HomeMy WebLinkAbout28943.docBEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE INVESTIGATION INTO RATE CENTER CONSOLIDATION FOR QWEST CORPORATION IN SOUTHERN IDAHO TO CONSERVE AVAILABLE NXX CODES. )
)
)
)
)
)
CASE NO. USW-T-99-21
ORDER NO. 28943
On its own Motion, the Commission initiated an investigation in September 1999 to examine actions which may delay the need for additional telephone area code(s) in Idaho. More specifically, the Commission sought comments on the possible consolidation of rate centers in Qwest Corporation’s southern Idaho service area. Rate centers are the geographic coordinates typically used by telephone companies for determining whether a call is a local or long-distance (toll) call. In response to the Commission’s Notice, Qwest initially proposed that 42 of its existing exchanges be consolidated into six rate center groups. Parties filing comments were supportive of rate center consolidation. In September 2000 and again in December 2001, Qwest updated its consolidation proposal.
On December 21, 2001, the Commission issued a Notice of Amended Application and a Second Notice of Modified Procedure in this matter. Pursuant to the Notice, the Commission Staff and Citizens Communications filed additional comments. Having reviewed Qwest’s consolidation proposals and the comments submitted by the parties, we direct Qwest to implement rate center consolidation as set out in greater detail below.
BACKGROUND
A. General
The consolidation of rate centers is one method of conserving NXX prefixes and ultimately delaying the need for a new area code. Historically, there is a rate center associated within each exchange and the local exchange company has at least one NXX (the prefix or the first three digits in a seven digit telephone number) for each rate center. As local telephone competition emerges, it is typically necessary for each new provider or competitor to obtain an NXX for each rate center in the area in which it provides service. For example, a competitor providing service throughout the Qwest Treasure Valley calling area would normally obtain 18 NXX codes corresponding to the 18 exchanges in the calling region. Rate center consolidation reduces the number of rate centers in a local calling area and, consequently, allows for greater conservation of NXX prefixes.
In its Second Notice of Modified Procedure, the Commission also noted that there were other methods of delaying the exhaustion of the 208 area code. Number pooling allows telephone numbers to be allocated to service providers in blocks of 1,000 numbers instead of the existing common network-mandated blocks of 10,000 numbers. On November 6, 2001, the Commission petitioned the FCC to implement number pooling in the Boise metropolitan area in 2002. The FCC has yet to rule on the Commission’s Petition.
In response to the North American Numbering Plan Administrator’s notice that Idaho’s 208 area code was scheduled to exhaust in 2003, the Commission found it appropriate to propose that Idaho be geographically split into three distinct area code regions. In Order No. 28902, the Commission found that it does not need a new area code if the FCC grants the Commission authority to require number pooling in Idaho. On reconsideration, the Commission reaffirmed its decision to split Idaho into three geographic areas each with its own area code. In Order No. 28924 issued January 11, 2002, the Commission affirmed its belief that new area code(s) would not be required if number pooling is implemented in a timely manner.
B. Procedural History
In its initial Notice of Modified Procedure, the Commission requested written comments from interested parties. The Commission specifically requested comments regarding: (1) the Qwest exchanges appropriate for consolidation; (2) the manner of consolidation and any technical concern; (3) implementation concerns, such as timing, costs, etc.; and (4) potential cost recovery mechanisms, if necessary. The Commission directed that Qwest file initial comments and identify exchanges appropriate for consolidation. After Qwest submitted its proposal, Verizon and the Commission Staff filed comments supporting consolidation. Qwest filed reply comments with a second consolidation proposal.
On December 5, 2001, Qwest again revised its recommended list of exchanges to be consolidated into rate center groups. On December 21, 2001, the Commission issued an Amended Notice of Application and a Second Notice of Modified Procedure. Pursuant to the Notice, the Commission Staff and Citizens Communications filed the comments.
THE COMMENTS
A. The Initial Comments
1. Qwest’s Initial Proposal and Comments. In general, Qwest “supported this Commission’s interest in preserving NXX codes in Idaho.” Comments at 2. In evaluating rate centers to consolidate, Qwest stated that it adheres to two general principles. First, the Company anticipated that the current dialing patterns for intra- and interLATA toll calls will not change. Second, the Company believed that it is essential to protect the integrity of the present E911 routing system.
Qwest maintained that the public interest would be served by consolidating many of its rate centers and, over the course of this case, the Company has worked with the Commission Staff to explore several consolidation scenarios. Qwest stated that what makes rate center consolidation possible is the alignment of local calling between exchanges. However, there are several exchanges that should not be included in a group. For example, Nampa, Caldwell, Blackfoot, and Burley should not be included in any group because there are no Qwest exchanges with precisely the same calling area as these exchanges. Id. at 6.
