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Before The Public Utilities Commission Of The State Of California
REPORT ON THE 415 AREA CODE Submitted in Compliance with California Public Utilities Code Section 7937, CPUC Decision 99-12-051, and Administrative Law Judge Ruling Issued on January 18, 2000 CALIFORNIA PUBLIC UTILITIES COMMISSION TELECOMMUNICATIONS DIVISION Respectfully submitted November 28, 2000 Jack Leutza, Director Telecommunications Division 505 Van Ness Avenue, 3rd Floor San Francisco, CA 94102 REPORT ON THE 415 AREA CODE CALIFORNIA PUBLIC UTILITIES COMMISSION TELECOMMUNICATIONS DIVISION November 28, 2000 Prepared by Telecommunications Division: Michael Amato Jack Leutza Victor Banuelos Robert Benjamin Mary Jo Borak Helen Mickiewicz Geraldine Carlin Eleanor Szeto Cherrie Conner Karen Watts-Zagha Melvin De La Cruz Maryam Ebke Risa Hernandez Sue Wong
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a. Type 1 Numbers 36
APPENDIX A APPENDIX B APPENDIX C APPENDIX D APPENDIX E APPENDIX F APPENDIX G APPENDIX H APPENDIX I
At the same time, the 415 study finds that under FCC rules, about 2.2 million numbers cannot be contributed to the 415 number lottery, nor can they be contributed to the existing 415 number "pool" for reassignment to other companies. The FCC has determined that wireless carriers do not have to participate in the pool at this time.3 In addition, the FCC has determined that the CPUC may only require wireline carriers to contribute to a number pool those blocks of 1,000 numbers that are 10% or less contaminated,4 meaning those blocks in which only 100 or fewer numbers are unavailable. However, wireline carriers may also keep a portion of the 10% or less contaminated blocks if those are needed for use within six months. Thus, 2.2 million numbers in the 415 area code are available only to the companies holding those numbers because they are held by wireless carriers, are in blocks that are more than 10% contaminated, or are in blocks 10% or less contaminated but kept for six-month inventory. The study further finds that of the 3.9 million numbers not in use, about 3.1 million could be made available to companies through pooling if a) the companies donated blocks with higher contamination levels to the pool, and b) wireless carriers were required to participate in the 415 number pool. The first table below illustrates the current distribution of numbers. The second table shows the distribution that would occur if all the recommendations in this report were implemented.
Finally, the study notes that companies identify 3.8 million numbers as unavailable. TD staff recommends specific measures the CPUC can employ to ensure that companies use those "unavailable" numbers more efficiently. Given the near doubling of the number of area codes in California, from 1996 to 1999, this vital public resource should be used as efficiently and effectively as possible. The CPUC and the telecommunications industry should strive to minimize the quantity of numbers left "stranded" in company inventories. The 415 Area Code Report recommendations are summarized in Appendix I.
