III. Position of the Parties.
Yablon states that overlays have the advantage of providing area code relief without requiring customers to change their 7-digit phone numbers. The disadvantage is that customers must use 10-digit dialing for all calls within an overlay region, which causes disruption, frustration, and expense to telephone users. Yablon claims that 8-digit dialing would help make living with overlays easier by preventing misdials. For instance, in standard 10-digit overlays, many customers habitually dial familiar 7-digit numbers and end up having to hang up and re-dial using 10 digits. In the 8-digit overlay, habitual dialing of 7-digit numbers is not a problem. After dialing 7 digits, customers enter the one-digit "area code selector." If customers forget to enter the eighth digit, an announcement could be provided to remind customers to enter the eighth digit, and the call would be completed without frustration.
Yablon states that 10-digit dialing should remain available alongside 8-digit dialing so that customers would never have to hang up and redial, regardless of the format they begin dialing with.6 Thus, backward compatibility with previously established dialing patterns is maintained, thereby minimizing customer frustration and expense. Yablon states that this feature would also allow visitors who are not familiar with 8-digit dialing to dial any number.
Yablon asserts that 8-digit dialing conforms to the 10-digit structure of the NANP. This is because the new 8th digit is used only for dialing, and does not become part of the 10-digit NANP telephone number. Hence, as with telephone numbers currently dialed with 7 digits, a telephone number dialed with 8 digits would be treated as a 10-digit telephone number that complies with the NANP.
Yablon states that 8-digit dialing is compatible with local number portability and number conservation measures. This is because numbers dialed with 8-digits would always be treated as standard 10-digit NANP numbers. Thus, the network would interact with the 8-digit number as if 10 digits had been originally dialed.
Yablon believes that the Commission has authority to implement 8-digit dialing, since the impact of the 8-digit dialing does not affect costs, switching, or dialing for any customers or telephone companies outside of California. Yablon states that if the Commission does not have authority to implement 8-digit dialing, the Commission could petition the FCC for a waiver of the FCC's requirement to dial 10 digits for all calls within an overlay region.
Yablon acknowledges that telephone companies would incur costs to implement 8-digit dialing. Yablon believes, however, that the cost to implement 8-digit dialing would not be significantly different in the long run than what it would cost to implement standard overlays with 10-digit dialing. Yablon also acknowledges that the public would have to be educated about 8-digit dialing, but Yablon claims the education effort for 8-digit dialing would not have to be any more expensive than the education effort required for standard overlays with 10-digit dialing.
GTE and Pacific oppose 8-digit dialing. They state that 8-digit dialing is not compatible with the current network, and that it would be costly to upgrade the network to accommodate 8-digit dialing. For example, the network would have to be modified to provide the interactive recorded announcement proposed by Yablon if an eighth digit is not dialed. According to Pacific, current network equipment can provide an announcement, but the equipment cannot operate like voice mail or other telephone answering systems that allow customers to make various choices by pressing numbers on their phone set. Pacific states that it would be very costly to add equipment to the network that would allow this type of interactive system.
Pacific asserts that 8-digit dialing would be very confusing for customers who would be using three different dialing patterns: 7-digit dialing in areas without overlays, 8-digit dialing in areas with overlays, and 10-digit dialing between geographically separate area codes. Pacific states that tourists and other visitors would also face this array of dialing patterns, but would have no experience with 8-digit dialing.
Pacific asserts that 8-digit dialing does not comply with the FCC's requirement for mandatory 10-digit dialing for every call made within an overlay. According to Pacific, the FCC would have to waive or eliminate this requirement in order for 8-digit dialing to be implemented.
Finally, GTE and Pacific state that 8-digit dialing has already been reviewed and critiqued by the California Telecommunications Industry and the national Industry Numbering Committee. Both reviews found that 8-digit dialing has significant technical issues and should not be pursued further.
6 Yablon states that if the "area code selector" digit is inadvertently entered at the end of a 10-digit dial, the selector digit would be ignored and the call routed to the 10-digit number that was dialed.