Qwest suggested that one possible drawback to immediate rate center consolidation has to do with future extended area service (EAS) expansion. More specifically, if the Commission implements rate center consolidation, then future “EAS expansion must occur by rate center, not by individual exchange.” Id. This requirement arises because “once a rate center is consolidated, there is no longer any methodology whereby the network can distinguish between ‘pieces’ of the rate center so that some calls remain local while others be treated as toll.” Id. at 7.
Turning to the issue of cost recovery for consolidation, Qwest did “not anticipate requesting compensation for the implementation of rate center consolidation in Idaho. . . due to the limited scope of the implementation required.” Id. at 9. Costs to implement rate center consolidation would be limited to reprogramming the Company’s billing system and would not require additional hardware in the network. Consequently, “[n]o request is being made at this time. . . .” Id.
The Company estimated that it would take six months to implement the billing system updates required for consolidation and notify other carriers of network changes. It would take another six months to prepare number block donations for pooling.
Finally, Qwest commented on the issue of E911 default routing. Default routings of 911 calls are very rare and occur when calls placed to 911 either: (1) fail to carry their automatic number identification (ANI); or (2) the automatic line identifier (ALI) database does not contain 911 public service answering point (PSAP) routing information for the ANI that was sent. If rate centers are consolidated, there may be more than one PSAP in some rate center groups. Qwest maintained that if this occurs, each “service provider [must] establish a unique trunk group for each default PSAP located in each end office serving area.” Comments at 10.
2. Verizon Comments. In its reply comments, Verizon recommended that the Commission adopt rate center consolidation for Qwest in southern Idaho. In recommending consolidation, Verizon asserted that the following criteria should apply to any proposed rate center consolidation. In particular, Verizon suggested that consolidation rate centers should be contiguous and capable of local number portability, have identical local calling areas, and identical local exchange service rates. In addition, Verizon recommended that:
a) Consolidation not create undo technical implementation complications for service providers without establishing cost recovery mechanisms as part of the consolidation process.
b) Rate centers should not be consolidated across LATA or area code boundaries.
c) Consolidation must not affect the provision of critical emergency services such as 911.
3. Staff Comments. Staff agreed that reducing the number of rate centers reduces the number of NXX codes each new service provider needs to serve a local calling area. In the long run, rate center consolidation “prolongs the life of the 208 area code and avoids the expense of adding a second area code for Idaho.” Staff Comments at 2.
The Staff stated that the cost, if any, in implementing rate center consolidation is far outweighed by the benefits. Id. at 3. The conservation of numbers in assigning single NXX codes for each group justifies consolidation. Staff asserted that given the benefits of consolidation, no specific cost recovery mechanism is necessary. Id. Staff also endorsed the comments of Qwest that all exchanges included within a single rate center must share the same local calling area. Id. at 4.
Turning to the issue of 911 calling, the Staff observed that it was likely that more than one PSAP will be present in each rate center group. The Staff also agreed with Qwest that the “over whelming majority of calls to 911 . . . should not present a problem.” Id. at 5. In those rare circumstances when calls do not contain the necessary ANI or ALI information, each new telephone service provider “will need to establish a new trunk group to each default PSAP in a rate center.” Id. Staff believes that calls to southern Idaho 911 systems all deliver ANI to the PSAP.
4. Qwest Reply Comments. On September 19, 2000, Qwest filed further comments in this matter with a second consolidation proposal. The Company observed that several outstanding EAS cases had been concluded and that the FCC was beginning to require number utilization thresholds before additional prefixes are assigned to rate centers.
B. The Current Comments
As previously mentioned, Qwest submitted its third consolidation proposal on December 5, 2001. The Commission issued a Second Notice of Modified Procedure on December 21, 2001. Citizens Communications and the Staff were the only parties to submit additional comments.
1. Staff Comments. The Staff stated that it continues to believe that it is appropriate and reasonable for Qwest to implement rate center consolidation. Staff noted that the current consolidation proposal includes rate centers that: are contiguous; have the same local calling area; do not cross LATA boundaries; and will have no adverse impact to the provision of 911 service. “Rate center consolidation also decreases the demand for prefixes while increasing the effectiveness of 1,000 block pooling by increasing the scope of rate centers from which to pool numbers.” Staff Comments at 5.
Staff reiterated that costs, if any, associated with implementing rate center consolidation are far outweighed by the benefits. Staff did not believe that customer rates will be affected or that any cost recovery mechanism is necessary.
