Parties' Positions

Parties disagree on what back-up plan should be adopted for the 310 NPA and what the timing and conditions of implementation of any back-up plan should be. Assemblyman Knox and Assembly Speaker Villaraigosa oppose any form of back-up plan for the 310 NPA that entails creating a new area code. They express concern that adopting a back-up plan to implement a new area code may unduly take precedence over the commitment to make the number conservation measures work. The other parties agree that the back-up plan must provide for the creation of a new area code in order to conform to FCC requirements, but disagree as to whether the back-up plan should be an overlay or a geographic split. Parties representing incumbent and wireless carriers advocate reinstatement of the previously suspended overlay as the back-up plan, with its implementation to begin immediately. Parties representing competitive local carriers generally support adoption of a geographic split as a back-up plan, and offer alternative views on when implementation should begin.

Pacific, AirTouch, and Sprint PCS favor the overlay as a back-up relief plan arguing that it is better for customers, and claim that a geographic split could not be fully implemented before complete code exhaustion in the 310 NPA. These parties argue that given the lead time needed to implement a back-up plan, only an overlay could be implemented in time to assure that code exhaustion is avoided.

The Joint Commenters and ORA/TURN support adoption of the geographic split previously proposed by the industry, Alternative 1A, as the only viable back-up plan that is consistent with Commission policy. ORA/TURN oppose Pacific's proposal for a seven-digit overlay, arguing such a plan would be anti-competitive, would create gross inequities in customer dialing patterns, and would violate FCC rules. These parties argue that a streamlined implementation schedule could be devised to provide for expedited implementation of a geographic split.

Several parties argue that implementation of the back-up plan should begin immediately in view of the time required for implementation. Parties differ as to how long implementation of the back-up plan would take and how far in advance the implementation would have to begin to avoid code exhaustion.

If the Commission were to defer the implementation of a back-up plan, most parties still generally agree on the need for some triggering mechanism that would automatically initiate immediate implementation of the back-up plan. CCAC proposes that a mechanism be established to trigger implementation of the back-up plan when the 310 NPA is projected to be six months from exhaustion. ORA and TURN support either a six-month or nine-month-to-exhaust standard as a trigger to initiate implementation of the back-up plan after number pooling is in place.

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