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Before The Public Utilities Commission Of The State Of California
Order Instituting Rulemaking on the Commission's own Motion Into Competition for Local Exchange Service.
(Filed April 26, 1995)
Order Instituting Investigation on the Commission's own Motion Into Competition for Local Exchange Service.
(Filed April 26, 1995)
Submitted in Compliance with California Public Utilities
Code Section 7937, CPUC decision 99-12-051, and Administrative Law Judge
Ruling Issued On January 18, 2000
CALIFORNIA PUBLIC UTILITIES COMMISSION
October 10, 2001
Jack Leutza, Director
505 Van Ness Avenue, 3rd Floor
San Francisco, CA 94102
CALIFORNIA PUBLIC UTILITIES COMMISSION
October 10, 2001
Prepared by Telecommunications Division:
Michael Amato John Miller
Robert Benjamin Michaela Pangilinan
Mary Jo Borak Craig Stevens
Cherrie Conner Karen Watts-Zagha
Jack Leutza Sue Wong
TABLE OF CONTENTS
I. CHAPTER ONE: OVERVIEW OF NUMBERING 88
II. CHAPTER TWO: 5.61 MILLION UNUSED NUMBERS IN THE 209 AREA CODE .........................................................................................................1818
CHAPTER THREE: NUMBER POOLING AND OTHER NUMBER CONSERVATION MEASURES 4343
Like much of the country, California currently is experiencing a numbering crisis. From 1947 to January 1997, the number of area codes in this state increased gradually from 3 to 13. During the next three years, however, the number of area codes in California nearly doubled. By the end of 1999, California had 25 area codes statewide. The California Public Utilities Commission (CPUC) recently implemented several measures intended to ensure efficient use of telephone numbers. Without the implementation of major conservation measures, the telecommunications industry had plans underway to add 22 more area codes in California by the end of 2003, resulting in a statewide total of 47 area codes.
This study recounts the history of the 209 area code, from its creation in 1958 when it was geographically split from the 415 area code. Today, the 209 area code serves portions of Alpine, Amador, Calaveras, Mariposa, Merced, San Joaquin, Stanislaus, and Tuolumne counties. Portions of 209 are located within the Sacramento, Stockton and Fresno Metropolitan Statistical Areas (MSA). This report should be viewed in a broader context than the facts pertaining solely to the 209 area code. The report evaluates the status of number availability in the 209 area code, and discusses the various state and federal policies which govern number use in California and nationwide. In addition, the report analyzes number use by carrier category and identifies what measures the CPUC can employ in the 209 and other area codes to improve efficiency of number use in order to avoid prematurely opening new area codes. Data is self-reported by the companies; the CPUC staff has not audited any 209 utilization data submitted for this study and report.
The utilization study sheds new light on the numbering crisis in the 209 area code. The data reveals that despite increasing demand for numbers, the 209 area code is not fully utilized. The study found that of the 7.75 million useable numbers in the 209 area code, approximately 5.61 million, or 72%, presently are not in use. The data further establishes that the 209 area code possesses considerable room for growth, and thus, aggressive measures such as splits or overlays are not yet warranted in the 209 area code. The report further urges the CPUC to seek from the FCC authority to implement Unassigned Number Porting (UNP) as a means to more efficiently use numbers still available in the 209 area code.
This report is filed in compliance with CPUC Decision (D.) 99-12-051, and with AB 406, enacted by the California Legislature in the 1999 legislative session. (Chapter 99-809, 1999.) AB 406, codified as Public Utilities Code Section 7937, requires the CPUC to obtain historical telephone number use data from every telecommunications company in California. The CPUC's Telecommunications Division (TD) first obtained and analyzed data from the 310 area code in Los Angeles late in 1999, and produced a utilization report on the 310 area code in March 2000. In November 2000, TD completed utilization reports covering the 415, 510, 818, and 909 area codes, and in March 2001 TD completed utilization reports covering the 408, 619, 650, and 714 area codes. TD released another four utilization reports in May 2001 covering the 323, 562, 916, and 925 area codes, and in July released reports on the 626, 707, 805, and 949. This report on the 209 area code continues TD's analysis covering specific area code number utilization levels.
The 209 area code contains approximately 7.75 million telephone numbers available for consumer use. These numbers are available to telecommunications companies which obtain the numbers from the North American Numbering Plan Administrator (NANPA), 1 and in turn, assign the numbers to their customers for their immediate use. Alternatively, companies may reserve numbers for future use, or retain numbers for some internal (administrative) use. Some companies provide blocks of numbers to resellers or "dealers", which then assign those numbers to customers. The FCC deems numbers that companies allocate to resellers to be "intermediate" numbers. In addition, each assigned number, after disconnection, must "age" during a transition period before assignment to the next customer. Many companies have inventories of numbers in the "aging" process. Finally, some numbers are not available for public use, as they have been set aside for emergency purposes, for technical network support, or for other reasons. The FCC has defined numbers in these five categories - assigned, administrative, reserved, intermediate, or aging - as unavailable, either because they are already in use or are designated for some present or future use.
TD's analysis shows that of the 5.61 million available numbers, approximately 2.56 million have been set aside by the CPUC to use in a lottery for companies seeking numbers. Companies possess the remaining unused 3.05 million numbers. Wireline carriers, such as Pacific Bell and many competitive local exchange carriers, hold roughly 1.86 million available numbers, while wireless carriers2 hold approximately 1.19 available numbers.
At the same time, the 209 study finds that under FCC rules about 2.14 million numbers cannot be contributed to the 209 number lottery, nor can they be contributed to the future 209 number pool for reassignment to other companies. The FCC has determined that wireless carriers do not have to participate in the pool at this time.3 In addition, the FCC has determined that the CPUC may only require wireline carriers to contribute to a number pool those blocks of 1,000 numbers that are 10% or less contaminated,4 meaning those blocks in which only 100 or fewer numbers are unavailable. However, wireline carriers may also keep a portion of the 10% or less contaminated blocks if they need to use those blocks within six months. The study further finds that of the 5.61 million numbers not in use, a maximum of 4.54 million numbers5 could be made available to companies through pooling if a) the companies donated blocks with higher contamination levels to the pool, and b) wireless carriers were required to participate in the 209 number pool. The first table below illustrates the current distribution of numbers assuming wireline pooling at 10% contamination. The second table shows the distribution that would occur if all the recommendations in this report were implemented.
In both graphs, numbers may not add to 100% due to rounding.
Finally, the study notes that companies identify 2.14 million numbers as unavailable. TD staff recommends specific measures the CPUC can employ to ensure that companies use those "unavailable" numbers more efficiently. Given the near doubling of the number of area codes in California, from 1996 to 1999, this vital public resource should be used as efficiently and effectively as possible. The CPUC and the telecommunications industry should strive to minimize the quantity of numbers left stranded in company inventories. The 209 Area Code Report recommendations are summarized in Appendix I.
California is currently experiencing an explosive demand for telephone numbers and area codes. The increased demand for numbers is due to many factors, including competition for local phone service, as well as the popularity of faxes, pagers, cell phones, internet services, etc. California's robust economy and the growth in the state's population also contribute to the increased demand for telephone numbers. This increase in demand is complicated by a number allocation system dating from the 1940s that is inefficient in today's competitive marketplace.
Prior to 1997, one phone company6 provided local telephone service to all customers in a particular area and new area codes were opened as the population grew. The number of California area codes rose steadily from three in 1947 to 13 in 1992, and stayed at that level until January 1997. During the next three years, however, the number of area codes in California nearly doubled. By the end of 1999, California had 25 area codes. The Telecommunications Act of 1996 sought to open competition for the local telephone service market and competitive local phone companies7 began to enter the marketplace, each requiring its own stock of numbers. The traditional system of number allocation was not designed to provide telephone numbers to more than one company.
In the past, when telecommunication companies needed telephone numbers to serve their customers, they received blocks of 10,000 numbers, i.e. prefixes. Because companies were assigned blocks of 10,000 numbers, they may have been assigned more numbers than they needed. For example, under this system, a company with only 500 customers would have received a 10,000 number block, the same quantity of numbers a company with 9,500 customers would receive. Thus, numbers are taken in these large blocks, creating an artificial demand for more numbers, which in turn fuels the need to open more area codes. The need to assign 10,000 numbers is a practice from the past when one telephone company provided service to all customers in its territory. Today, with over 200 telecommunications companies in the state needing numbers to serve customers, and with the limited quantity of numbers available in each area code, this process is no longer an efficient way to allocate numbers.
The rise in demand for numbers combined with the inefficient allocation system for numbers has forced the rapid opening of new area codes throughout the state. Since 1997, the number of area codes in California has nearly doubled to 25. Without the implementation of major conservation measures, the telecommunications industry had plans underway to add 22 more area codes by the end of 2003. With more and more companies needing numbers of their own, new area codes are not necessarily the best solution.
The 209 area code was created in 1958 when it was split from 415, one of the three original area codes in California. Area code 559 was carved out of 209 in 1999 reducing the area by half, and establishing a new southern boundary for 209 south of Merced.
Today, the 209 area code serves portions of Alpine, Amador, Calaveras, Mariposa, Merced, San Joaquin, Stanislaus, and Tuolumne counties. Portions of 209 are located within the Sacramento, Stockton and Fresno Metropolitan Statistical Areas (MSAs). Portions of the 209 area code reside in a top 100 MSA and are available for pooling while rate centers not in the top 100 MSA's are not completely open to pooling trials.
In September 1999, the North American Numbering Plan Administrator declared the 209 area code to be in jeopardy. The exhaust projection was for 2nd Quarter 2002. NANPA more recently projected 209 would run out of numbers in 2nd quarter 2005. After a series of public meetings in May 2000, the NANPA submitted in August 2000 for CPUC consideration an exhaust relief plan containing two alternatives for introducing a new area code into the area presently covered by 209, in order to provide additional numbers for phone company use. The alternatives submitted included a 2-way geographic split and an all-services overlay. The CPUC has not issued a decision for the 209 area code. The CPUC first wanted to provide an opportunity to determine the feasibility of extending existing number resources, the purpose of this report8.