California is currently experiencing an explosive demand for telephone numbers and area codes. The increased demand for numbers is due to many factors, including competition for local phone service, as well as the popularity of faxes, pagers, cell phones, internet services, etc. California's robust economy and the growth in the state's population also contribute to the increased demand for telephone numbers. This increase in demand is complicated by a number allocation system dating from the 1940's that is inefficient in today's competitive marketplace. Prior to 1997, one phone company5 provided local telephone service to all customers in a particular area and new area codes were opened as the population grew. The number of California area codes rose steadily from 3 in 1947 to 13 in 1992, and stayed at that level until January 1997. The Telecommunications Act of 1996 brought competition to local telephone service and competitive local phone companies6 began to enter the marketplace, each requiring its own stock of numbers. The traditional system of number allocation was not designed to provide telephone numbers to more than one company. In the past, when telecommunication companies needed telephone numbers to serve their customers, they received blocks of 10,000 numbers, i.e. prefixes. Because companies were assigned blocks of 10,000 numbers, they may have been assigned more numbers than they needed. For example, under this system, a company with only 500 customers would have received a 10,000 number block, the same quantity of numbers a company with 9,500 customers would receive. Thus, numbers are taken in these large blocks, creating an artificial demand for more numbers, which in turn fuels the need to open more area codes. The need to assign 10,000 numbers is a practice from the past when one telephone company provided service to all customers in its territory. Today, with over 200 telecommunications companies in the state needing numbers to serve customers, and with the limited quantity of numbers available in each area code, this process is no longer an efficient way to allocate numbers. The rise in demand for numbers combined with the inefficient allocation system for numbers has forced the rapid opening of new area codes throughout the state. Since 1997, the number of area codes has nearly doubled to 25. Unless major changes occur, the CPUC projects that 16 more area codes would need to be opened in California by 2002. With more and more companies needing numbers of their own, new area codes are not necessarily the best solution. The 415 area code is a classic example of area code proliferation in California. One of the first three area codes in California in 1947, the 415 area code originally covered all of central California. Today, the 415 area code encompasses only San Francisco and portions of Marin County. The geographic area comprising the original 415 area code is now divided into seven additional area codes, including 209, 408, 559, 831, 510, 925, and 650. Despite the introduction of seven area codes between 1958 and 1997 to provide new numbers to the 415 area code, the North American Numbering Plan Administrator (NANPA) determined in late 1997 that the 415 area code was running short of numbers. In response to the NANPA's determination that the CPUC must act to provide additional numbers for phone company use, the CPUC approved an area code overlay on April 1, 1999. In an overlay, a new area code is created covering the same geographical area as the existing area code. Under CPUC and Federal Communications Commission (FCC) rules, all customers with numbers in both the new and old area codes are required to dial 1 plus the area code plus the seven digit number (known as 1 + 10 digit dialing) to reach any other number in either of the two area codes. The new area code was scheduled to be overlaid on the 415 area code on October 21, 2000, with mandatory 1 + 10 digit dialing to begin on July 24, 2000. When the first overlay and 1 + 10 digit dialing were implemented in the 310 area code (located in the Los Angeles area) in April of 1999, customers expressed strong objections to the overlay and to the requisite 1 + 10 digit dialing. The CPUC halted the 310 overlay in September. In December of 1999, by Decision 99-12-051, the CPUC suspended all overlays previously approved, which included the overlay in the 415 area code. In that same decision, the CPUC required its Telecommunications Division (TD) staff to study number use to determine the quantity of available, unused numbers in the 415 area code. This report fulfills that requirement.7 In all the area codes in danger of running out of numbers, the CPUC has instituted a lottery process to fairly allocate the remaining prefixes among phone companies when demand exceeds supply. The 415 lottery began in October 1996. Currently, the CPUC distributes three prefixes (two initial and one growth8) in the monthly 415 lottery. Each company submits applications for initial and growth prefixes to the NANPA Code Administrator. If more applications are received than can be satisfied in that month, the first applicants chosen by random drawing are assigned a prefix and the remaining applicants are placed on a priority list and receive prefixes in one of the following months' lotteries in the order they were drawn. Once every company requesting a prefix has received one, a new drawing is held and additional companies are eligible to receive prefixes. Twenty-nine