20151005Comments.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
(208) 334-03s7
IDAHO BAR NO. 7956
Street Address for Express Mail:
472W, WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
NEUSTAR, INC., ON HEBALF OF THE IDAHO
TELECOMMUNICATIONS INDUSTRY, FOR
APPROVAL OF NUMBERING PLAN AREA
RELIEF FOR THE 208 ARE,A CODE.
F.fiCIil lV[: l]
I$15 0UT -5 Plt ?: 32
uvti-rrYffis&mki'd*'**
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. GNR.T.15.O6
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Brandon Karpen, Deputy Attorney General, and in response to the Notice of
Application and Notice of Modified Procedure issued in Order No. 33355 on August 6,2015, in
Case No. GNR-T-I5-06, submits the following comments.
BACKGROUND
On July 21,2015, Neustar, Inc. filed an Application seeking approval to implement a
"Relief Plan" for the 208 area code, which has been projected to run out of available prefixes in
mid-2018. Neustar made this Application in its capacity as the administrator of the North
American Nurnbering 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 for the
entire State of Idaho, which is currently served only by the 208 area code. Neustar further
I Industry is composed of current and prospective telecommunications carriers operating in, or considering
operations within, the 208 area code of Idaho.
STAFF COMMENTS OCTOBER 5,2015
recommends a l6-month implementation period. The proposed overlay relief plan will require
all customers to dial l0 - digits for all local telephone calls and I + 10 digits for long-distance
calls.
In April 2015, Neustar reported that the 208 number plan area ("NPA") is projected to
exhaust during the second quarter of 2018. Due to the projected exhaustion of available
numbers, Neustar notif,red the Industry on April 14,2015, that area code 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: (l) overlaying a
new area code for all services ("Overlay"); and (2) splitting the state into two or more area codes
("Split").
With an Overlay, a new area code would be superimposed over the existing 208 NPA.
All existing customers would retain their current20S arca code and their current phone number.
With the Overlay, customers would be required to dial ten digits (area code + the telephone
number) for all calls. Neustar claims that the Overlay alternative has a projected life of 66 years.
Id. at 4.
With the Split alternative, Idaho would be split into two distinct geographic areas and a
new area code would be assigned to one area. The other area would retain the 208 area code.
The Split plan would require ten-digit dialing between different area code areas. However,
within the same area code, seven-digit dialing would be permitted. The Idaho customers who
receive the new area code would have to abandon their current 208 area code numbers and be
assigned a new area code for their telephone number. 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. 1d 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
STAFF COMMENTS OCTOBER 5,2015
was reached to recommend that the Commission adopt the all-services overlay with a l6-month
implementation schedule, as follows:
EVENT TIMEFRAME DATE
Total Implementation Period l6 months
Start Network Preparation and Customer Education 6 months TBD
Start of Permissive 7-digit and 10-Digit Dialing Period
(Calls within 208 NPA can be dialed using 7 or l0 digits)
and continued Customer Education
9 months TBD
Mandatory dialing at the end of the Permissive Dialing
Period during 4Q2017
TBD
First Code Activation after end of Permissive Dialing
Period (Effictive date for codes from new NPA)
I months TBD
Neustar has indicated that the Commission has some flexibility in choosing
implementation dates on the proposed schedule. See Exhibit A at 7. In setting dates, Neustar has
encouraged the Commission to give serious consideration 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 avoid major holidays and tourism seasons. Finally, Neustar
recommends that mandatory dialing begin six months prior to the forecasted exhaust for the 208
NPA, which would be fourth quarter 2017.
Neustar has requested that this Application be processed under Modified Procedure.
STAFF REVIEW
Beginning in2002, the Commission began a proactive approach to extending the 208
area code as it was approaching exhaust back then. Some of the actions taken by the
Commission were rate center consolidation, mandatory Thousand-Block-Number Pooling and
reclamation of unused blocks/uncontaminated numbers from carriers. This activity was able to
stave off exhaust for 16 years. The current exhaust date is second quarter 2018, which in
accordance with the NPA Code Relief Planning and Notification Guidelines, is typically thirty-
STAFF COMMENTS OCTOBER 5,2075
six months. Because of this requirement, Staff began its investigation into exhaust relief
planning at that time.
For its review, Staff looked at public comments, national trends (geographic splits/all-
services overlays), technological advances and associated requirements. Because Idaho has been
successful at maintaining the 208 area code there was a large amount of national data to use
when assessing what method would be the most beneficial for Idaho consumers.
Public Comments
As of September 23,2015, the Commission had received 39 written comments from the
public. Of those commenters;28Yo were in favor of an overlay, while 670/o rccommended a
geographic split. Two public commenters proposed options that are technically not achievable.
On September 22,2015, the Commission received joint comments from sixteen Idaho carriers.