1. Monthly Lottery Allocates Prefixes
For those area codes nearing number exhaust, the CPUC has instituted a lottery process to fairly allocate the remaining prefixes among phone companies when demand exceeds supply. The 209 lottery began in October 1999. Currently, the CPUC distributes five prefixes (three initial and two growth9) in the monthly 209 lottery. Each company submits applications for initial and growth prefixes to the NANPA Code Administrator. If more applications are received than can be satisfied in that month, the first applicants chosen by random drawing are assigned a prefix and the remaining applicants are placed on a priority list and receive prefixes in one of the following months' lotteries in the order they were drawn. Once every company requesting a prefix has received one, a new drawing is held and additional companies are eligible to receive prefixes. Forty-six prefixes have been allocated in the 209 area code through this process between January 1, 2000 and December 31, 2000. With the CPUC working with companies to reclaim excess prefixes held by companies, twenty-three prefixes have been returned and reclaimed during the same period, for a net distribution of twenty-three prefixes. During the first nine months of 2001, twenty-two prefixes have been allocated through the lottery, and eleven have been returned to NANPA, for a net distribution of eleven prefixes. As of September 30, 2001 there were 246 prefixes available for assignment in the 209 area code.10
Recognizing the substantial social and economic burdens associated with constant area code changes, the CPUC has taken steps to resolve the numbering crisis. Responding to widespread public outcry over the proliferation of new area codes, the CPUC suspended, beginning in December 1999, all plans for new area codes previously approved. In July 2000, the CPUC adopted number conservation measures, including establishing number pooling trials, fill rates, and sequential numbering.
1. Number Pooling
The CPUC, with FCC approval, has implemented pooling trials in ten area codes, in order to boost the efficiency of phone number allocation. In addition, the CPUC has ordered pooling trials for four other area codes during 2001.
Number pooling allows telephone companies to receive numbers in smaller blocks than the traditional 10,000 numbers, enabling multiple providers to share a prefix, thereby utilizing this limited resource much more efficiently. The technology that enables the network to support the assignment of smaller blocks is referred to as Local Number Portability or LNP.11 LNP was originally mandated by the FCC as a means to enable customers to retain their telephone numbers when they switch telephone service to another local provider. This same platform is utilized for number pooling. The FCC had required all wireline carriers to become LNP-capable by the end of 1998 in the top 100 Metropolitan Statistical Areas (MSAs) in the country. Thirteen of the top 100 MSAs are located in California; the 209 area code is partially located in three of them, the Sacramento, Stockton and Fresno Metropolitan Statistical Areas.12
Though LNP technology has existed for several years, the FCC later granted cellular and PCS companies an extension of time until November 2002 to become LNP-capable. The FCC gave paging companies a permanent exemption from the LNP requirement.13 Thus, at this time, only wireline carriers14 can participate in number pooling. In the area codes with number pooling, wireline carriers participate in pooling and wireless carriers participate in the lottery. In the remaining area codes in rationing, all phone companies participate in the lottery.
The CPUC has been aggressively setting up number pools. In November, 2000, by an Assigned Commissioner's Ruling, the CPUC established a schedule for implementing ten number pools during 2001. The CPUC also issued a more detailed schedule in February 2001 identifying the start dates for the last nine of the ten number pools scheduled to begin in 2001. A pooling schedule has not been set for the 209 area code. Once pooling is implemented in the 209 area code, all wireline companies with numbers in rate centers located in the top 100 MSA's in 209 will be required to donate 1,000-number blocks to the pooling administrator. While FCC rules only require companies to donate numbers to the number pool in rate centers located in the top 100 MSA's, many companies have implemented LNP capability throughout their service territories. These companies could also donate or receive thousand-blocks in all rate centers in an area code's number pool, rather than just in rate centers located within top 100 MSA's. Under the number-pooling program, all LNP-capable carriers receive numbers in blocks of 1,000 on an as-needed basis. There is no rationing process in a number pool and the blocks received can be put into service almost immediately upon receipt. All wireless carriers, as well as wireline carriers who decline to take part in pooling in the rate centers not located in a top 100 MSA, will continue to receive numbers in blocks of 10,000 through the monthly lottery allocation process.
2. Improved Number Inventory Management
While number pools will improve the efficiency of the distribution of numbers to companies, companies have not had strong incentives to efficiently manage the numbers already allocated to them. Thus the CPUC ordered companies to improve number inventory management with measures including rules on fill rates and sequential numbering.
In July 2000, the CPUC issued Decision 00-07-052, which extended number conservation measures adopted in the 310 area code to other area codes within California. These number conservation measures include the following:
· Companies are required to return to the NANPA any prefix held for more than six months without being used.
· "Imminent exhaust criteria" are established in all area codes with lotteries or pooling trials. In each rate center in which companies request additional numbers, they must provide to NANPA a form demonstrating they will be out of numbers within six months15.
· Companies must satisfy a minimum 75% fill rate requirement before being eligible to request a growth prefix in any area code in rationing and before being eligible to receive a thousand-block through the number pool. Companies must assign numbers in thousand block sequence, assigning numbers in the next block only once a 75% fill rate has been attained in the prior block.
TD anticipates these policies will potentially free more numbers for use in number pooling, to be allocated through the lottery, or to be otherwise used by companies. Indeed, these measures together with the effects of number pooling have already achieved some positive results. For example, since the CPUC extended the 75% fill rate and imminent exhaust rules to all area codes, including 209, CPUC staff has observed that the demand for growth prefixes in each month's lottery has declined dramatically. Further evidence of the effectiveness of the CPUC's number conservation policies is the recent increase in the number of excess prefixes in the 209 area code being returned to the NANPA by companies.
3. CPUC Efforts at Federal Level
The FCC has exclusive jurisdiction over numbering in the United States. Therefore, the CPUC's number conservation policies (pooling, fill rates, and sequential numbering) are governed by the FCC's delegation of authority to the states. In recognition of the severity of the numbering crisis in California, the CPUC has aggressively petitioned the FCC for additional authority. As a result, the FCC has delegated authority to plan and implement area code changes, as well as authority to implement number conservation measures.
On April 26, 1999, the CPUC filed a petition with the FCC requesting authority to institute number pooling trials and other number conservation measures within the state to better manage this public resource. On September 15, 1999, the FCC granted that petition, allowing the CPUC to institute mandatory number pooling on a trial basis, deploying it sequentially in one MSA at a time. When the FCC granted the CPUC the authority to deploy various numbering resource optimization strategies, including the authority to institute thousand-block numbering pooling trials, it also clarified that California's authority will be superseded by future national measures adopted by the FCC.
On March 31, 2000, the FCC released the Numbering Resource Optimization Report and Order and Further Notice of Proposed Rulemaking (first NRO Order).16 The first NRO Order sets forth rules for defining numbers, forecasting, tracking and auditing companies' use of numbers, and for conservation measures associated with number usage, including but not limited to number pooling. The definitions of numbers and timelines for aging and reserved numbers that were adopted in that order have been incorporated into the utilization data contained herein.
With the release of the first NRO Order, the FCC adopted a number of administrative and technical measures that will allow it to monitor more closely the way numbering resources are used and to promote more efficient use of numbering resources. In particular, the FCC adopted a nationwide system for allocating numbers in blocks of one thousand, rather than ten thousand, wherever possible, and announced its intention to establish a plan for national rollout of thousand-block number pooling.
Because the FCC recognized that state thousand-block number pooling trials underway might not conform to the national standards set forth in the first NRO Order, the FCC gave state commissions until September 1, 2000 to conform their thousand-block number pooling trials to the national framework. One requirement imposed in California which differs from the national standards is the requirement that companies meet a 75% fill rate in each block before they may receive an additional block from the pooling administrator. The CPUC recognized the 75% fill rate as a critical factor in the success of the 310 pooling trial and petitioned for a waiver of compliance with the national rules. On August 31, 2000, the FCC issued an order granting the CPUC authority to continue to use its pooling rules until the FCC decides on the merits of the petition, or until December 31, 2000, whichever occurs sooner. This allows California to continue applying the 75% utilization rate in its number pooling efforts.
On December 29, 2000, the FCC issued its Second Report and Order on Number Resource Optimization. In the second NRO Order, the FCC also ruled on California's Petition for Waiver, concluding that we may continue to use our utilization thresholds subject to parameters set in this order (when FCC thresholds exceed California's, we must migrate to the more stringent utilization thresholds). The FCC also declined to adopt a transition period between the time that covered CMRS carriers must implement LNP and the time they must participate in any mandatory number pooling.
The first NRO Order further constrains the CPUC by concluding that the rollout of thousand-block number pooling should first occur in area codes that are located in the largest 100 MSAs. In its comments prior to the release of the first NRO Order, the CPUC had argued that California might be precluded from exploring whether number pooling could alleviate the crises for number resources in many parts of the state that are located outside the top 100 MSAs. The CPUC believes the FCC should delegate authority to the states to order deployment of LNP. This grant of authority to California would make pooling possible throughout the state. The 209 area code has three top 100 MSA's where rate centers are located. Fourteen of the rate centers in the 209 area code are located within MSA's that are listed in the top 100 MSA's. The remaining 48 rate centers are outside of the top 100 MSA's.
Currently, state commissions are constrained by the FCC from establishing an area code specifically for wireless telecommunications services. On April 26, 1999, the CPUC filed another petition with the FCC requesting authority to create service-specific or technology-specific area codes. In the 209 area code, wireless carriers hold 167 prefixes. If the CPUC were allowed to create a separate area code for those companies, these 167 prefixes in the 209 area code could be reassigned to other phone uses, thus prolonging the life of the existing area code. To date, the FCC has not acted on the CPUC's petition. In the Second Report and Order, the FCC asks for further comments on technology specific or non-geographic area codes.On September 28, 2000, Governor Davis signed into law Senate Bill (SB) 1741, authored by Senator Bowen. SB 1741 requires the CPUC to request authority from the FCC to require telephone corporations to establish technology-specific area codes based on wireless and data communications, and to permit 7-digit dialing within both that technology-specific area code and the underlying pre-existing area code or codes. The bill requires the CPUC to use any authority so granted unless it makes a specified finding that there is reason not to do so. The legislation also prohibits the CPUC from implementing any authority granted by the FCC in a manner that impairs number portability. The petition that the CPUC filed with the FCC in April 1999 fulfills the technology-specific area code requirement set forth in the bill. The bill also prohibits the CPUC from approving new area codes unless a telephone utilization study has been performed and all reasonable telephone number conservation measures have been implemented.
4. Utilization Studies
Before requiring the residents and businesses of the 209 area code to undergo another area code change, the CPUC recognized the necessity of determining the number of telephone numbers that are in use and the number yet to be used. To that end, the CPUC instituted a utilization study of the 209 area code and required companies to provide usage data to the CPUC as of December 31, 2000. The TD contracted with NeuStar to collect the data; NeuStar submitted the aggregated data in its entirety to TD in April 2001. The definitions used in the utilization study are included in Appendix A-1.
