to what time of year is best to introduce dialing
changes, as well as the length of time to allow for permissive dialing. Neustar recommends that
the Commission should try to avoid major holidays and tourism seasons. Finally, Neustar
recommends that mandatory dialing begin six months prior to forecasted exhaust for the 208
NPA, which would be fourth quarter 2017.
Neustar has requested that this Application be processed under Modified Procedure.
PETITION FOR LIMITED ADMISSION
In a separate filing, Neustar’s attorney of record Kimberly Miller filed a petition
requesting that the Commission grant her limited admission. The local counsel associated with
this Motion is Idaho attorney Mary Hobson.
Miller has been admitted by the Idaho State Bar under Bar Rule 227, has certified that
she is an active member in good standing with the District of Columbia Court of Appeals, and
that she maintains a regular practice of law with Neustar, Inc. in Washington, D.C. Both Hobson
and Miller have further acknowledged that as local counsel, Hobson’s attendance shall be
required at all proceedings before the Commission in which Miller appears, unless specifically
excused by the Commission. Neustar also requested that Hobson be excused from attendance at
any proceeding before the Commission in this matter.
STAFF RECOMMENDATION
Staff recommends the Commission issue a Notice of Application and Notice of
Modified Procedure establishing a 60-day comment period to process the Application. Staff
DECISION MEMORANDUM 4
further recommends that the Commission grant Miller’s Petition for Limited Admission and
Neustar’s request that local counsel be excused from proceedings before the Commission.
COMMISSION DECISION
Does the Commission wish to issue a Notice of Application and Notice of Modified
Procedure establishing a 60-day comment period to process Neustar’s Application? Does the
Commission wish to grant limited admission to Kimberly Miller and excuse local counsel from
attending proceedings before the Commission in this matter?

__Brandon Karpen_________________ Brandon Karpen Deputy Attorney General

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