prefixes have been allocated in the 415 area code through this process between January 1, 2000 and August 31, 2000. Recognizing the substantial social and economic burdens associated with constant area code changes, the CPUC has taken steps to resolve the numbering crisis. Responding to widespread public outcry over the proliferation of new area codes, the CPUC suspended, beginning in December 1999, all plans for new area codes previously approved. In July 2000, the CPUC adopted number conservation measures, including establishming number pooling trials, fill rates, and sequential numbering. The CPUC, with FCC approval, has begun pooling trials in four area codes, in order to boost the efficiency of phone number allocation. Number pooling allows telephone companies to receive numbers in smaller blocks than the traditional 10,000 numbers, enabling multiple providers to share a prefix, thereby utilizing this limited resource much more efficiently. The technology that enables the network to support the assignment of smaller blocks is referred to as Local Number Portability or LNP.9 LNP was originally mandated by the FCC as a means to enable customers to retain their telephone numbers when they switch telephone service to another local provider. This same platform is utilized for number pooling. The FCC had required all wireline carriers to become LNP-capable by the end of 1998 in the top 100 Metropolitan Statistical Areas (MSAs) in the country. Thirteen of the top 100 MSAs are located in California; the 415 area code is in one of them.10 Though LNP technology has existed for several years, the FCC later granted cellular and PCS companies an extension of time until November 2002 to become LNP-capable. The FCC gave paging companies a permanent exemption from the LNP requirement.11 Thus, at this time, only wireline carriers12 can participate in number pooling. In the area codes with number pooling, wireline carriers participate in pooling and wireless carriers participate in the lottery. In the remaining area codes, all phone companies participate in the lottery. The CPUC has been aggressively setting up number pools. On July 29, 2000, the CPUC initiated a mandatory number pooling trial, the second number pooling trial in the state, for the 415 area code. Pursuant to Assigned Commissioner's Ruling dated April 21, 2000, the CPUC placed 36 prefixes on hold to provide an initial inventory of codes for this pool. All companies with numbers in 415 are required to donate 1,000-number blocks to the pooling administrator. Under the number pooling program, all LNP-capable carriers receive numbers in blocks of 1,000 in the 415 area code on an as-needed basis. There is no rationing process in the pooling trial and the blocks received can be put into service almost immediately upon receipt. As of the end of August 2000, LNP-capable carriers had donated 640 blocks, or 640,000 numbers, to the pool. A complete discussion of the status of the 415 pooling trial is found later in this report. While the pooling trials have improved the efficiency of the distribution of numbers to companies, companies have not had strong incentives to efficiently manage the numbers already allocated to them. Thus the CPUC ordered companies to improve number inventory management with measures including rules on fill rates and sequential numbering. In July 2000, the CPUC issued Decision 00-07-052, which extended number conservation measures adopted in the 310 area code to other area codes within California. These number conservation measures include the following:
TD anticipates these policies will potentially free more numbers for use in number pooling, to be allocated through the lottery, or to be otherwise used by companies. Indeed, these measures together with the effects of number pooling have already achieved some positive effects. For example, since the CPUC extended the 75% fill rate and imminent exhaust rules to all area codes, including 415, CPUC staff has observed that the demand for growth prefixes in each month's lottery has declined. Further evidence of the effectiveness of the CPUC's number conservation policies is the recent increase in the number of remaining prefixes in the 415 area code. As of April 30, 2000, there were 72 remaining prefixes available for assignment in the 415 area code. That number increased to 89 prefixes by August 2000, with the CPUC working with companies to reclaim excess prefixes held by companies. These 89 prefixes are in addition to the 36 prefixes set aside for the 415 pool. Because the CPUC has instituted changes to number allocation rules, and because prefixes have been reclaimed from companies, there are four more prefixes available for assignment today compared to December 1999. The FCC has exclusive jurisdiction over numbering in the U.S. Therefore, the CPUC's number conservation policies (pooling, fill rates, and sequential numbering) are governed by the FCC's delegation of authority to the states. In recognition of the severity of the numbering crisis in California, the CPUC has aggressively petitioned the FCC for additional authority. As a result, the FCC has delegated authority to plan and implement area code changes, as well as authority to implement number conservation measures. On April 26, 1999, the CPUC filed a petition with the FCC requesting authority to institute number pooling trials and other number conservation measures within the state to better manage this public resource. On