Of the 7.75 million numbers in the 209 area code, companies hold 5.19 million. The other 2.56 million numbers have yet to be assigned to companies. The CPUC's utilization study found that of the 5.19 million numbers held by companies, 3.05 million remain unused in their inventories. Therefore, 5.61 million numbers in the 209 area code remain unused. A portion of these unused numbers can be made available for use by all companies, through the monthly lottery allocation process or through a future number pool. In addition, companies have reported 2.14 million numbers as unavailable. A portion of these unavailable numbers can be used more efficiently if the recommendations contained in this report are implemented.
C. THE SCOPE OF THE UTILIZATION STUDY
1. Distribution Statistics of Prefixes
The CPUC asked thirty-seven companies, holding 519 prefixes in the 209 area code, to report their utilization data with a reporting cut-off date of December 31, 2000. Table 2-1 shows the distribution of prefixes held in 209 by incumbent local exchange carriers (ILECs), competitive local exchange carriers (CLECs),17 cellular/PCS carriers and paging carriers in 62 rate centers.
2. Carriers Reporting
Of the 37 companies in the 209 area code, 33 companies submitted utilization data. A list of the companies that have been allocated numbers in the 209 area code appears in Appendix A.
The remaining companies hold fourteen prefixes in the 209 area code. According to NeuStar, all four companies are out of business in California. Table 2-2 summarizes this information.
Company OCN Rate Center Prefix(es)
CCCCA, Inc. DBA Connect! 2559 Modesto 415, 451, 452, 452
CRL Network Services 4128 Modesto 701
CRL Network Services 4128 Merced 702
San Diego Paging 6480 Turlock 203
San Diego Paging 6480 Fresno 214
San Diego Paging 6480 Modesto 344
San Diego Paging 6480 Stockton 519
San Diego Paging 6480 Merced 705
TSR Wireless Services 6483 Tracy 561
TSR Wireless Services 6483 Lodi 562
TSR Wireless Services 6483 Modesto 717
D. NUMBERS AVAILABLE IN THE 209 AREA CODE
1. 5.61 Million Numbers Available
The 209 area code has 5.61 million unused numbers. Of these unused numbers, TD found that companies held 3.05 million numbers in their inventories.18 These numbers held in inventory are currently not used but held in anticipation of future need. The remaining 2.56 million unused numbers are not yet assigned to companies and are made available in the monthly lottery. The breakdown of available numbers is shown in the table below.
Summary of Available Numbers
Wireline Carriers 1,864,155
Wireless Carriers 1,014,654
Type 1 Carriers 172,488
Total Available Numbers Reported by Carriers 3,051,297
Numbers Available for the 209 Lottery 2,560,000
Total Available Numbers in the 209 Area Code 5,611,297
Not all of the 5.61 million unused numbers are immediately available to every company that wants numbers. Of the 5.61 million numbers, only 3.40 million numbers19 are estimated to be available to all companies via future pooling. The remaining 2.21 million unused numbers are only available to the companies who hold them. Pooling for the 209 area code has not as yet been scheduled. By setting up number pooling in the 209 area code and adopting recommendations in this report, 20 the CPUC could shift 1.14 million unused numbers to the category available to all companies. Of the 5.61 million unused numbers, those actions could result in making a maximum of 4.54 million numbers21 available to all companies with the remaining 1.07 million numbers available to the companies who hold them.
Current technology requires a company to be LNP-capable in order to donate numbers for another company to use. All wireline numbers in rate centers that are in the top 100 MSA's are required to be LNP-capable.22 Although number pooling has not started for the 209 area23, TD analyzed the 209 utilization data by percentage contamination to determine the availability of numbers that potentially can be used in a number pool. Wireline companies hold 1.86 million unused numbers in the 209 area code. In order for the unused numbers to be retrieved from company inventories, the FCC requires these unused numbers to be retrieved from blocks which are 10% or less contaminated.24 Of the wireline companies' 1.86 million unused numbers, 1.34 million are contained in 1,443 thousand-blocks held by LNP-capable carriers that are 10% or less contaminated. However, not all of these 1.34 million numbers can be retrieved from companies' inventories because companies need to have enough numbers to meet anticipated future need.25 Both the CPUC and the FCC have determined that six-months of inventory is a reasonable quantity to hold for future use.
The remaining 520,000 of the 1.86 million unused numbers cannot be retrieved, either because the numbers are in blocks greater than 10% contaminated or because they are in non LNP-capable blocks. However, companies can immediately use these numbers to provide service to their customers or meet other needs. Wireline carriers hold 433,000 numbers in blocks that are more than 10% contaminated.26 Non-LNP capable wireline carriers hold 90,000 of the 1.86 million unused numbers.
Wireless carriers hold 1.01 million unused numbers in the 209 area code. Of these unused numbers, 728,000 are in blocks that are 10% or less contaminated, while 287,000 numbers are in blocks greater than 10% contaminated. Until wireless carriers become LNP-capable in November 2002, none of these numbers may be reallocated to other companies. In the interim, wireless carriers may assign these numbers to their own customers.
E. ANALYSIS OF AVAILABLE NUMBERS
The CPUC requires each company participating in number pools to donate blocks that are 10% or less contaminated, excluding those retained for the six-month inventory.27
TD analyzed the 209 utilization data to determine the availability of numbers within blocks of different contamination levels to assess different contamination thresholds that could be employed in the number pool. The following table summarizes available numbers by contamination levels by rate center for wireline carriers.
Wireline Available Numbers by Block Contamination Level
Table 2-5 Continued
The first two numeric columns of Table 2-5 show the potential numbers available to the pooling trial, except for those numbers kept for companies' six-month inventory, under current rules. Available numbers in one rate center cannot be used in another rate center. Table 2-5 shows that three rate centers, other than Directory Assistance, have no available numbers that companies could donate to the pool. Fresno only has special use codes, Ripon has available numbers but only in blocks greater than 25% contaminated, and Kirkwood Meadows contains a prefix which is non-LNP capable.
The last three columns of Table 2-5 capture available numbers in blocks that are greater than 10% contaminated but no more than 25% contaminated. Under the current number pool rules, companies retain thousand-blocks that are more than 10% contaminated. Increasing the contamination rate threshold from 10% to 25% would potentially free up an additional 142,87528 numbers for use in the number pool. TD cautions that although Table 2-5 shows potential results from increasing allowable contamination levels, further analysis and input from the industry may be necessary to determine accurately the quantity of additional numbers that can be added to the pool while still leaving companies with a six-month inventory.
As shown by Table 2-5 and also shown graphically in Table B-3 of Appendix B, most rate centers have available numbers from blocks of differing contamination levels up to 25%. The tables show that if the contamination ceiling for pooling were increased from 10% to 25%, more unused numbers exist in most rate centers that potentially could be donated to the pool.
Recommendation from Block Contamination Analysis of Wireline Carriers
· The CPUC should petition the FCC to increase the contamination level for pooling to 25%. If the FCC grants the petition, the CPUC should increase the maximum contamination level of donated blocks from 10% to 25% for all LNP-capable carriers.
Under current FCC rules, cellular and PCS companies are exempt from number pooling until November 2002 when they must become LNP-capable. The FCC has indefinitely exempted paging companies from becoming LNP capable. Table 2-6 shows available numbers in blocks of differing contamination levels held by wireless carriers. Wireless carriers hold 728,000 available numbers in blocks that are 10% or less contaminated, as shown in the first two columns of Table 2-6. Wireless carriers also have 135,000 available numbers in blocks with contamination levels greater than 10% but less than or equal to 25% as indicated by the last three columns of Table 2-6. Of these 862,000 million unused numbers held by wireless carriers, TD estimates that 414,000 (48%) are held by paging companies. 29 TD staff is investigating whether there are methods to make some of these 414,000 unused numbers available to other carriers despite the FCC's exemption of paging companies from the LNP requirement.
Wireless Available Numbers by Block Contamination Level
Because the FCC has granted wireless carriers an extension of time to implement LNP, no wireless carriers serving the 209 area code are capable of implementing LNP. Thus, wireless carriers cannot participate in number pooling at this time, resulting in 862,000 unused numbers in blocks between 0% to 25% contaminated in the 209 area code.
Recommendations from Block Contamination Analysis for Wireless
· When cellular and PCS companies become LNP-capable in November 2002, the CPUC should direct those wireless carriers to donate to and participate in the pool.
· The CPUC should adopt a 25% contamination threshold for donated blocks from wireless carriers to the pool.
· The CPUC should meet with paging companies to explore options for their consolidating numbering resources in fewer rate centers, as well as other methods of reducing the number of stranded numbers held by paging companies.
3. Potential Block Contamination Abuses
When blocks are slightly more than 10% contaminated, those blocks cannot be donated to the pool under current rules. Viewing the utilization data suggests that companies have not generally followed practices of sequential numbering and filling blocks substantially before using new blocks. The CPUC's rules on sequential numbering and fill rate practices promulgated in Decision 00-07-052 are designed to prevent this problem from occurring. Fill rates mitigate contamination by requiring companies to use contaminated blocks up to 75% before they can receive additional blocks. Sequential numbering minimizes contamination by requiring companies to begin assignment in the next thousand-block only after a 75% fill rate has been attained in the prior block. Where companies possess significant available numbers in a given rate center, these two efficiency measures could prevent the opening of new blocks or prefixes.
Companies reported utilization data as of December 31, 2000. The sequential numbering and fill rates decision was issued in July 2000. Some of these practices of non-sequential numbering and not filling blocks substantially before using new blocks may have happened before the July 2000 decision. TD does not expect carriers to contaminate blocks unnessarily.
Recommendation for Block Contamination Issues Affecting All Companies
· The CPUC should monitor compliance with its fill rate and sequential numbering policies through future number utilization filings and audits.
· The CPUC should establish penalties for non-compliance with fill rate and sequential numbering policies adopted in Decision 00-07-052.30
4. Reclamation of Prefixes
Decision 00-07-052 directed companies to return prefixes that are held unused for more than six months. As shown in Appendix B-1, wireline carriers and wireless carriers hold 1,173,000 unused numbers and 468,000 unused numbers, respectively, in the 0% contaminated blocks. Of these 0% contaminated blocks, 240,000 numbers are in 24 whole prefixes, i.e. spare prefixes, while 1,401,000 numbers are scattered throughout many different prefixes. The following table shows the breakdown between wireless and wireline carriers.