The telecommunication carriers unanimously supported NANPA's overlay recommendation "as
stated in the NANPA's July 21, 2015 application."
Most of the customers in favor of the geographic split have expressed a desire to keep
their current20S area code phone number and proposed that those customers outside of the split
area be assigned the new area code. Customers in favor of the all-services overlay cite concerns
of costs associated with geographic splits for businesses having to obtain new phone numbers,
billing invoices, business cards, advertisement, signage on vehicles, etc. There were also
arguments from residential customers concerned about the inconvenience if they were assigned a
new area code.
Staff agrees with the customers and Telecommunications carriers who favored the all-
services overlay. Staff believes it is fiscally sound to assign the new area code to new Idaho
customers and to implement ten digit dialing. It also avoids the question of choosing which
customers were to keep the 208 area code and who would have to change their numbers, which
would be the case if a geographic split were favored. Moreover, a split may be cost prohibitive
for businesses and inconvenient for half the states population.
National Trends - Geographic Split vs All-Services Overlay
Staff has been reviewing the common practices throughout the United States. It has been
eight years since a geographic split was implemented. Time has proven that with an all-services
overlay customers have been able to adjust to ten digit dialing much more readily than those
STAFF COMMENTS OCTOBER 5,2015
states where a geographic split was used. For states that have enacted a geographic split,
ultimately those decisions were reversed and an overlay was implemented.2
At the point when the vast majority of dialing plans are mandatory 10-digit dialing, the
FCC accepted a "Best Practice" recommendation from the North America Numbering Council
(NANC), wherein the NANC recommended that an overlay be the Commission's position as it
comports with the industry's recommendation as a state's option to choose the best means of
implementing area code relief for its citizens. See FCC Order DA 14-842. The reasons cited for
this recommendation were that the vast majority of dialing plans are mandatory l0-digit dialing
and most customers no longer "dial" a number because the person/business being called are
stored in mobile/smart phone applications.
From an industry standpoint, an overlay is much more efficient and technically sound.
With a geographic split all carriers would have programming and translation challenges. The
potential of a number being programmed incorrectly may result in a customer not being able to
call out or receive calls. With an overlay, the potential for mistakes is significantly reduced and
the process is much more efficient.
Technological Advances in the Telecommunications Industry
Currently, many carriers are converting their networks over to all IP networks.3 This is
being done so that newer network routing technologies can be utilized for new technological
service offerings such as Voice over Internet Protocol ("VoIP"). These new technologies are
increasingly requiring 1O-digit dialing platforms. The Federal Communications Commission has
opened many dockets to address these technological advances and is currently investigating an
eventual all IP network. Eventually, there will come a time where lO-digit dialing will be
2 WestYirginiaPSC (CaseNo.00-953-T-PC\.February 13.2008. Order Granting Petitionfor Reconsideration and
Ordering an Overlav for 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."
3 The Internet Protocol. IP is the most important of the protocols on which the internet is based. The IP Protocol is
a standard describing software that keeps track of the Internet's addresses for different nodes, routes outgoing
messages, and recognizes incoming messages.
STAFF COMMENTS OCTOBER 5,2015
required, therefore it is beneficial for Idaho to move toward this dialing platform in anticipation
ofthe advances that are underway.
STAFF RECOMMENDATIONS
There have been no geographic splits implemented since October 2007. The nation is
already making progress in moving toward a consistent lO-digit dialing plan as area code
overlays have become the prevalent method of area code relief implemented for almost a decade.
Overlays eliminate the need for consumer number changes, treat all consumers fairly, are
simpler to implement from a technical standpoint and subsequent relief is easily implemented
when needed through an additional overlay. Because 10-digit local dialing is a federal
requirement for overlays, overlays essentially pave the way for an eventual nationwide 10-digit
dialing plan.
Staff recommends the Commission adopt the all-service overlay presented in the North
American numbering Plan Administrator's Relief Plan and supported by the Joint
Telecommunications Carriers' comments.
Staff recommends that with the overlay, l0-digit mandatory dialing be implemented.
Staff further recommends that all Telecommunications providers launch a comprehensive
educational program for each companies' Idaho customers.
Finally, when the Industry finalizes its l6 month implementation plan, an informational
notice be filed with the Commission.
Respectfully submitted this 6+Yoay of october 2015.
Technical Staff: Carolee Hall
i : umisc/comments/uwiw I 5.2bkrpsph comments
6STAFF COMMENTS OCTOBER 5,2015
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE TTIIS 5d' DAY OFOCTOBER2O15,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. GNR.T-15.06, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
KIMBERLY WHEELER MILLER
NEUSTAR INC
1775 PENNSYLVANIA AVE NW
4TH FLOOR
WASHINGTON DC 20006
MARY S HOBSON
341I W MORRIS HILL RD
BOISE ID 83706
CERTIFICATE OF SERVICE