Staff recognized that some customers who are on distance-sensitive toll plans may see increases in their per-minute toll rates when new vertical and horizontal (V&H) coordinates are established for a consolidated rate center. This impact may be more pronounced for customers located in exchanges immediately outside large local calling areas. However, the Staff believes that the number of affected customers will be very small given the popularity of simple per-minute calling plans and the expansion of EAS routes throughout Idaho. Id. at 6. To mitigate any adverse impacts, Staff recommended that carriers notify their customers of the coming changes and the option for simple per-minute toll plans.
Staff also repeated that consolidating rate centers now will impact the Commission’s ability to implement EASs in the future. Consequently, Staff recommended removal of the Emmett, Melba, Murtaugh, Rigby, and Roberts exchanges from the consolidation proposal. The Staff proposed consolidation plan is compared to the Qwest December 2001 proposal below.
Qwest December 2001
Recommended Groups
Staff
Recommended Groups Emmett, Kuna, Melba, Meridian, Middleton, Star
Glenns Ferry and Mountain Home
Hailey and Ketchum
Boise and Idaho City
American Falls, Bancroft, Downey, Grace, Lava Hot Springs, McCammon, Montpelier, Pocatello, Preston, Soda Springs
Idaho Falls, Rexburg, Rigby, Ririe, Roberts, Shelley (including Firth)
Bliss, Buhl, Castleford, Eden/Hazelton, Gooding, Hagerman, Jerome, Kimberly, Murtaugh, Shoshone/Dietrich, Twin Falls, Wendell.
Cottonwood and Grangeville
Kuna, Meridian, Middleton, Star
Glenns Ferry and Mountain Home
Hailey and Ketchum
Boise and Idaho City
American Falls, Bancroft, Downey, Grace, Lava Hot Springs, McCammon, Montpelier, Pocatello, Preston, Soda Springs
Idaho Falls, Rexburg, Ririe, Shelley (including Firth)
Bliss, Buhl, Castleford, Eden/Hazelton, Gooding, Hagerman, Jerome, Kimberly, Shoshone/Dietrich, Twin Falls, Wendell
Rigby and Roberts
Cottonwood and Grangeville
Staff’s proposal provides for slightly less consolidation than Qwest’s current plan, but it allows 38 rate centers to be consolidated while giving the Commission flexibility for future EAS routes.
Staff also recognized that Qwest will need at least three months to notify carriers of new V&H coordinates. However, Staff also noted that the Commission has asked the FCC to accelerate Idaho’s number pooling timetable. “Because it is preferable to have consolidation done before pooling begins, Staff believes that Qwest should be prepared to accelerate its consolidation timetable if Idaho’s [pooling] request is granted by the FCC.” Staff Comments at 7. Consequently, Staff asserted that it is appropriate for the Commission to allow Qwest 21 days in which to present its implementation schedule “with the understanding that the Company may need to accelerate an implementation date if the FCC grants” the Commission’s pooling request. Id.
Citizens Comments. In its comments, Citizens expressed serious concerns with two of the proposed consolidations. Under Qwest’s most recent proposal, Group No. 1 would consolidate Emmett, Kuna, Melba, Meridian, Middleton, and Star into a single rate center. Citizens asserted that this consolidation would significantly impact its customers located in the Sweet exchange. The Company noted that Citizens’ Sweet exchange currently has EAS to Emmett but not to the other exchanges in the proposed group. Citizens’ Comments at 2. Including Emmett in the first group would require that the Sweet EAS to Emmett be expanded to all the exchanges in the group or that the EAS be eliminated. Citizens noted that either option will impact the Company and its customers. “If EAS is granted to the entire cluster, the proposed consolidation will result in higher rates to recover lost revenues and incremental expense that may be required to handle additional traffic. If EAS is eliminated, customers in Sweet will no longer be able to make toll-free calls to the county seat.” Id.
Citizens also expressed concern with the proposal to consolidate the Cottonwood and Grangeville exchanges into a single rate center. The Company noted that its Elk City exchange has local option calling to Grangeville but not to Cottonwood. If the proposed consolidation of these two exchanges were approved, Citizens would need to increase the price of its local calling plan to recover lost revenues and incremental expenses of adding Cottonwood as a terminating exchange. Id. at 2-3. Citizens did not include any revenue impacts in its comments. Finally, Citizens requested that the Commission hold a hearing “to further explore the impact of rate center consolidation on customer rates and local calling scope.” Id. at 3.