Breakdown of Numbers in 0% Contaminated Blocks
Avail. Numbers Avail. Numbers Avail. Numbers
0% Contain Blocks Spare Prefixes Differing Prefixes
Wireline Carriers 1,173,000 150,000 1,023,000
Wireless Carriers 468,000 90,000 378,000
Total 1,641,000 240,000 1,401,000
As shown above, 240,000 numbers in 24 prefixes can possibly be reclaimed if not used within six months. However, as a result of the FCC's March 31, 2000 first NRO order, the NANPA no longer has sole authority to reclaim unused prefixes. The FCC granted authority to state regulatory commissions to investigate and determine whether code holders have activated prefixes within the allowed time frames, and directed the NANPA to abide by the state commission's determination to reclaim a prefix if the state commission is satisfied that the code holder has not activated the prefix within the time specified in the first NRO order. Substantial cooperation between the CPUC and the NANPA will be required in order for the CPUC to exercise this new authority and determine whether a prefix should be reclaimed. Furthermore, the NANPA must still perform the mechanical steps to reclaim prefixes once the CPUC directs the NANPA to reclaim a prefix.
NANPA has provided to the CPUC a list of companies which have failed to report whether their assigned prefix(es) have been placed in service. The CPUC issued Assigned Commissioner's Ruling Requiring Carriers to Comply With NXX Code Reclamation Rules, dated December 21, 2000. In this ruling, the CPUC instructed the delinquent companies to comply immediately. Companies are to inform the CPUC either that the prefix(es) have been placed in service or returned, that the company was incorrectly included in NANPA's delinquent list, or the reasons the prefix(es) have not been placed in service. The CPUC will review the reasons and make a determination on whether the prefix(es) must be returned or reclaimed by NANPA, or whether an extension of time is to be granted to the company to place the prefix(es) in service. Any delinquent companies that fails to comply will be subject to penalties and sanctions.
F. ANALYSIS OF 2.14 MILLION "UNAVAILABLE" NUMBERS
In the following sections, TD recommends a series of policies designed to require companies to use unavailable numbers more efficiently. These policies would potentially free more numbers for use in the pool, to be allocated through the monthly lottery, or to be otherwise used by companies.
Companies report that 2.14 million numbers in the 209 area code are either assigned to customers or are used by companies for reserved, administrative, intermediate and aging purposes. Assigned numbers are those numbers that are currently being used by customers or equipment. Companies commonly refer to these numbers as "unavailable". Unavailable numbers include not only those actually in use by customers, but also the following categories:
· Reserved numbers - Numbers that are reserved in blocks for future use by specific customers;
· Administrative numbers - Numbers that companies use for their own internal use;
· Intermediate numbers - Numbers that are made available for use by another telecommunications carrier or non-carrier entity for the purpose of providing telecommunications service to an end user or customer; and
· Aging numbers - Numbers from recently disconnected service which are not reassigned during a fixed interval.
In its first NRO Order, the FCC ruled that companies must show that they have used a certain percentage of their existing inventory of numbers before they may obtain additional numbers in a given rate center. This order specified that companies' utilization rates will be calculated using only assigned numbers in the numerator. This method greatly increases companies' incentive to use numbers sparingly for purposes of reserved, administrative, intermediate, or aging numbers; none of those uses will raise a company's utilization rate and enable it to obtain additional numbers.
1. 1.71 Million Assigned Numbers
In the 209 area code, there are 1.71 million assigned numbers with 1.18 million assigned to customers by wireline carriers and 0.53 million assigned to customers by wireless carriers. Analysis of the utilization data submitted by wireline carriers reveals sharply differing utilization rates of ILECs and CLECs. While ILECs in the 209 area code are using 49.9% of their numbers, CLECs' data shows a utilization rate of only 16.6%. Likewise, analysis of wireless carriers' data revels sharply differing utilization rates of paging carriers and cellular/PCS companies. While cellular/PCS carriers in the 209 area code are using 45.6% of their numbers, paging carriers' data shows a utilization rate of only 7.1%. The percentage of assigned numbers to total numbers held by companies is shown in the table below.
Utilization Rates by Carrier Type
Non-Working wireless describes numbers assigned to wireless customer equipment, but which are not yet working. In the present study, these numbers are considered a sub-category of assigned numbers31. For example, wireless carriers sometimes pre-package a cellular telephone with an assigned telephone number for sale to customers. Although the number is assigned, it will remain inactive until a customer purchases the telephone. There are no non-working wireless numbers reported for this area code. While the quantity of non-working wireless numbers reported is generally zero or very low, this sub-category of assigned numbers could increase because there are no restrictions on the number of days that a wireless company can hold these numbers, causing numbers to remain idle for an unspecified period.
The CPUC should consider several options to improve inventory management of non-working wireless numbers. One option is for the CPUC to require companies to return these numbers to the available category after 180 days (similar to the requirement the FCC has established for reserved numbers). Since pre-packaged equipment with non-working assigned numbers is often located in various retail outlets, another option is for the CPUC to require companies to maintain inventory records of all such retail/wholesale equipment with the associated numbers assigned and to require regular (weekly/monthly) updating of these inventory records. While TD thinks this is an area of potential abuse, the FCC's NRO Orders prohibit us from requiring regular reporting from carriers beyond their biannual NRUF reports. Audits by the CPUC may uncover or limit misuses of this category by carriers.
Recommendations for Treatment of Non-Working Wireless
· Non-working wireless numbers should be treated as reserved numbers and limited to 180 days, after which they should be classified as available for assignment to customers.
· The CPUC should continue to monitor non-working wireless numbers in the near term by reviewing future utilization filings, and should include this category of numbers in any audits conducted of wireless carrier number use.
Interim Number Portability (INP) is the ability to move telephone service from one service provider to another using Remote Call Forwarding (RCF), Direct Inward Dialing (DID), or equivalent means. 32 Prior to the implementation of permanent LNP, companies entered into INP arrangements to enable the transfer of customers from one company to another. Under these INP arrangements, two telephone numbers are associated with each customer. LNP eliminates the need for two telephone numbers for each customer when the customers change companies because customers can take their numbers with them.
Since the 209 area code has portions which are included in the top 100 MSAs in the nation, all wireline carriers should be LNP-capable in the 14 rate centers which are in the top 100 MSA's. Companies reported a total of 72 INP numbers in the 209 area code. TD questions why any INP numbers exist in this area code as the uses for INP have been replaced by LNP. Switching to LNP technology and eliminating INP will free up to half of the 72 INP numbers that are currently dedicated to INP.
Recommendations for INP-Related Conservation Measures
· The CPUC should adopt a schedule for transitioning INP arrangements to LNP in all California area codes.
Historically, the telecommunications industry has designated certain prefixes for special uses, usually to an ILEC. These include numbers for recorded public information announcements such as time-of-day, weather forecasts, high-volume call in numbers, and emergency preparedness33 numbers. These prefixes are not made available for general commercial use, and thus numbers within these prefixes that are not in actual use lie vacant. In 1999, companies decided not to duplicate the special use prefixes in each area code. Concerned that this process could adversely affect the public, the CPUC directed that these prefixes should be duplicated in each new area code.
The utilization study shows that 8 prefixes are dedicated for special uses: one each for directory assistance, time, emergency preparedness, 700 IntraLATA Presubscription, limited service and information provider service and three for high volume calling34. TD questions the necessity of assigning an entire prefix for each of the purposes listed above.
Furthermore, having multiple special use prefixes is an inefficient use of numbers in the 209 area code as well as in other area codes in California. For example, if the 555 prefix35 currently reserved only for directory assistance could be used to provide time and emergency preparedness then two more prefixes could be returned for reallocation in the 209 area code.
Similarly, expanded use of the 555 prefix throughout the state could result in more returned prefixes in other area codes. TD recommends that the CPUC initiate an investigation into broader use of the 555 prefix in California. The CPUC should further analyze the option of obtaining standard 555 numbers in every California area code to provide time, emergency preparedness, and weather information at no additional cost to customers.
Recommendations for Special-Use Prefixes
· TD recommends that the CPUC initiate an investigation into the possibility of moving the numbers for time and emergency preparedness into the 555 prefix.
· TD recommends that the CPUC include in its investigation the broader use of the 555 prefix in California's area codes by providing standard 555 numbers in every California area code to provide time, emergency preparedness, and weather information.
Carriers "set aside" numbers for future use by customers.36 Previously, industry number assignment guidelines allowed companies to reserve a prefix for up to 18 months for customers' future use.37 The FCC's first NRO Order modified the number reservation period to 45 days. This 209 utilization study incorporated the FCC's 45-day requirement. The second NRO Order on Reconsideration changed the number reservation period to 180 days. This took effect on December 29, 2000.38
Companies reported a total of 92,000 reserved numbers in the 209 utilization study. 39 Wireline carriers reported a total of 72,000 reserved numbers in the 209 area code, which constitute 2% of wireline's numbers. Wireless carriers reported about 20,000 reserved numbers in the 209 area code, which constitute 1.2% of wireless carriers' numbers. As stated in Section D above, under the utilization rules promulgated in the FCC's First and Second NRO Orders, carriers now have a much stonger incentive to minimize the quantity of numbers they reserve for future use by customers, thus freeing more numbers for immediate assignment to customers, or for donation to the number pool.
Recommendations for Reserved Numbers
· The CPUC should monitor reserved number use for all companies by reviewing future utilization data to ensure companies are complying with the FCC's 180-day requirement.
3. Administrative Numbers are a Potential Source of Additional Numbers
Administrative numbers are those not assigned to customers and are generally used for a wide range of applications for companies' internal use, including testing, internal business, and other network purposes. Companies reported over 86,00040 administrative numbers in the 209 area code. Wireline carriers hold approximately 64,000 of these numbers and wireless carriers hold approximately 22,000 of them. These quantities of administrative numbers represent 1.8% of wireline carrier's total numbers and 1.3% of wireless carrier's total numbers.
The utilization study revealed that companies exhibit a wide range of rates of administrative number usage. Given the variances in the levels of administrative numbers between companies and rate centers, it is unclear what basis companies use for placing numbers in this category. The CPUC should therefore pursue an investigation in this area.
Companies could conserve numbers by centralizing assignment of administrative numbers within one or a few blocks within one prefix. However, some companies randomly assigned administrative numbers in multiple thousand-blocks within the same prefix. Because of this practice, companies already have contaminated multiple thousand-blocks; thus, preventing them from donating blocks once they can participate in number pooling or other LNP-based conservation measures.
Also, some companies holding multiple prefixes in a given rate center randomly assign administrative numbers throughout different prefixes when they have the available number resources to centralize the assignment of these numbers in one prefix in that rate center. TD questions the need for companies to hold multiple prefixes in a given rate center, when they are using multiple prefixes to serve their internal purposes and not necessarily to serve customer needs.
