2. Discussion

Pacific requests that D.96-12-086 be modified to allow the use of overlays for new area codes implemented through the year 2000. Since we are now in the year 2001, Pacific's request is moot.

Pacific also requests that D.96-12-086 be modified to adopt a policy that favors overlays under specified circumstances. Our current policy is to maximize the efficient use of telephone numbers in order to avoid the need for new area codes.8 When new area codes have become necessary, we have repeatedly found that overlays have significant disadvantages. Appendix A contains excerpts from Commission decisions that highlight the significant disadvantages of overlays. Pacific's petition offered no new arguments in support of overlays. Therefore, in light of significant disadvantages of overlays, we deny Pacific's request to adopt a policy that favors overlays.9

For the forgoing reasons, Pacific's petition to modify D.96-12-086 is denied.

8 D.00-07-052. 9 On September 15, 1999, the Commission filed a petition at the Federal Communications Commission (FCC) for authority to establish service-specific and technology-specific overlays. The FCC has not yet acted on the petition. If the FCC grants the petition, we will consider whether to implement service-specific and/or technology-specific overlays at the first available opportunity.

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