FINDINGS AND DECISION
After reviewing Qwest’s proposals and the comments, the Commission finds that it is appropriate to implement rate center consolidation for Qwest’s southern Idaho area as outlined below. All commenters supported consolidation. We find that consolidation will conserve the assignment of and promote greater efficiency in the use of NXX codes. This, in turn, may extend the life of Idaho’s area code. We now turn to the comments of the parties.
Citizens expressed serious reservations concerning two consolidation groups. In particular, Citizens noted that its Sweet exchange currently has EAS to Emmett. Including Emmett in the first consolidation group would require that Sweet’s EAS be expanded to all the exchanges in the group or that it be eliminated. Obviously, eliminating EAS will disadvantage customers and is unacceptable. On the other hand, expanding EAS from Sweet to the other five exchanges in the proposed group would significantly reduce Citizens’ access charge revenues and likely lead to a rate increase. Consequently, we find that it is appropriate to adopt Staff’s suggestion to remove the Emmett exchange from the first consolidation group. Removing the Emmett exchange maintains the status quo for Citizens’ customers.
We find a similar solution is appropriate to address Citizens’ concerns about the proposed consolidation of the Cottonwood and Grangeville exchanges into a single rate center. Unfortunately, Citizens did not include any financial information on its estimated revenue impacts of consolidating the Qwest exchanges of Cottonwood and Grangeville. However, having addressed Citizens concerns, we find it is not necessary to hold a hearing.
The Commission Staff also recommended that we remove the Melba and Murtaugh exchanges from the Qwest consolidation proposal. Even though we currently have no EAS requests affecting these exchanges, we believe it is reasonable to remove them. Adopting the Staff’s recommendations results in a consolidation of 37 exchanges into 8 consolidation groups. This action will conserve many NXX codes and reduce the pressure for new area codes.
Although we realize that some customers who subscribe to distance-sensitive toll plans may be adversely affected by consolidation, we find the benefits of the consolidation outweigh these adverse affects. We believe that the number of affected customers is likely to be small and that they have alternatives available to mitigate any adverse consequences. In implementing rate center consolidation, Qwest shall notify local exchange companies and toll carriers of the change in vertical and horizontal coordinates. We direct toll carriers with distance sensitive rates to notify their customers of the possible rate impacts of the changes in the V&H coordinates.
We also find that the costs associated with implementing rate center consolidation will be minimal and outweighed by the benefits. Consequently, we see no need to implement a specific mechanism to recover the costs of implementation. Indeed, Qwest has not proposed any recovery mechanism.
Having concluded that rate center consolidation is appropriate and reasonable, Qwest shall file an implementation schedule with the Commission within 21 days of the service date of this Order. To the extent possible, the Commission desires to accelerate the rate center consolidation implementation schedule with the hope that the Federal Communications Commission will also grant our request to initiate number pooling and the life of the 208 area code can be extended.
O R D E R
IT IS THEREFORE ORDERED that Citizens Communications’ request for a hearing in this matter is denied.
IT IS FURTHER ORDERED that Qwest implement rate center consolidation as set out above.
IT IS FURTHER ORDERED that Qwest notify local exchange companies and toll carriers of the change in vertical and horizontal coordinates associated with rate center consolidation. Carriers whose customers may be affected by rate center consolidation shall advise their customers of the impending change.
IT IS FURTHER ORDERED that Qwest file its implementation schedule with the Commission within 21 days of the service date of this Order.
THIS IS A FINAL ORDER. Any person interested in this Order (or in issues finally decided by this Order) or in interlocutory Orders previously issued in this Case No. USW T 99 21 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 or in interlocutory Orders previously issued in this Case No. USW T 99 21. Within seven (7) days after any person has petitioned for reconsideration, any other person may cross-petition for reconsideration. See Idaho Code § 61-626.
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this
day of January 2002.
PAUL KJELLANDER, PRESIDENT
MARSHA H. SMITH, COMMISSIONER
DENNIS S. HANSEN, COMMISSIONER
ATTEST:
Jean D. Jewell
Commission Secretary
vld/O:USWT9921_dh4
AT&T Communications of the Mountain States also submitted a letter of general support for consolidation. Although AT&T reserved the option of filing additional comments, it did not do so.
To demonstrate the rare occurrence of default calls, Qwest noted that the number of default calls to the city of Denver amounts to just two-tenths of 1% of the 911 calls directed to the city.
See Second Report and Order FCC 00-429 CC Docket No. 99-200 Rel. December 20, 2000.
Staff recommended that Rigby and Roberts be removed from Qwest Group No. 6 and that the two exchanges be consolidated in their own group.
ORDER NO. 28943 1
Office of the Secretary
Service Date
February 1, 2002