4. Aging Numbers
The FCC's first NRO Order defines aging numbers as disconnected numbers that are not available for assignment to another customer for a specified period of time. Consistent with the Industry Numbering Committee (INC) Guidelines, the CPUC adopted the FCC upper limits for aging numbers as 90 days for residential numbers and 365 days41 for business numbers.
In the 209 area code, there are approximately 90,800 numbers in the aging category, representing 3.9% of the total unavailable numbers. While most companies track aging telephone numbers by business and residential categories, Pacific Bell, the largest single number holder in the 209 area code, does not differentiate and reported all its aging numbers in the "Residential" category for this phase of the area code studies. Therefore, the vast majority of the aging numbers in the residential category may give a false impression that most aging numbers are residential numbers.
Because Pacific Bell does not differentiate between residential and business in reporting aging numbers, it is uncertain whether Pacific is adhering to the maximum 90-day aging period for residential numbers, and whether, at the end of the 90-day period, Pacific is reassigning these numbers to the "available" category. Pacific Bell may be allowing residential numbers to be in the aging category for nine months longer than is permissible under both FCC and CPUC rules. The FCC's NRO Orders do not require carriers to report their aging numbers broken down into residential and business categories. Since Pacific has not voluntarily provided this breakdown as requested in its data submissions for the CPUC's number utilization studies, TD staff should focus particular attention on the issue of Pacific's adherence to FCC and CPUC time limits on numbers in the again category whenever it audits numbering data.
A higher percentage of aging numbers occurs in the wireless category, as compared to the wireline category. Aging numbers represent 5.6% of the total unavailable wireless numbers, or about 36,600 numbers. Aging numbers represent 3.30% of the total unavailable wireline numbers, or about 54,250 numbers. This is consistent with the higher turnover or "churn" that occurs in the wireless industry. Appendix G shows the breakdown of aging numbers by wireless and wireline categories.
Recommendation for Aging Numbers
· Although the CPUC has required all companies to differentiate aging numbers between residential and business and track the two categories separately, Pacific Bell has not complied with these requirements. TD staff should check Pacific's adherence to FCC and CPUC time limits on numbers in the again category when it audits numbering data.
5. Intermediate Numbers
Recommendation for Intermediate Numbers
· The CPUC should monitor intermediate number use for all companies by reviewing future utilization filings to test whether potential abuses in this reporting category occur.
Wireline carriers allocate numbers for use by wireless carriers through Type 1 interconnection agreements.43 Because wireline and wireless carriers share responsibility for Type 1 numbers, both types of companies reported on these numbers. Wireline carriers report Type 1 numbers in the Intermediate category since they provide these numbers to another company. Wireline carriers also list the wireless carriers to whom they distributed ranges of numbers. Wireless carriers report on the numbers they received, placing them in the Assigned, Administrative, Reserved, Intermediate, Aging, or Available categories.
Record keeping of Type 1 numbers is inadequate because, more often than not, wireline carriers' reports disagreed with wireless Type 1 carriers' reports. In the 209 area code, over half of all Type 1 numbers are unaccounted for or mismatched.44 In some cases, wireless Type 1 carriers deny "owning" the numbers that wireline carriers report as distributed. In other cases, wireless Type 1 carriers go out of business and do not return their numbers to the wireline carrier. In either case, numbers are lying dormant, used by neither the wireline or wireless Type 1 carrier.
In today's scarce numbering environment, it is unacceptable to let numbers go unused because of inadequate record keeping. Wireline donor carriers currently do not monitor wireless Type 1 inventories, nor do they proactively reclaim unused Type 1 numbers from wireless carriers. TD recommends that wireline carriers perform a one-time inventory check on Type 1 numbers to confirm that the numbers they have distributed are acknowledged by the recipient wireless Type 1 carrier. If errors are discovered, the wireline carriers should count the numbers as part of their own inventories.
Improved Type 1 number management is particularly crucial because unlike numbers held by most wireless carriers, Type 1 numbers are eligible for number pooling.45 Therefore, once wireline carriers recover unused Type 1 numbers, these numbers could be made available for pooling. Despite the problems with reporting, TD has identified 16 blocks of Type 1 numbers in the 209 area code that may be eligible for donation to the pool.46 The CPUC should recognize Type 1 numbers as a resource for number pooling and take steps to have wireline companies recover unused Type 1 numbers for donation to the number pool.
As described in Chapter 1, state and federal mandates require most companies to demonstrate efficient numbering practices before becoming eligible to obtain more numbers. In contrast, Type 1 wireless carriers have no check on their number use because they draw numbers directly from wireline companies, therefore avoiding the scrutiny of the official number administrator. TD recommends that Type 1 wireless carriers be subject to number conservation measures, and the CPUC should develop a system to ensure compliance.
Recommendations for Type 1 numbers:
· Wireline and wireless carriers should improve Type 1 number inventory management. Wireline carriers should perform a one-time inventory check of wireless Type 1 numbers to verify their records match the wireless Type 1 carriers' records. Companies should make inventory data available to the CPUC upon request. Wireline carriers should recover and add to their inventories any Type 1 numbers lying dormant.
· Type 1 carriers should be subject to number conservation techniques such as sequential numbering and fill rates. A system to ensure compliance with Type 1 number conservation measures should be developed.
· The Commission should consider Type 1 numbers as potential donations to the number pool. Excess and unused Type 1 numbers should be returned to the wireline carriers and either used to serve customers or donated to the number pool.
The data analyzed in this utilization study was self-reported by companies. Given the area code crisis in California, the CPUC should audit the data for two reasons. First, verifying number usage data is important to ensure that the public resource of telephone numbers is efficiently managed. Second, audits will help verify whether companies are complying with CPUC and FCC rules for number usage.
Recommendation for Audit
· The CPUC should audit the data submitted by companies in this study and future area code number utilization studies.
Many of the recommendations in Chapter Two resulted directly from the analysis of the utilization data and address actions that the CPUC should undertake to make additional numbers available for either pooling or for the regular monthly lottery. The recommendations contained in this chapter suggest additional conservation measures as required by Public Utilities Code Section 7935(a). The CPUC could adopt the following conservation measures in the 209 area code and statewide: LNP-related actions, Unassigned Number Porting, Rate Center Consolidation, and prefix sharing. When applied, these conservation measures would result in uniform policies which will cause companies to use numbers more efficiently across California and would minimize customer confusion.
H. NUMBER POOLING
Number pooling is an excellent method of number conservation. The CPUC worked aggressively to bring number pooling to California and the results have been dramatic. Pools are underway in ten area codes and four additional pools are scheduled to begin in 2001.
Number pooling has avoided the need to open prefixes and therefore has extended the life of area codes. Prior to pooling, 432 prefixes would have been opened in the 310, 408, 415, 650, 714, 818 and 909 area codes.47 In addition, the pool has satisfied the numbering needs of all companies participating in the pool almost entirely with donated blocks.48
Pooling benefits not only the public but the companies as well by reducing the time necessary to acquire numbering resources. Without pooling, activating new numbers takes at least 66 days.49 With number pooling, activating new numbers can be accomplished in three weeks.
1. More Accurate Forecasting Will Improve Number Pooling
So far in California, number pooling has worked well because companies have met their numbering needs from the excess numbers other companies donate to the pool. The CPUC has set aside prefixes in each area code that will be used to replenish the pools if and when donations are no longer sufficient. There are a limited number of set aside prefixes, so it is crucial that these prefixes be opened only when there is truly a need.
If donated numbers are not sufficient to meet the companies' forecasts, a new prefix may need to be opened. Industry guidelines suggest replenishing a pool at least 66 days in advance when the forecast shows a company will need more numbers than the pool has on hand. This presents a problem, as companies in California have been, on average, forecasting nearly six times more numbers than they will take from the pool. Had the pool administrator opened prefixes based on the forecast, the prefixes would lie unused in the rate center.50
The CPUC has thus far prevented prefixes from being unnecessarily opened by ordering the Pooling Administrator (PA) to consult with TD prior to opening any prefix. However, the CPUC believes this issue should be addressed for the long term. Industry guidelines encourage companies to over-forecast, because a company can only be assured numbers for which it forecasts.51 In essence, a company could be penalized for under-forecasting. Since there is no penalty for over-forecasting, it is in companies' interests to err on the side of over-forecasting. TD recommends the CPUC develop specific rules guiding company forecasting. TD also recommends that the PA take historical usage into account when determining when to open a fresh prefix of 10,000 numbers.
Recommendations for Number Pooling
· The CPUC should work with industry groups and the Pooling Administrator to develop specific rules for companies pertaining to forecasting a six-month inventory when a number pool is authorized in a particular area code.
I. LACK OF LOCAL NUMBER PORTABILITY STANDS AS A KEY BARRIER TO POOLING
Full LNP deployment in the 209 area code is critical to effective number conservation. As described in Chapter 1, LNP enables customers to keep their telephone numbers when they switch companies. Because the number remains with the customer and can be transferred to different companies, there is no need to distribute duplicate numbering resources to both companies. Also, LNP is the technology platform that makes number pooling possible.
In an order released in 1997, the FCC ordered all wireline carriers in the top 100 MSAs to become LNP capable by December 1998.52 The 209 area code falls partially within one of the top 100 MSAs. The study revealed that all but one wireline carrier in the 209 area code is LNP capable. This company holds 81,000 numbers that could be made available for number pooling if they implemented LNP technology.53 On July 26, 2001, the CPUC gave noncompliant carriers an incentive to implement LNP capability by allowing them to receive numbering resources only through the number pool, once a number pool has been established in the are code.54
Wireless carriers, however, requested and received from the FCC an extension of time, until November 2002, to become LNP capable.55 The CPUC filed comments with the FCC arguing that wireless carriers should be required to participate in pooling immediately upon becoming LNP capable. 56 In the Second NRO Report and Order, the FCC agreed with the CPUC and will require wireless carriers to participate in pooling immediately upon becoming LNP capable. Wireless carriers hold 167prefixes in the 209 area code, of which 739 blocks could be made available for pooling if they were required to participate in the pool.
As noted earlier, federal LNP requirements are directed at companies in the country's top 100 MSAs. But roughly forty percent of the area codes in California fall partially or completely outside of these MSAs. These area codes are facing similar numbering crises, and LNP is not ordered. Without full activation of LNP throughout California, the CPUC is effectively prevented from operating number pools in large portions of the area codes in the state. California has a pending petition at the FCC to extend LNP deployment statewide. The CPUC should urge the FCC to act on the petition for authority to order LNP capability statewide.