September 15, 1999, the FCC granted that petition, allowing the CPUC to institute mandatory number pooling on a trial basis, deploying it sequentially in one MSA at a time. When the FCC granted the CPUC the authority to deploy various numbering resource optimization strategies, including the authority to institute thousand-block numbering pooling trials, it also clarified that California's authority will be superseded by future national measures adopted by the FCC. On March 31, 2000, the FCC released the Numbering Resource Optimization Report and Order and Further Notice of Proposed Rulemaking (NRO Order).13 The NRO Order sets forth rules for defining numbers, forecasting, tracking and auditing companies' use of numbers, and for conservation measures associated with number usage, including but not limited to number pooling. The definitions for numbers and timelines for aging and reserved numbers that were adopted in that order have been incorporated into the utilization data contained herein. With the release of the NRO Order, the FCC adopted a number of administrative and technical measures that will allow it to monitor more closely the way numbering resources are used and to promote more efficient use of numbering resources. In particular, the FCC adopted a nationwide system for allocating numbers in blocks of one thousand, rather than ten thousand, wherever possible, and announced its intention to establish a plan for national rollout of thousands-block number pooling. Because the FCC recognized that state thousand-block number pooling trials underway might not conform to the national standards set forth in the NRO Order, the FCC gave state commissions until September 1, 2000 to conform their thousands-block number pooling trials to the national framework. One requirement imposed in California which differs from the national standards is the requirement that companies meet a 75% fill rate in each block before they may receive an additional block from the pooling administrator. The CPUC recognized the 75% fill rate as a critical factor in the success of the 310 pooling trial and petitioned for a waiver of compliance with the national rules. On August 31, 2000, the FCC issued an order granting the CPUC authority to continue to use its pooling rules until the FCC decides on the merits of the petition, or until December 31, 2000, whichever occurs sooner. This allows California to continue applying the 75% utilization rate in its number pooling efforts. The NRO further constrains the CPUC by concluding that the rollout of thousand-block number pooling should first occur in area codes that are located in the largest 100 MSAs. In its comments prior to the release of the NRO, the CPUC had argued that California would be precluded from exploring whether number pooling could alleviate the crises for number resources in many parts of the state that are located outside the top 100 MSAs. The CPUC believes the FCC should delegate authority to the states to order deployment of LNP. This grant of authority to California would make pooling possible throughout the state. Currently, state commissions are constrained by the FCC from establishing an area code specifically for wireless telecommunications services. On April 26, 1999, the CPUC filed another petition with the FCC requesting that the CPUC be granted authority to create service-specific or technology-specific area codes. In the 415 area code, there are 21 wireless carriers holding 157 prefixes. If the CPUC were allowed to create a separate area code for those companies, the 157 prefixes in the 415 area code could be reassigned to other phone uses, thus prolonging the life of the existing area code. To date, the FCC has not acted on the CPUC's petition. On September 28, 2000, Governor Davis signed into law Senate Bill (SB) 1741, authored by Senator Bowen. SB 1741 requires the CPUC to request authority from the FCC to require telephone corporations to establish technology-specific area codes based on wireless and data communications, and to permit 7-digit dialing within both that technology-specific area code and the underlying pre-existing area code or codes. The bill requires the CPUC to use any authority so granted unless it makes a specified finding that there is reason not to do so. The legislation also prohibits the CPUC from implementing any authority granted by the FCC in a manner that impairs number portability. The Petition that the CPUC filed with the FCC in April 1999 fulfills the technology-specific area code requirement set forth in the bill. The bill also prohibits the CPUC from approving new area codes unless a telephone utilization study has been performed and all reasonable telephone number conservation measures have been implemented. This utilization study fulfills the telephone utilization study portion of SB 1741. Before requiring the residents and businesses of the 415 area code to undergo another area code change, the CPUC recognized the necessity of determining the amount of telephone numbers that are in use and yet to be used. To that end, the CPUC instituted a 415 utilization study and required companies to provide usage data to the CPUC as of April 30, 2000. The TD contracted with NeuStar to collect the data, which submitted the aggregated data in its entirety to TD on August 18, 2000. The study parameters and filing requirements appear in Appendix A, as well as a list of companies who have been allocated numbers in the 415 area code.
