III. Industry Proposals

The industry could not reach consensus on one plan for 909 area code relief, but reached consensus on forwarding two relief plan proposals, as described below.

A. Alternative #7 - Two-Way Geographic Split

The industry offers Alternative #7 as one of its two proposed options. Alternative #7 would split the boundary running along rate center lines in a west-to-east direction approximately through the center of the present 909 area code region. The new boundary line approximately separates Riverside and San Bernardino Counties, and maintains a single area code for residents of Calimesa and Riverside, Banning and Beaumont Counties.

NANPA projects the northern area would have a life of seven years and the southern area would have a life of twelve years. If the Commission approves this plan, the industry requests that the existing 909 area code be retained by the northern area in view of its shorter projected life and to avoid the potential for customers in this area to change their area code twice within a relatively short period of time. The industry also requests guidance from the Commission concerning the assignment of certain 909 central office codes rated to tandem switches which are located geographically outside the 909 area code.

The industry recommends shortening the mandatory dialing period to three months. Pub. Util. Code § 7932, which became effective January 1, 1999, provides discretion to the Commission to determine the duration of any transitional dialing period. The industry recommends the following implementation dates for the split plan:

IMPLEMENTATION EVENT	Timeframe
From Effective Date of Order to Start of Permissive Dialing	9 months
Permissive Dialing Period	3 months
From Beginning of Mandatory Dialing to First Code Activation Using New Area Code	2 months

B. Alternative #6 - All-Services Overlay

Under the proposed overlay alternative, a new area code would be superimposed over the same geographic area currently served by the 909 area code. All existing customers would retain the 909 area code. If this option is adopted, the industry proposes a 10-month implementation period. The industry recommends the 10-month implementation period for Alternative #6 be allocated in the following manner:

IMPLEMENTATION MEASURE	Timeframe
Notification from Commission to industry	3 months
Permissive 1+10-digit dialing and Customer Education Period	6 months
From beginning of mandatory 1+10-digit dialing until first code activation in the new area code	1 month

C. Comments of Industry Members

Although both plans are sponsored by the industry, one party filed comments advocating a preference for the overlay. On June 28, 2002 Verizon Wireless filed comments in support of the all-services overlay as the preferred option. Verizon argues that this alternative avoids the divisive practice of drawing boundary lines and essentially picking winners and losers based on which side is assigned the new area code. Verizon argues that adequate consumer education, speed dialing, and other measures can help consumers adapt to 1+10-digit dialing without undue burden. If the Commission adopts a geographic split, however, Verizon proposes that wireless carriers be given an extended permissive dialing period in view of the required reprogramming of hundreds of thousands of handsets. In instances where over-the-air reprogramming is not available, customers may have to bring their phones into retail or service outlets for reprogramming.