Recommendations for LNP
· The CPUC should continue to work with the FCC to enforce LNP capability mandates for all wireline carriers in the top 100 MSAs.
J. UNASSIGNED NUMBER PORTING
Unassigned Number Porting (UNP) is the term used to describe the transfer of unused numbers from one company to another. Like number pooling and the porting of assigned numbers from company to company, UNP is made possible by deployment of LNP. The primary benefit of UNP would be increased access to unused numbers stranded in carrier inventories. UNP would also strengthen competitively neutral access to public numbering resources by enabling companies with smaller inventories to access the inventories of companies with larger number holdings.
UNP would allow companies to transfer small increments of numbers between themselves. Various proposals have suggested limiting the increments to 25 or 100 numbers.57 Two efficiencies would be gained: 1) companies with smaller scale needs would be able to receive numbers in increments appropriate to meet their needs, and 2) unused numbers stranded in company inventories would be transferred to companies where they could be put to use.
Currently, companies receive unused numbers from the NANPA or the PA in increments of 10,000 numbers (prefixes) or 1,000 numbers (blocks). In areas without number pooling, prefixes held in company inventories that are not put to use within six months must be returned, but only if uncontaminated. If just one number has been used, the remaining 9,999 are stranded in the company inventory. In areas with number pooling, blocks are eligible for return only if 10% or less contaminated. For example, if a company receives 1000 numbers and only has need for 100 numbers, the remaining 900 numbers are eligible for return. However, if a company received 1000 numbers and only has need for 101 numbers, the remaining 899 numbers are ineligible for return and are stranded in the company inventory. UNP is one way to address the problem of stranded numbers.
The FCC has contemplated UNP but has so far declined to act.58 The FCC has not ruled out UNP as a conservation measure.59 In the absence of a voluntary company agreement to implement UNP, however, the CPUC could only implement UNP with FCC approval. Given the number conservation benefits to be had, the CPUC should petition the FCC for authority to undertake a UNP trial.
Recommendations for UNP
· The CPUC should petition the FCC for authority to implement UNP statewide.
· The CPUC should solicit comments in order to develop rules and practices necessary to implement UNP.
K. CONSOLIDATION OF RATE CENTERS TO MAXIMIZE NUMBER USE
Rate Center Consolidation (RCC) is a potential number conservation tool because it allows companies to use numbers over a larger geographic area, thus slowing the rate at which prefixes are used. Rate center location dictates both the scope of a customer's local calling area and the charges assessed per toll call. In California, each rate center governs a relatively small, uniform local calling area, measured from the rate center of each exchange. Because the local calling areas in California are small compared to those in many other states, it is virtually impossible to migrate to larger calling areas via consolidation of rate centers without eliminating at least some toll call routes.
Eliminating toll routes would have the residual effect of reducing revenues for toll service providers, which include both local exchange carriers and interexchange carriers. The two major ILECs in California, Pacific Bell and Verizon (formerly GTE California), have expressed at industry meetings their belief that they should be "made whole" for any loss of toll revenues that likely would result from consolidating rate centers. An industry task force which the CPUC charged with developing a proposal for rate center consolidation reported to the CPUC in March 1999 that it would offer no such plan until the CPUC addresses revenue and consumer impact issues. However, it is difficult, if not impossible for the CPUC to address consumer and revenue impacts if the CPUC has no plan before it for consolidating rate centers, which would provide the context and details for assessing such impacts.
California has roughly 750 rate centers, each of which is the approximate center of a 12-mile local calling area. With no input from the industry, the CPUC cannot begin to guess what approach would be most appropriate. For example, California could consolidate from 750 rate centers to 400, or to 200. Each of those possibilities would present different rate "impacts" for both companies and customers. Alternatively, rather than attempting to consolidate rate centers on a statewide basis, the CPUC could consider consolidating rate centers on an area code-by-area code basis. All rate centers in one area code, for example, could be consolidated into one rate center. This would eliminate both the uniform statewide local calling area of 12 miles and uniform statewide rates for each company, thus generating some amount of customer confusion as individuals travel throughout the state for business or social purposes, or relocate their home or business. Further, because companies would lose toll revenues when rate centers are consolidated and local calling areas expanded, the CPUC would need to address the question of which, if any, companies should be allowed to recover those lost revenues, and if so, how.60
Finally, rate center consolidation will mean direct, substantial, and permanent basic rate increases for many customers, unless the ILECs forgo their claim that RCC should be revenue neutral. Economics and Technology, a Boston consulting group, has projected that ".....rate center consolidation in California could result in a per-access-line increase of $5.56 in basic monthly rates for California ILEC customers."61
This may not be an acceptable option, even though California presently has among the lowest local exchange rates in the country. And, if the ILECs continue to press for revenue neutrality, the very process of determining the amount of those revenues, as well as how those monies should be recovered and from what class(es) of customers, would constitute a rate-design proceeding of significant scale and scope. Such a proceeding could consume a tremendous amount of CPUC, industry, and consumer representative resources, and take one to two years.62
Nonetheless, because RCC offers the potential for conserving significant quantities of numbers in California, TD recommends that the CPUC renew its efforts to determine how RCC could be implemented in California. The industry should be directed to posit several different scenarios, if they cannot agree on one proposal.
Recommendations for Rate Center Consolidation
· The CPUC should undertake further investigation by ordering the telecommunications industry to develop a plan, within 180 days, for rate center consolidation.
L. SHARING PREFIXES MAY YIELD MORE EFFICIENT NUMBER USE
In analyzing previous utilization data in the 310 area code, TD became aware that two non-affiliated companies were sharing prefixes under an informal arrangement. Using LNP technology, a company with excess numbers had transferred whole thousand blocks of numbers to the other company for use. TD believes this sharing arrangement promotes efficient number use among companies.
Some companies reporting utilization data in the 209 area code are affiliated through mergers, acquisitions or other business relationships. Despite these affiliations, each company separately requests numbers from the NANPA.63 TD notes that the benefits of sharing prefixes may be different in area codes in which number pooling has already been implemented versus those that number pooling has not been implemented. Sharing prefixes between companies appears worthy of further investigation by the CPUC as a mechanism to promote more efficient use of numbers.
Recommendations for Sharing of Prefixes
· The CPUC should further explore sharing of prefixes as a means to more efficiently utilize numbers in all area codes.
Analyzing the utilization data provided by carriers has provided useful information regarding number availability and usage practices in the 209 area code. It also has offered insights into developing better public policies to improve efficiency of number use.
We now know that, of the approximately 7.75 million usable numbers in the 209 area code, approximately 5.61 million, or roughly seventy-two percent, presently are not in use. Despite the increasing demand for numbers, the 209 area code is not fully utilized. The data indicates that there is considerable room for growth within the existing 209 area code, and it is premature to consider splitting or overlaying the 209 area code at this time.
The CPUC already has directed carriers to employ measures to use the numbering resources in 209 more efficiently. Recently adopted fill rates and sequential numbering rules will ensure that carriers use their existing resources more fully and receive additional numbers only on an as-needed basis. To date, the CPUC has only established number pools in area codes that are completely in the top 100 MSA's. The 209 area code has portions within the top 100 MSA's, but not completely. Fourteen rate centers out of sixty-two are located in a top 100 MSA. If pooling were implemented in all of 209, allocating numbers in thousand-block increments rather than in full prefixes of 10,000 numbers would ensure that the numbering resources are used more efficiently, and can greatly extend the life of the existing area code. Implementing these more efficient numbering practices is an important first step, but more needs to be done.
In analyzing the carrier data, it is now clear that because of 1) past inefficiencies in numbering policies and practices, 2) the 10% contamination ceiling for block donations to pooling, and 3) the deferral of LNP capability for wireless carriers, 2.21 million numbers are not in use in 209 but cannot be reassigned to other carriers. Changes in contamination thresholds and requiring LNP capability for all carriers could make about 1.14 million of these stranded numbers available for reassignment.
The CPUC should continue its collaborative process with the FCC and the telecommunications industry to implement Unassigned Number Porting, the development of non-geographic-specific area codes, and other measures that will more fully utilize numbers. The CPUC should begin implementation of the many number conservation and management practices found in the Recommendations section of this report. As a public resource, it is important that our numbering supplies are used as efficiently and effectively as possible.
DEFINITIONS FOR UTILIZATION STUDY
Administrative: Administrative numbers are numbers used by telecommunications carriers to perform internal administrative or operational functions necessary to maintain reasonable quality of service standards. Subcategories used in the Utilization Studies are:
Internal Business Purpose/Official Numbers: A number assigned by a service provider for its own internal business purposes
· Test Numbers: Telephone numbers (TNs) assigned for inter-and intra-network testing purposes
· Other Administrative Numbers (include only Location Routing Number, Temporary Local Directory Number and Wireless E911 ESRD/ESRK) where
· Identical to a Local Routing Number (LRN): The ten-digit (NPA-XXX-XXXX) number assigned to a switch/point of interconnection (POI) used for routing in a permanent local number portability environment
· Temporary Local Directory Number (TLDN): A number dynamically assigned on a per call basis by the serving wireless service provider to a roaming subscriber for the purpose of incoming call setup
· Wireless E-911 ESRD/ESRK: A ten-digit number used for the purpose of routing an E911 call to the appropriate Public Service Answering Point (PSAP) when that call is originating from wireless equipment. The ESRD identifies the cell site and sector of the call origination in a wireless call scenario. The Emergency Services Routing Key (ESRK) uniquely identifies the call in a given cell site/sector and correlates data that is provided to a PSAP by different paths, such as the voice path and the Automatic Location Identification (ALI) data path. Both the ESRD and ESRK define a route to the proper PSAP. The ESRK alone, or the ESRD and/or Mobile Identification Number (MIN), is signaled to the PSAP where it can be used to retrieve from the ALI database, the mobile caller's call-back number, position and the emergency service agencies (e.g., police, fire, medical, etc.) associated with the caller's location. If a NANP telephone number is used as an ESRD or ESRK, this number cannot be assigned to a customer.
For convenience, "other administrative numbers" are reported as a group for purposes of the Utilization Study
Aging Numbers: Aging numbers are disconnected numbers that are not available for assignment to another end user or customer for a specified period of time. Numbers previously assigned to residential customers may be aged for no more than 90 days. Numbers previously assigned to business customers may be aged for no more than 360 days. For purposes of the Utilization Study, carriers are to separately report aging numbers associated with residential service from those associated with business service.
