IV. Parties' Positions

Carlson's general recommendation is for the Commission to modify D.96-12-086 to eliminate the 1+10-digit dialing requirement prospectively for all overlays on a statewide basis. Alternatively, Carlson proposes that the Commission could limit the applicability of the 10-digit dialing requirement only to the current 310/424 area code overlay, and then evaluate the results before applying the policy more broadly to future area code overlays.

In support of his Petition, Carlson claims that no technical or legal barriers exist in implementing 10-digit dialing (rather than 1+10-digit dialing) for calls originating from and destined to telephone numbers within the geographic area served by an overlay. Carlson argues that customers should have the option of dialing 1+10-digits for calls within the overlay region on a permissive basis, but should also have the option not to dial the "1" prefix.

CALTEL expresses general support for Carlson's Petition, but CALTEL is primarily interested in a Commission reevaluation of the statewide 1+10 digit dialing plan for calls initiated on wireline networks, at least insofar as it impedes the ability of any carrier to implement 10-digit versus 1+10-digit dialing in area code overlays. CALTEL claims that constraints with the 1+10-digit dialing only apply to wireline carriers' systems, but not to those of wireless carriers. As a result, CALTEL claims, dialing the prefix "1" is not technologically neutral, and no longer appears to be providing the dialing parity benefits that it was originally designed to ensure.

SBC, Verizon, Verizon Wireless, Nextel of California, Inc., Sprint, Cingular Wireless, and T-Mobile claims that there is no time left to address the 1+10 digit issue for the 310/424 overlay, and that to do so would unreasonably delay implementation of the urgently needed area code change in the 310 NPA. However, they did not provide any evidence supporting this claim. None of them provided actual data or estimates of time, activities, and resources supporting this claimed delay if the prefix "1" was removed. SBC and Verizon further claim that the proposed transition to 10-digit dialing would lead to customer confusion because customers are already accustomed to dialing a "1" preceding calls requiring the area code and seven-digit line number. They also assert that there are technical impediments to transitioning from 1+10-digit to only 10-digit dialing. Yet, they did not provide any evidence supporting the existence of these technical impediments.