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Risa Hernandez Sue Wong

A. Inefficient Use and Increasing Demand for New Numbers in California Is Causing Area Code Proliferation 66

B. 818 History and CPUC Decisions 77

1. Monthly Lottery Allocation of Prefixes 77

C. CPUC Efforts to Resolve Area Code Proliferation 88

1. Number Pooling 88

2. Improved Number Inventory Management 99

3. CPUC Efforts at Federal Level 1010

4. Utilization Studies 1313

A. The Scope of the Utilization Study 1414

1. Distribution Statistics of Prefixes 1414

      2. Carriers Reporting..............................................................15

      3. Non-Reporting Carriers........................................................15

B. 3.9 Million Numbers Available in the 818 Area Code 1616

C. Analysis of Available Numbers 2020

1. Analysis of Wireline Carriers' Contamination Rates 2020

2. Analysis of Wireless Carriers' Contamination Rates 2222

3. Potential Block Contamination Abuses 2424

4. Reclamation of Prefixes 2525

D. Analysis of 4.0 Million "Unavailable" Numbers 2626

1. 3.1 Million Assigned Numbers 2727

2. Reserved Numbers Are a Potential Source of Additional Numbers 3131

3. Restrictions on Administrative Numbers Could Yield More Numbers 3333

4. Intermediate Numbers 3535

5. Aging Numbers 3737

6. The Need to Audit the Data 3939

A. Introduction 4040

B. Number Pooling 4040

1. More Accurate Forecasting Will Improve Number Pooling 4141

C. Lack of Local Number Portability Stands as a Key Barrier to Pooling 4242

D. Unassigned Number Porting 4444

E. Consolidation of Rate Centers to Maximize Number Use 4545

F. Sharing of Prefixes May Yield More Efficient Number Use 4747





4. Utilization Studies


1. Distribution Statistics of Prefixes



          1. Analysis of Wireline Carriers' Contamination Rates



        b) Eliminating Interim Number Portability Releases Numbers for Reallocation







For convenience, "other administrative numbers" are reported as a group for purposes of the Utilization Study



      · The CPUC should monitor reserved number use for all companies by reviewing future utilization data to ensure companies are complying with whether the FCC's 45-day requirement.

      · The CPUC should adopt efficient number use practices specific to company reserve 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 number resources prior to requesting new number resources.