Assigned Numbers: Assigned numbers are numbers working in the Public Switched Telephone Network under an agreement such as a contract or tariff at the request of specific end users or customers for their use, or numbers not yet working but having a customer service order pending. Numbers that are not yet working and have a service order pending for more than five days shall not be classified as assigned numbers. For purposes of the Utilization Studies, numbers for non-working wireless and for interim number portability are to be considered as assigned numbers in Part 1-Section A and separately identified in Part 2. See Interim Number Portability and Non-Working Wireless for definitions.
Available Numbers: Available numbers are numbers that are available for assignment to subscriber access lines, or their equivalents, within a switching entity or point of interconnection and are not classified as assigned, intermediate, administrative, aging, or reserved.
COC Type: Three-digit element defining the use of the Central Office Code (codes such as 0XX used for access tandem and testboard addressing or a "+" symbol that indicates direct routing to the designated switch in the NPA. 2XX-9XX values are considered NXXs.) Allowable codes in the LERG Destination Code by LATA and Tandem Homing Arrangements (LERG 6/9) are:
ATC = Access Tandem Code (0/1XX)
CDA = Customer Directory Assistance only (555 line numbers are assigned by
the North American Numbering Plan Administration)
EOC = End Office Code
PLN = Planned Code - non-routable
PMC = Public Mobile Carrier (Type 2 Interconnected)
RCC = Radio Common Carrier (Dedicated Type 1 Interconnected)
SIC = Special 800 Service Code
SP1 = Service Provider - Miscellaneous Service (Type 1 Interconnected)
SP2 = Service Provider - Miscellaneous Service (Type 2 Interconnected)
TST = Standard Plant Test Code
Allowable codes in the LERG Oddball file (LERG6ODD only) are:
700 = 700 IntraLATA Presubscription
AIN = Advanced Intelligent Network
BLG = Billing Only
BRD = Broadband
CTV = Cable Television
ENP = Emergency Preparedness
FGB = Feature Group B Access
HVL = High Volume
INP = Information Provider
LTC = Local Test Code
N11 = N11 Code
ONA = Open Network Architecture
PRO = Protected
RSV = Reserved
RTG = Routing Only
UFA = Unavailable for Assignment
Interim Number Portability (INP): The interim ability to move telephone service from one service provider to another service provider using Remote Call Forwarding (RCF), Direct Inward Dialing (DID), or equivalent means where:
· Remote Call Forwarding allows a customer to have a local telephone number in a distant location. Every time someone calls that number, that call is forwarded to the RCF customer in the distant location. Remote call forwarding is similar to call forwarding on a residential line, except that the RCF customer has no phone, no office and no physical presence in that location.
· A DID (Direct Inward Dial) trunk is a trunk from the Central office which passes the last two to four digits of the Listed Directory Number into the PBX, thus allowing the PBX to switch the call to and thus ring the correct extension" without the use of an attendant (Newton's Telecom Dictionary). Existing DID retail service is limited to PBX services. For purposes of providing INP, Pacific and GTEC will use the DID switch functionality to provide INP to any CLC customer regardless of the type of terminal equipment used on the customers' premises.
· For the purposes of the Utilization Study, each carrier must report the quantity of its assigned numbers that are dedicated to providing INP under Assigned Numbers in Part 1-Section A and separately identified in Part 2.
Intermediate Numbers: Intermediate numbers are numbers that are made available for use by another telecommunications carrier or non-carrier entity for the purpose of providing telecommunications service to an end user or customer. Numbers ported for the purpose of transferring an established customer's service to another service provider shall not be classified as intermediate numbers. For Type 1 donor carriers, Type 1 numbers are to be reported as intermediate numbers in Part 1-Section A and detailed information is to be provided in Part 2 for the Utilization Studies. For Type 1 recipient donors, Type 1 numbers shall be reported in the Part 1-Section B for the Utilization Studies. For definition, see Type 1 numbers.
Local Number Portability: The ability to move a telephone number from one service provider to another service provider using LRN-LNP technology
Non-Working Wireless: this category is for wireless companies only to report numbers that they have already assigned to customer equipment, but are not yet working. For example, cellular carriers often pre-package a cellular telephone with an assigned telephone number for sale to customers. Those phone numbers are assigned, but are not actually activated until after the customer purchase is made. For the purposes of the Utilization Study, each carrier must report the quantity of its non-working wireless numbers under Assigned Numbers in Part 1-Section A and separately identified in Part 2.
OCN: Operating Company Number (OCN) assignments must uniquely identify the applicant. Relative to CO Code assignments, NECA-assigned Company Codes may be used as OCN's. Companies with no prior CO Code or Company Code assignments should contact NECA (973-884-8355) to be assigned a Company Code(s). Since multiple OCNs and/or Company codes may be associated with a given company, companies with prior assignments should direct questions regarding appropriate OCN usage to the Traffic Routing Administration (TRA) on 732-699-6700
Reserved Numbers: Reserved numbers are numbers that are held by service providers at the request of specific end users or customers for their future use. Numbers held for specific end users or customers for more than 45 days shall not be classified as reserved numbers.
Special Use NXX Codes: Certain NXX codes have traditionally been reserved or designated for special uses, and have not been available for assignment by carriers for general commercial use in providing telephone numbers to customers. These NXX prefixes are restricted to such special uses as recorded public information announcements of time-of-day and weather forecasts, high-volume call-in numbers, and emergency access numbers used by the Federal Emergency Management Administration (FEMA), etc.
Type 1 Numbers: numbers pursuant to a Type 1 interconnection agreement. The Type 1 interconnection is a connection between a mobile/wireless service provider and an end office of another service provider for the purpose of originating and terminating traffic or for access to end user services (i.e. DA, Operator services, 911, etc). The interconnection consists of a facility between the mobile/wireless service provider and the end office, switch usage, and telephone numbers (only required if the mobile carrier wishes to receive originating (L/M) traffic). For the purposes of this Utilization Study, both mobile/wireless service providers who have received Type 1 numbers and those service providers who have provided Type 1 numbers to mobile/wireless service providers are asked to report on those numbers at the 1000 block level.
Prefix Holders in the 209 Area Code
CALAVERAS TEL CO
CONTINENTAL TEL CO OF CALIFORNIA, INC. (VERIZON)
EVANS TEL CO
HORNITOS TEL CO
SIERRA TEL CO
CITIZENS TELECOMM CO OF TUOLUMNE.
CCCCA, INC DBA CONNECT! - CA
CRL NETWORK SERVICES, INC.
O1 COMMUNICATIONS, INC.
ARRIVAL COMMUNICATIONS, INC. - CA
AIRTOUCH CELLULAR - CA (VERIZON)
AIRTOUCH PAGING - CALIFORNIA (VERIZON MESSAGING)
MESSAGE CENTERS BEEPERS
SAN DIEGO PAGING
TSR WIRELESS LLC
GTE MOBILNET OF CENTRAL CALIFORNIA
MAP MOBILE COMMUNICATIONS, INC.
PACIFIC BELL WIRELESS
GOLDEN STATE CELLULAR
NETWORK SERVICES LLC
COOK TELECOM, INC.
VIA WIRELESS LLC
BROOKS FIBER COMMUNICATIONS - CA
TELEPORT COMMUNICATIONS GROUP-SAN FRANCISCO
ICG TELECOM GROUP - CA
PAC-WEST TELECOMM, INC.
MEDIAONE TELECOMMUNICATIONS OF CALIFORNIA, INC.
SUMMARY OF RECOMMENDATIONS
The Following Contains A Comprehensive List of Recommendations Contained In This Report:
Recommendation from Block Contamination Analysis of Wireline Carriers
· The CPUC should petition the FCC to increase the contamination level for pooling to 25%. If the FCC grants the petition, the CPUC should increase the maximum contamination level of donated blocks from 10% to 25% for all LNP capable carriers.
Recommendations from Block Contamination Analysis for Wireless Carriers
· When cellular and PCS companies become LNP capable in November 2002, the CPUC should direct those wireless carriers to donate to and participate in the pool.
· The CPUC should adopt a 25% contamination threshold for donated blocks from wireless carriers to the pool.
· The CPUC should meet with paging companies to explore options for their consolidating numbering resources in fewer rate centers, as well as other methods of reducing the number of stranded numbers held by paging companies.
· If deemed feasible, the CPUC should petition the FCC to rescind the paging companies' permanent exemption on becoming LNP capable.
Recommendation for Block Contamination Issues Affecting All Companies
_ The CPUC should monitor compliance with its fill rate and sequential numbering policies through future number utilization filings and audits.
_ The CPUC should establish penalties for non-compliance with fill rate and sequential numbering policies adopted in Decision 00-07-052.64
Recommendations For Treatment of Non-Working Wireless
_ Non-Working wireless numbers should be treated as reserved numbers and limited to 180 days, after which they should be classified as available for assignment to customers.
_ The CPUC should continue to monitor non-working wireless numbers in the near term by reviewing future utilization filings and include this category of numbers in any audits conducted of wireless carrier number use.
Recommendation for INP-Related Conservation Measures
_ The CPUC should adopt a schedule for transitioning INP arrangements to LNP in all California area codes.
Recommendations for Special-Use Prefixes
_ TD recommends that the CPUC initiate an investigation into the possibility of moving the numbers for time and emergency preparedness into the 555 prefix.
_ TD recommends that CPUC include in its investigation the broader use of the 555 prefix in California's area codes by providing standard 555 numbers in every California area code to provide time, emergency preparedness, and weather information.
Recommendations for Reserved Numbers
_ The CPUC should monitor reserved number use for all companies by reviewing future utilization data to ensure companies are complying with the FCC's 180-day requirement.
_ The CPUC should adopt efficient number use practices specific to companies' reserved number holdings. In developing these practices, the CPUC should investigate various alternatives including, but not limited to, 1) limits on the quantity or percentage of reserved numbers companies can hold, and 2) requirements for using reserved numbers prior to requesting new numbers.
Recommendations for Intermediate Numbers
_ The CPUC should monitor intermediate number use for all companies by interviewing future utilization filings to test whether potential abuses in this reporting category occur.
Recommendations for Type 1 numbers
_ Wireline and wireless carriers should improve Type 1 number inventory management. Wireline carriers should perform an annual inventory check of wireless Type 1 numbers to verify their records match the wireless Type 1 carriers' records. Companies should make inventory data available to the CPUC upon request. Wireline companies should recover and add to their inventories any Type 1 numbers lying dormant.
_ Type 1 carriers should be subject to number conservation techniques such as sequential numbering and fill rates. A system to ensure compliance with Type 1 number conservation measures should be developed.