Of the 7.7 million numbers in the 415 area code, companies hold 6.6 million. The other 1.1 million numbers have yet to be assigned to companies. The CPUC's utilization study found that of the 6.6 million numbers held by companies, 2.8 million remain unused in their inventories. Therefore, 3.9 million numbers in the 415 area code remain unused. A portion of these unused numbers can be made available for use by all companies, either through pooling or through the monthly lottery allocation process. In addition, companies have reported 3.8 million numbers as unavailable. A portion of these unavailable numbers can be used more efficiently if the recommendations contained in this report are implemented.
The CPUC asked forty-nine companies, holding 658 prefixes (6.6 million numbers) in the 415 area code, to report their utilization data with a reporting cut-off date of April 30, 2000. Table 2-1 shows the distribution by incumbent local exchange carriers (ILECs), competitive local exchange carriers (CLECs)14, and wireless carriers in 14 rate centers and one special code area. 15 Of the 49 companies, 45 submitted utilization data; one company submitted data too late to be included in the summaries provided by NeuStar. Staff has considered this late filer in its analysis. The remaining four companies holding 21 prefixes in the 415 area code are no longer offering service in the 415 area code. CRL Network Services and GTE Communications Corporation wrote to NeuStar that they were returning all their prefixes in California and the 415 area code, respectively. Geotek Communications verbally informed NeuStar that it is no longer conducting business in California. NeuStar was notified that Conxus Spectrum is in bankruptcy. NANPA has confirmed that GTE Communications Corp. and CRL Network Services have returned all nineteen of their 415 prefixes. However, Geotek and Conxus, each holding one prefix, have not yet returned their prefixes. Recommendation for Prefixes Held by Companies No Longer in Service
The 415 area code has 3.9 million unused numbers. Of these unused numbers, TD found that companies held 2.8 million numbers in their inventories.16 These numbers held in inventory are currently not used for any purpose but held in anticipation of future need. The remaining 1.1 million unused numbers are not yet assigned to companies: 360,000 numbers have been set aside for number pooling17 and 720,000 numbers are available for allocation in the 415 monthly lottery. The breakdown of available numbers is shown in the table below. ______________________________________________________________________________ Table 2-2 Summary of Available Numbers Wireline Carriers 2,144,757 Wireless Carriers 650,906 Type 1 Carriers18 48,061 Total Available/Unused Numbers Held by Carriers 2,843,724 Numbers Set Aside for the 415 Pooling Trial 360,000 Numbers Available for the 415 Lottery 720,000 Total Available Numbers in the 415 Area Code 3,923,724 ______________________________________________________________________________ Not all of the 3.9 million unused numbers are immediately available to every company that wants numbers. Of the 3.9 million, a maximum of 1.7 million numbers19 are available to all companies via the pooling trial or the lottery. The remaining 2.2 million numbers are only available to the companies who hold them. As shown in the table below, the CPUC could shift the availability of numbers from one category to another by adopting the recommendations20 in this report. Of the 3.9 million unused numbers, those actions could result in making a maximum of 3.1 million numbers21 available to all companies with the remaining 0.8 million numbers available to the companies who hold them.
