V. Conclusion

With more than two million telephone numbers still available in the 310 area code, it is not necessary to split the 310 when there are more than enough unused and available telephone numbers to serve customer demand for the foreseeable future. The excessive demand forecasts and the continuance of overly large inventory holdings in the 310 area code make it appear unnecessarily that 310 area code has less numbers available for use than are actually available. This chicken-little approach to projecting area code relief is clearly flawed.

The 310 area code, which was originally projected by industry forecasters for imminent split in 1997, is still strongly alive eight years later. The success of past conservation efforts indicates just how important it is to continue down the path of conservation. We believe that specific telephone number conservation options should be more fully explored as a means of prolonging the life of the 310 are code before taking action to impose a split or overlay on it businesses and families.

Conservative estimates of implementing just two additional number conservation measures (inventory guidelines and moving pager carriers to the pooling system) would alone add four to five years to the life of the 310. Beyond that, the full impact of current conservation measures such as LNP for wireless carriers has yet to be fully studied. Given the current continual and positive net inflow or increase of numbers to the 310 pool, it is conceivable that the 310 area code relief might not be needed for many years to come.

California has been a leader and innovator in this country for telephone number conservation. A step backwards now will lead the state to where we were in the late nineteen-nineties with a proliferation of new area codes.

Accordingly, we direct the Commission Telecommunications Division (TD) staff to explore further conservation measures as indicated, to develop a plan for streamlining the way that wireless carriers use rate centers, and to develop an updated approach to forecasting area code exhaust in California. TD should also continue to monitor the remaining telephone numbers in both the 310 number pool and the lottery, and to make any necessary reallocations in order to provide carriers with necessary telephone numbers.

Some data contained in this document is obtained from the most current NANPA NRUF report available (12/31/03) and represents the most currently known state of available numbers in the 310 area code as well as trends in how carriers utilize telephone numbers. As new NRUF data is expected to be publicly available by mid-September, we will incorporate new data into this decision as it is updated in response to public comment.