_ The CPUC should consider Type 1 numbers as potential donations to the number pool. Excess and unused Type 1 numbers should be returned to the wireline carriers and either used to serve customers or donated to the number pool.
Recommendation for Aging Numbers
_ Although the CPUC has required all companies to differentiate between residential and business numbers in aging and track the two categories separately, Pacific Bell has not complied with these requirements. TD staff should check Pacific's adherence to FCC and CPUC time limits on numbers in the again category when it audits numbering data.
Recommendations for Audits
_ The CPUC should audit the data submitted by companies in this study and future area code utilization studies.
Recommendations for Number Pooling
_ The CPUC should work with industry groups and the Pooling Administrator to develop specific rules for companies pertaining to forecasting a six-month inventory when a number pool is authorized in a particular area code.
Recommendations for LNP
_ The CPUC should request that non-LNP capable wireline carriers in the 650 area code become LNP capable.
Recommendations for UNP
_ The CPUC should petition the FCC for authority to implement UNP statewide.
_ The CPUC should solicit comments in order to develop rules and practices necessary to implement UNP.
Recommendations for Rate Center Consolidation
_ The CPUC should undertake further investigation by ordering the telecommunications industry to develop a plan, within 180 days, for rate center consolidation.
Recommendations for Sharing of Prefixes
1 NANPA is a role performed by NeuStar, Inc. The FCC chose NeuStar, formerly Lockheed Martin, to perform the functions of numbering administration and area code changes nationwide. 2 Including Type 1 Carriers. Type 1 numbers are described in Chapter 2, Sec. D. 4.a. 3 At present, only wireline carriers are required to participate in number pooling. The FCC has granted most wireless carriers an extension of time, until November, 2002, to implement the technology that will support number pooling. The FCC has permanently exempted paging companies from implementing the technology necessary to pool. 4 The percentage of numbers in use in a particular block of 1,000 numbers is referred to as the "contamination" level. 5 This assumes that companies' six-month inventory needs would be satisfied out of the unused numbers in the blocks greater than 25% contaminated. 6 Today called the Incumbent Local Exchange Carrier (ILEC) 7 Today called Competitive Local Exchange Carriers (CLEC) 8 D.00-07-053 9 A company's request for its first prefix in the rate center is considered an initial request; requests for additional prefixes are considered growth requests. 10 TD's analysis of available numbers in the remainder of this report uses 256 prefixes available for lottery as of the utilization data date of December 31, 2000. 11 See Chapter Three of this report for a discussion of LNP. 12 FCC's Opinion and Order on Telephone Number Portability FCC 97-74, issued March 6, 1997 13 Cellular companies, PCS companies, and paging companies comprise the wireless category. 14 ILECs and CLECs 15 The CPUC revised the imminent exhaust criterion from three months to six months in Joint Assigned Commissioner and Administrative Law Judge's Ruling Implementing Revised Procedures to Conform to FCC Order, dated April 30, 2001. 16 Report and Order and Further Notice of Proposed Rulemaking, CC Docket No. 99-200 FCC 00-104 (released March 31, 2000). 17 Wireline carriers are composed of ILECs and CLECs. 18 A detailed break-down of the available 3.05 million numbers is shown in Table B-1 in Appendix B. 19 3.40 million numbers is comprised of 844,753 estimated pooling donations by companies, plus 2.56 million available through the lottery. 20 Recommendations dealing with receiving authority from the FCC to increase contamination threshold rates (25%) for pooling, recovering blocks from special use codes, and recovering unused numbers from non-LNP capable carriers and Type 1 carriers as described later in this report. 21 See Table B-2 in the appendix for a detailed breakdown of the 4.54 million numbers. 22 Although all wireline carriers in rate centers that are in the top 100 MSA's are required to be LNP-capable, two wireline carriers in the 209 area code remain non LNP-capable in one or more of the rate centers that are located within one of the top 100 MSA's. 23 Rulemaking 95-04-043. 24 10% or less contaminated means that out of 1000 numbers in a block, 100 numbers or fewer have been classified as unavailable. 25 Future need may include serving new customers or offering new services. 26 See Table B-1 in Appendix B. The 432,626 is comprised of 57,990 which are in blocks that are 10-15% contaminated, 68,620 from 15-20% contaminated, 16,265 from 20-25% contaminated, and 289,751 numbers which are in blocks that are more than 25% contaminated. Later in this chapter, TD recommends additional steps that can be implemented to make more of the 432,626 numbers available for number pooling. 27 INC's Thousand Block (NXX-X) Pooling Administration Guidelines, dated January 10, 2000, state that carriers should donate specified thousand blocks. 28 Additional numbers from the last three columns of Table 2-5: 57,990+68,620+16,265=142,875 29 See Table B-2, Appendix B, for the derivation of this estimate. 30 See Chapter 1 for the discussion on Decision 00-07-052. 31 The FCC's First NO Order stated, "Numbers such as dealer number pools should be included as a subcategory of intermediate numbers." The definitions in the FCC's NRO Orders will govern companies' NRUF submissions and utilization rates for meeting utilization requirements. 32 Remote Call Forwarding allows a customer to have a local telephone number in a distant location. RFC is similar to call forwarding on a residential line, except that the RCF customer has no phone, no office and no physical presence in that location. Direct Inward Dialing uses a trunk from the central office which passes the last two to four digits of the Listed Directory Number into the PBX, thus allowing the PBX to switch the call to the correct extension without the use of an attendant. Existing DID retail service is limited to PBX services. For purposes of providing INP, DID switch functionality is used to provide INP to any CLC customer regardless of the type of terminal equipment used on the customer's premises. 33 The emergency preparedness prefixes are for services other than 911. 34 See Appendix C for a list of the prefixes reported as "special use", and the number of available numbers reported in each prefix. 35 The number used for inter-area code directory assistance, which is uniform throughout California, is 1-XXX- 555-1212. This number has been designated for this use at the federal level. 36 An example would be a customer request for 2,500 numbers to be used in 2000, coupled with a request to have the next 2,500 numbers in sequence "reserved" for the customer to use in 2001. 37 Central Office Code (NXX) Assignment Guidelines, prepared by the Industry Numbering Committee, January 27, 1999 version, Section 4.4. 38 See FCC Order 00-129, Paragraph 114 39 See Appendix D for a breakdown of reserved numbers reported in the 209 NPA by rate center. 40 86,000 administrative numbers include 10,000 administrative numbers reported in the 209 Directory Assistance rate center. 41 In the first NRO Order, both 360 days and 365 days were used as the time period for aging business numbers. In a clarifying order, the FCC adopted 365 days as the aging period for business numbers. When the CPUC sent out the parameters for utilization data for this study, the 360 day time period for aging business numbers was used. In order to be consistent with the time frames the FCC adopted, the CPUC is now using the 365 time period for aging business numbers. 42 See Appendix F for a breakdown of intermediate numbers held by wireline and wireless carriers. 43 Type 1 numbers are programmed in the wireline carrier's end office, but are used by a wireless carrier. 44 158,636 out of a total of 296,236 Type 1 numbers are unaccounted for or mismatched. 45 Type 1 numbers given to wireless carriers are from prefixes in which LNP has already been initiated by the wireline carriers. Because Type 1 numbers reside in the wireline carrier's end office, Type 1 numbers are LNP-capable and thus suited for pooling. 46 These blocks are 10% or less contaminated. 47 As of July 3, 2001. 48 One prefix was opened in the 310 area code to supply numbers to the pool, and two prefixes were opened in the 909 area code to supply numbers to the pool. Several prefixes have been opened for LRN purposes. 49 Before a whole prefix is activated, the prefix must be first listed for 66 days in the Local Exhange Routing Guide (LERG), stating the rate center where the prefix will be located. 50 Data can be found in Pooling Appendix. 51 Sections 6.1.4 & 6.1.5 in INC 99-0127-023, January 10, 2000 52 FCC 96-286 in CC Docket No. 95-116. 53 A second company lacks LNP capability in one switch in the 209 area code, although it is LNP capable is all other switches in the 209 area code. If this switch were LNP capable, 7,000 additional numbers would be eligible for pooling. 54 CPUC Joint Assigned Commissioner's and Administrative Law Judge's Ruling Regarding Lottery Eligibility and Number Pooling Requirements on July 26, 2001. 55 FCC 99-19, WT Docket 98-229; CC Docket No. 95-116, Released: February 9, 1999. Paging companies are indefinitely exempt from becoming LNP-capable. 56 Further Comments of the California Public Utilities Commission and the People of the State of California in CC Docket No. 99-200, submitted May 19, 2000. 57 See INC Contribution #336R of September 29, 2000, "UNP Architecture With Minimal Administrative Structure" and Focal and MCIWorldcom's Report on UNP Trial 58 NRO Order, FCC 00-104, CC Docket 99-200, ¶ 230. "We reiterate our finding that UNP and ITN [individual telephone number pooling] are not yet sufficiently developed for adoption as nationwide numbering resource optimization measures and conclude that ITN and UNP should not be mandated at this time.". 59 See ¶ 231: "We permit carriers, however, to engage voluntarily in UNP where it is mutually agreeable and where no public safety or network reliability concerns have been identified." 60 For example, while the ILECs still control roughly 95% of the residential toll market, competitors have succeeded in making significant inroads into the business toll market, where the ILECs now hold only 50% of the market. If the CPUC were to decide that the ILECs should be "made whole" for any lost toll revenues, then other companies legitimately could demand a mechanism to make them whole as well. Alternatively, if the competitors cannot practically be reimbursed for lost revenues, then as a policy matter, the CPUC must decide if it is reasonable to allow only the ILECs to recover such revenue.
_ The CPUC should further explore sharing of prefixes as a means to more efficiently utilize numbers in all area codes.
61 "Where Have All the Numbers Gone?" (Second Edition), The Ad Hoc Telecommunications Users Committee, prepared by Economics and Technology, Inc., June 2000. The estimate of $5.56 may be conservative.62 The last major rate design proceeding undertaken for Pacific Bell and Verizon, then GTEC, was the Implementation and Rate Design (IRD) phase of the New Regulatory Framework proceeding, 1.87-l l-033. The IRD phase took three years to complete. 63 Prior to the opening of a number pool, all companies requesting telephone numbers get prefixes from the NANPA. Thereafter only non-LNP-capable carriers receive prefixes from the NANPA, while LNP-capable carriers receive thousand-blocks from the pooling administrator. 64 See Chapter 1 for the discussion on Decision 00-07-052.