Current technology requires a company to be LNP-capable in order to donate numbers for another company to use. All wireline carriers in the 415 area code are required to be LNP capable.22 Wireline carriers hold 2.1 million unused numbers in the 415 area code. In order for the unused numbers to be retrieved from company inventories, the FCC requires these unused numbers to be retrieved from blocks which are 10% or less contaminated.23 1.4 million of wireline companies' 2.1 million unused numbers are contained in 1,444 thousand-blocks held by LNP-capable carriers and are 10% or less contaminated. However, not all of these 1.4 million numbers can be retrieved from companies' inventories because companies need to have enough numbers to meet anticipated future need.24 Both the CPUC and the FCC have determined that six-months of inventory is a reasonable quantity to hold for future use. Of these 1,444 thousand-blocks eligible for donation, 804 blocks remain with companies for their six-month inventory while 640 blocks are now available for pooling. The remaining 724,000 of the 2.1 million unused numbers cannot be retrieved, either because the numbers are in blocks greater than 10% contaminated or because they are in non LNP-capable blocks. However, companies can immediately use these numbers to provide service to their customers or meet other needs. Wireline carriers hold 664,000 numbers in blocks that are more than 10% contaminated.25 Non-LNP capable carriers hold 50,000 of the 2.1 million unused numbers. Special use codes26 are generally not LNP capable and constitute 10,000 of the 2.1 million unused numbers. Wireless carriers hold 651,000 unused numbers in the 415 area code. Of these unused numbers, 312,000 are in blocks that are 10% or less contaminated, while 339,000 numbers are in blocks greater than 10% contaminated. Until wireless carriers become LNP-capable in November 2002, none of these numbers may be reallocated to other companies. In the interim, wireless carriers may assign these numbers to their own customers. The CPUC requires each company participating in the 415 number pool to donate blocks that are 10% or less contaminated, excluding those retained for the six-month inventory.27 TD analyzed the 415 utilization data to determine the availability of numbers within blocks if different contamination thresholds were employed in the number pool. The following table summarizes available numbers by contamination rates by rate center for wireline carriers. _____________________________________________________________________________ Table 2-4 Available Numbers by Percentage Contamination for LNP Capable Wireline Carriers
______________________________________________________________________________ The first two columns of Table 2-4 show the potential numbers available to the pooling trial, except for those numbers kept for companies' six-month inventory, under current rules. Available numbers in one rate center cannot be used in another rate center. Table 2-4 shows that all rate centers have available numbers that companies could donate to the pool. The last three columns of Table 2-4 capture available numbers in blocks that are greater than 10% contaminated but no more that 25% contaminated. Under the current 415 number pool rules, companies retain thousand number blocks that are more than 10% contaminated. Increasing the contamination rate threshold from 10% to 25% would potentially free up an additional 128,00028 numbers for use in the number pool. TD cautions that although Table 2-4 shows potential results from increasing allowable contamination levels, further analysis and input from the industry may be necessary to determine accurately the quantity of additional numbers that can be added to the pool while still leaving companies with a six-month inventory. As shown by Table 2-4 and also shown graphically in Table B-3 of Appendix B, each rate center has available numbers from blocks of differing contamination levels up to 25%. The table shows that if the contamination level was increased from 10% to 25%, more unused numbers exist in each rate center that potentially can be donated to the pool. Recommendation from Block Contamination Analysis of Wireline Carriers
Under current FCC rules, cellular and PCS companies are exempt from number pooling until November 2002 when they must become LNP-capable. The FCC has indefinitely exempted paging companies from becoming LNP capable.29 Table 2-5 shows available numbers in differing contamination levels held by wireless carriers. Wireless carriers hold 312,000 available numbers in blocks which are 10% or less contaminated as shown in the first two columns of Table 2-5. Wireless carriers also have 56,000 available numbers in blocks with contamination levels greater than 10% but less than 25% as indicated by the last three columns of Table 2-5. _____________________________________________________________________________ Table 2-5 Available Numbers by Percentage Contamination for Wireless Carriers