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 Historically, telephone numbers have been allocated to companies in blocks of 10,000, as a complete prefix, such as (415) 703-XXXX. Number pooling allows companies to obtain numbers in blocks of 1,000 or even fewer numbers. 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 A company's request for its first prefix in a rate center is considered an initial request; requests for additional prefixes are considered growth requests. 9 See Chapter 3 of this report for a discussion of LNP. 10 FCC's Opinion and Order on Telephone Number Portability FCC 97-74, issued March 6, 1997 11 Celullar companies, PCS companies, and paging companies comprise the wireless category. 12 ILECs and CLECs 13 Report and Order and Further Notice of Proposed Rulemaking, CC Docket No. 99-200 FCC 00-104 (released March 31, 2000). 14 Wireline carriers include ILECs and CLECs. 15 A further breakdown of the 2.7 million available numbers held by companies is shown in Table B-1 in Appendix B. 16 Type 1 carriers are not considered wireline or wireless carriers. Type 1 numbers are programmed in to wireline carrier's end office, but are used by a wireless carrier. 17 See Chapter 3 for the status on pooling in the 818 area code. 18 Chiefly, setting a higher contamination threshold (25%) for pooling, recovering blocks from special use codes, recovering unused numbers from non-LNP capable carriers and Type 1 carriers as described later in this report, and requiring wireless carriers to participate in pooling. 19 See Table B-2 in the appendix for a detailed breakout of the 3.2 million numbers. 20 Although all wireline carriers are required to be LNP capable, two wireline carriers in the 818 area code remain non LNP-capable. 21 10% or less contaminated means that out of 1000 numbers in a block, 100 numbers or less have been classified as unavailable. 22 Future need may include serving new customers or offering new services. 23 See Appendix B, Table B-1. The 426,463 is comprised of 55,667 numbers from blocks that are 10-15% contaminated, 54,387 from 15-20% contaminated, 28,191 from 20-25% contaminated, and 288,217 numbers from block that are more than 25% contaminated. Later in this chapter, TD recommends additional steps that can be implemented to make more of the 426,463 numbers available for number pooling. 24 For a discussion of numbers held for special uses, see Section D.1.c of this chapter. 25 INC's Thousand Block (NXX-X) Pooling Administration Guidelines, dated January 10, 2000, state that companies should donate specified thousand blocks. 26 Additional numbers from the last three columns of Table 2-5: 55,667 + 54,387 + 28,191 = 138,245 27 Of the 386,000 unused numbers held by wireless carriers, TD estimates that 162,000 are held by the paging companies. See Table B-2 of Appendix B. 28 See Chapter 1 for the discussion on Decision 00-07-052. 29 Companies must file monthly reports with TD identifying prefixes which have not been activated within the six month time frame and explain the circumstances causing the delay in activating the prefix. The CPUC would then consider each company's circumstances and determine whether to direct the NANPA to reclaim the prefixes. 30 Remote Call Forwarding allows a customer to have a local telephone number in a distant location. RCF 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. 31 However, two wireline carriers still remain non-LNP capable. 32 The emergency access prefixes are for services other than 911. 33 This prefix is reserved for companies who request telephone lines to set up numbers for customer information services. 34 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. 35 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. 36 Central Office Code (NXX) Assignment Guidelines, prepared by the Industry Numbering Committee, January 27, 1999 version, Section 4.4. 37 FCC Order 00-280, CC Docket No. 99-200, adopted and released on July 31, 2000. 38 See Appendix D for a breakdown of reserved numbers reported in the 415 NPA by rate center. 39 Although most wireline carriers serving the 818 NPA are LNP-capable, a number pooling trial has not yet been implemented in this area code. Thus, these companies still request new number resources at the 10,000 block level (i.e. whole prefix) from the NANPA. As described in Chapter 1 of this report, however, the CPUC is considering a proposal that would establish number pooling in the 818 area code in 2001. At that time, companies could donate excess numbering resources for reallocation and could get new number resources in smaller quantities (i.e. at the 1,000 number block level). 40 The Van Nuys rate center by far has the most prefixes allocated to companies in it compared to other rate centers in the 818 area code. As of April 30, 2000, 237 of the prefixes allocated in the 818 area code were located in there; other rate centers in the area code had between 1 and 70 prefixes each allocated in them. Correspondingly, there are nearly 200,000 reserved numbers in the Van Nuys rate center and thus it has a great potential for conserving number resources if improvements in the use of reserved numbers are implemented as suggested by TD. 41 This company used most of its numbers in this category for "other administrative purposes", which was ten times or more the amount of numbers any other company used for those purposes. See Appendix A for details on what is included in the subcategory "other administrative purposes". 42 See Appendix F for a breakdown of intermediate numbers held by wireline and wireless carriers. Appendix F demonstrates that the quantity of intermediate numbers in each 818 rate center varied from 0 to nearly 146,000. 43 Type 1 numbers are programmed in the wireline carrier's end office, but are used by a wireless carrier. 44 143,100 out of a total of 354,300 Type 1 numbers are unaccounted for or mismatched. 45 Type 1 numbers may go unused because wireless carriers go out of business or because of inadequate record keeping. 46 The 818 study revealed that 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. 47 These blocks are 10% or less contaminated. 48 In the 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. 49 Two prefixes have been opened in the 310 pool for LRN assignment purposes. 50 As of September 18, 2000. 51 Three prefixes have been opened in the 415 pool for LRN assignment purposes. 52 Before a whole prefix is activated, the prefix must be first listed for 66 days, in the Local Exchange Routing Guide (LERG), stating which rate center the prefix will be located in. 53 Data can be found in Pooling Appendix. 54 6.1.4 & 6.1.5 in INC 99-0127-023, January 10, 2000 55 FCC 96-286 in CC Docket No. 95-116 56 FCC 97-074 in CC Docket No. 95-116 57 FCC 99-19, WT Docket 98-229; CC Docket No. 95-116, Released: February 9, 1999 58 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. 59 See INC Contribution #336R of September 29, 2000, "UNP Architecture With Minimal Administrative Structure" and Focal and MCIWorldcom's Report on UNP Trial 60 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." 61 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." 62 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.

63 "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.

64 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. 65 See Chapter 1 for the discussion on Decision 00-07-052.

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