Conclusions of Law

1. The FCC requires 10-digit dialing for almost all calls in overlay regions. The only exemptions from the FCC's 10-digit dialing requirement are 411 calls, 911 calls, and a few other limited exemptions.

2. The FCC's requirement for mandatory 10-digit dialing for almost all calls in overlay regions precludes the use of 8-digit dialing in overlay regions.

3. Eight-digit dialing is not feasible at this time for the reason set forth in the previous Conclusion of Law.

4. The issue of whether 8-digit dialing should be implemented in California is not ripe for decision because (i) the FCC prohibits 8-digit dialing, and (ii) there are no overlays either in effect or being implemented in California.

5. The Commission should not open a proceeding at this time to consider the adoption of 8-digit dialing.

6. The Commission should not petition the FCC at this time for authority to implement 8-digit dialing.

7. The following order should be effective immediately.

INTERIM ORDER

IT IS ORDERED that:

1. A proceeding shall not be opened at this time to consider the adoption of 8-digit dialing.

2. The Commission shall not petition the Federal Communications Commission at this time for authority to implement 8-digit dialing.

This order is effective today.

Dated , at San Francisco, California.