In NANPA's application, the telecommunications industry proposed to conduct a public education program. We agree with the need for a PEP. Given that the overlay authorized by this decision will be only the second overlay area code implemented in California, the public is highly unlikely to be familiar with the nuances of an area code overlay and the mandatory 10-digit dialing required for calls within their own NPA. The public is familiar with the traditional association of a single area code with a unique geographic area, and has had a long-standing expectation that telephone calls between numbers within a single area code require dialing only seven digits.

With an overlay, however, these traditional paradigms will no longer apply to calls within the overlay region. Instead, every call to and from the 714 and 657 area codes will require mandatory 10-digit dialing, even for calls terminated within the same area code. Therefore, we have established a history of providing criteria, requirements, goals, and objectives for required public education programs associated with area code changes.

In D.96-12-086, we decided that "an appropriate customer education and awareness program" was necessary when instituting overlays. This program could simultaneously explain "the concept of an area code overlay to customers, industry, and telecommunications employees" and the mandatory 1+10-digit dialing procedure.

D.96-12-086 also developed the necessary conditions for justifying the approval of an overlay. These conditions include the following: (1) the "customer education program should begin no later than 12 months prior to the implementation date of the mandatory 1+10-digit dialing for the affected region," (2) the program must "explain why mandatory 1+10-digit dialing is necessary and why it is being implemented coincident with the overlay," and (3) the program must "explain that the new dialing procedure "will not affect the distinction between local and toll calls, nor the rates charged for the different types of calls." Our decision also required industry members to "correct signage for dialing instructions on payphones and in directories" and to "perform switch translation work for implementing mandatory dialing (12 weeks prior to cutover.)"

In D.98-05-021, we listed several requirements for the public education program, and expanded the conditions and requirements in D.96-12-086.17 One of the additions required service providers to "institute an instructional announcement directing callers to dial 1+10-digits" indefinitely after implementing the area code overlay. We viewed this as a way to minimize customer confusion, which includes visitors who may be familiar with other dialing procedures. We also agreed that the public education program "should incorporate appropriate measures to communicate changes" associated with an area code overlay to children, the elderly, the disabled community, and the various ethnic groups in the region. And, we prioritized the education of "those entities which will need to reprogram equipment" due to the new dialing procedure like alarm companies.

Also in D.98-05-021, we required the PEP "to inform customers how to dial directory assistance to locate numbers applicable to different area codes within the same overlay region." And, we required dissemination of billing inserts and public service announcements, as well as the updating of telephone directories to account for the area code and the seven-digit number for each directory listing.

In D.98-05-021, we also extended the coverage of the PEP to include not only the region in which the area code overlay will be implemented, which should be the first priority, but also the NPAs adjacent to the overlay NPA and the whole state (to a lesser extent) to facilitate the acceptance of area code overlays in general and to recognize the mobility of California residents. We also compelled the use of press releases, television and radio announcements, and billing inserts in the PEP. Moreover, we ordered the submission of a proposed PEP for review and approval within 30 days from the effective date of the decision.

In D.98-12-081, we ordered a PEP to "promote not only consumer awareness, but also consumer acceptance" of the area code overlay as the goals. We decided that a 70% customer awareness level was sufficient for the PEP to achieve. Furthermore, it set four major objectives for the PEP, recognizing the importance of serving the public's interest and minimizing disruptions and negative reactions:

(1) public awareness of the change in dialing patterns and area code identification resulting from implementation of the overlay;

(2) understanding of how customers will be affected by the change and the rationale behind the change;

(3) public assurance that cost or quality of telephone service will not be adversely affected by the change; and

(4) promotion of positive acceptance by customers of the change.

In D.98-12-081, we also mandated the operation of a call center for consumers to obtain information regarding the area code overlay. We also ordered "targeted paid advertising in the relevant zoned editions of major newspapers as well as newspapers targeted to ethnic communities", bill insert notices to the adjacent NPAs, limited use of billboard and radio advertising, and mailing of letters, brochures, and collateral materials to local government officials in the overlay and adjacent NPA regions. 18

In D.05-08-040, we incorporated "at a minimum the activities and standards previously required for the 310 and 408 area code overlay PEPs" to achieve a 70% public awareness level. We directed PEP outreach efforts to specifically target key governmental agencies and community leaders, chambers of commerce, major airports, hospitals, alarm providers, pay telephone providers and the state coordinator for E-911. The PEP also had to include special outreach to senior citizens, children, the disabled, and ethnic minorities and newspaper, billboard, radio, and television advertising targeted to the general public and ethnic minorities.

17 The requirements were described in Ordering Paragraphs 8 and 9 and Conclusions of Laws 5 thru 11.

18 The Commission subsequently adopted a similar PEP in June 1999 for the 408/669 area code overlay in Appendix A of D.99-06-087.

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