________________________________________________________________________ Because the FCC has granted wireless carriers an extension of time to implement LNP, no wireless carriers serving the 415 area code are capable of implementing LNP. Thus, wireless carriers cannot participate in number pooling at this time, resulting in 368,000 unused numbers in blocks between 0% to 25% contaminated in the 415 area code. Recommendations from Block Contamination Analysis for Wireless Carriers
When blocks are slightly more than 10% contaminated, those blocks cannot be donated to the pool. TD found instances where companies contaminated blocks just above 10%. The CPUC's rules on sequential numbers and fill rate practices promulgated in Decision 00-07-052 are designed to prevent this problem from occurring in the future. Fill rates mitigate contamination by requiring companies to use contaminated blocks up to 75% before they can receive additional blocks. Sequential numbering minimizes contamination by requiring companies to begin assignment in the next thousand block only after a 75% fill rate has been attained in the prior block. Where companies possess significant available numbers in a given rate center, these two efficiency measures could prevent the opening of new blocks or prefixes. Companies reported utilization data as of April 30, 2000. The sequential numbering and fill rates decision was issued in July 2000. Therefore, TD does not expect carriers to continue contaminating blocks unnecessarily. Recommendation for Block Contamination Issues Affecting All Companies
Decision 00-07-052 directed companies to return prefixes that are held unused for more than six months.31 As shown in Tables 2-4 and 2-5, wireline carriers and wireless carriers hold 1,087,000 unused numbers and 214,000 unused numbers, respectively, in the 0% contaminated blocks. Of these 0% contaminated blocks, 370,000 numbers are in 37 whole prefixes, i.e. spare prefixes, while 931,000 numbers scattered throughout many different prefixes. The following table shows the breakdown between wireless and wireline carriers. ________________________________________________________________________ Table 2-6 Breakdown of Numbers in 0% Contaminated Blocks ________________________________________________________________________ Avail. Nos. in Avail. Nos. in Avail. Nos. in 0% Contain Blocks Spare Prefixes Differing Prefixes Wireline Carriers 1,087,000 300,000 787,000 Wireless Carriers 214,000 70,000 144,000 370,000 ________________________________________________________________________ As shown above, 370,000 numbers in 37 prefixes can possibly be reclaimed if not used within six months. However, as a result of the FCC's March 31, 2000 NRO order, the NANPA no longer has sole authority to reclaim unused prefixes. The FCC granted authority to state regulatory commissions to investigate and determine whether code holders have activated prefixes within the allowed time frames, and directed the NANPA to abide by the state commission's determination to reclaim a prefix if the state commission is satisfied that the code holder has not activated the prefix within the time specified in the NRO order.32 Substantial cooperation between the CPUC and the NANPA will be required in order for the CPUC to exercise this new authority and determine whether a prefix should be reclaimed. Furthermore, the NANPA must still perform the mechanical steps to reclaim prefixes once the CPUC directs the NANPA to reclaim a prefix. Recommendation for Reclamation of Prefixes
In the following sections, the TD recommends a series of policies designed to require companies to use unavailable numbers more efficiently. These policies would potentially free more numbers for use in the pool, to be allocated through the monthly lottery, or to be otherwise used by companies. Companies report that 3.8 million numbers in the 415 area code are either assigned to customers or are used by companies for reserved, administrative, intermediate and aging purposes. Assigned numbers are those numbers that are currently being used by customers or equipment. Companies commonly refer to these numbers as "unavailable". Unavailable numbers include not only those actually in use by customers, but also the following categories:
In the 415 area code, 3.0 million assigned numbers exist with 2.3 million assigned to wireline carriers and 0.7 million assigned to wireless carriers. The percentage of assigned numbers to total numbers held by companies is shown in the table below. ________________________________________________________________________ Table 2-7 Assigned Numbers to Numbers Held by Companies (in millions) ________________________________________________________________________ Assigned Numbers Nos. Held by Companies Percentage Wireline Carriers 2.3 5.0 45.8% Wireless Carriers .7 1.6 46.7% ________________________________________________________________________ Non-working wireless describes numbers assigned to wireless customer equipment, but which are not yet working. These numbers are considered as a sub-category of assigned numbers. For example, wireless carriers sometimes pre-package a cellular telephone with an assigned telephone number for sale to customers. Although the number is assigned, it will remain inactive until a customer purchases the telephone. Only one company reported 7,000 assigned numbers in the non-working wireless category for the 415 area code. While the quantity of non-working wireless numbers reported generally is low, this sub-category of assigned numbers could increase because there are no restrictions on the number of days that a wireless company can hold these numbers, causing many numbers to remain idle for an unspecified period of time. The CPUC should consider several options to improve inventory management