III. Responses to the Petition
Responses to the Petition were separately filed by the California Cable & Telecommunications Association (CCTA) and by The Telephone Connection of Los Angeles, Inc. and The Telephone Connection Local Services, LLC (TCLA). An additional response in opposition to the Petition was filed jointly by Cingular Wireless, Pacific Bell Telephone Company, Sprint Nextel Corporation, T-Mobile, Verizon California Inc., and Verizon Wireless (referred to collectively as the "Joint Telecommunications Carriers" or "JTCs").
Responding parties oppose the Petition to the extent that it seeks to halt the implementation of the overlay, arguing that such a proposal would deny needed relief to the 310 area code. The JTCs claim that the Petition fails to raise any issue which has not already been fully considered by this Commission. The JTCs describe the numbering situation in the 310 area code as "dire" and claim that consumers and carriers will be harmed if there is further delay in implementing area code relief as ordered in D.05-08-040.
While CCTA and TCLA oppose suspension of the overlay implementation, they nonetheless support certain measures proposed by the County such as rate center consolidation and the porting of unassigned numbers as longer term remedies to promote more efficient utilization of number supplies.1
In addition to parties' formal filings, we received letters from representatives of various local governmental entities with constituencies in the 310 area code, expressing support for the County's Petition.2 These letters have been reviewed and placed in the correspondence file.
The County was permitted to file a third-round reply to parties' responses on February 7, 2006, addressing certain responses made by parties and incorporating a Supplemental Declaration of Lee Selwyn. We have considered all of the above-referenced materials in reaching our decision denying the Petition.
1 In its response, TCLA also proposes that the Commission petition the FCC for assignment of a technology-specific overlay for wireless telephone numbers and for wireless carriers to assign all numbers on a prospective basis from the specialized overlay. This proposal does not appear to be directly responsive to the issue of whether or not halt implementation of the overlay, and is therefore beyond the scope of the Petition for Modification.
2 Letters in support were received from the South Bay Cities Council of Governments, the South Bay Association of Chambers of Commerce, City of El Segundo, City of Manhattan Beach, City of Carson, City of Palo Verdes Estates, and City of Inglewood.