of non-working wireless numbers. One option is for the CPUC to require companies to return these numbers to the unassigned category after 45 days (similar to the requirement the CPUC has established for reserved numbers). Therefore, additional numbers would be freed for re-assignment. Since pre-packaged equipment with non-working assigned numbers is often located in various retail outlets, another option is for the CPUC to require companies to maintain inventory records of all such retail/wholesale equipment with the associated numbers assigned and to require regular (weekly/monthly) updating of these inventory records. In addition, the CPUC should continue to monitor non-working wireless numbers in the near term to track compliance with staff's recommendations. Recommendations For Treatment of Non-Working Wireless
Interim Number Portability (INP) is the ability to move telephone service from one service provider to another using Remote Call Forwarding (RCF), Direct Inward Dialing (DID), or equivalent means. 33 Prior to the implementation of permanent LNP, companies entered into INP arrangements to enable the transfer of customers from one company to another. Under these INP arrangements, two telephone numbers are associated with each customer. LNP eliminates the need for two telephone numbers for each customer when the customers change companies because customers can take their numbers with them. Since the 415 area code is included in one of the top 100 MSAs in the nation, all wireline carriers should have became LNP-capable by the end of December 1998.34 The only companies who reported INP numbers were ILECs. They reported a total of 271 INP numbers in the 415 area code. Since all the reported INP numbers were from ILEC's and none were from their competitors, it does not appear that INP exists in the 415 area code to facilitate competition for customers. Thus, TD questions why any INP numbers exist in this area code. Switching to LNP technology and eliminating INP will free up half of the 271 numbers that are currently dedicated to INP. Recommendation for INP-Related Conservation Measures
Historically, the telecommunications industry has designated certain prefixes for special uses, usually to an incumbent local exchange carrier (ILEC). These include numbers for recorded public information announcements such as time-of-day and weather forecasts, high-volume call-in numbers, and emergency access35 numbers. These prefixes are not made available for general commercial use and as such, numbers that are in actual use lie vacant. In 1999, companies decided not to duplicate the special use codes in each area code. Concerned that this process could adversely affect the public, the CPUC directed that prefixes should be duplicated in each new area code. The utilization study shows that six prefixes are dedicated for special uses, one each for high volume calling, directory assistance, 700 IntraLata Presubscription, time, emergency preparedness and weather service. Except for high volume calling, companies reported 50,000 assigned numbers in five prefixes. TD questions the necessity of assigning an entire prefix for each purpose. Furthermore, having multiple special use codes is an inefficient use of numbers in the 415 area code as well as in other area codes in California. For example, if the 555 prefix currently reserved only for directory assistance36 could be used to provide time, weather, emergency service and 700 IntraLata Presubscription, then four more prefixes could be returned for reallocation in the 415 area code. Similarly, expanded use of the 555 prefix throughout the state could result in more returned prefixes in other area codes. TD recommends that the CPUC initiate an investigation into broader use of the 555 prefix in California. The CPUC should further analyze the option of obtaining standard 555 numbers in every California area code to provide time, emergency preparedness, and weather information at no additional cost to customers. With respect to high volume calling, the utilization study indicates that the prefix dedicated to this service is not fully utilized37. Out of the 10,000 numbers allocated for High Volume Calling, only 90 are actually in use. The remainder of these numbers, however, can be a potential source of numbers for pooling. TD recognizes that there may be technical issues involved in obtaining these numbers. TD recommends that the CPUC solicit comments in the Local Competition proceeding regarding technical issues that would prevent the high volume prefix from being reclaimed and placed in the 415 number pool. In addition to the under-utilization of these numbers, the distribution of these numbers among various blocks also demonstrates inefficient utilization practices. The 90 numbers are contained within six different 1,000 number blocks. Consistent with our statewide conservation measures, adopted in July, TD recommends that CPUC require companies to assign these numbers sequentially within each 1,000 block. Recommendations for Special-Use Prefixes
Companies "set aside" numbers for future use by customers.38 Previously, industry number assignment guidelines allowed companies to reserve a prefix for up to 18 months for customer future use.39 The FCC's NRO Order modified the number reservation period to 45 days. This 415 utilization study incorporated the FCC's 45-day requirement. The FCC later issued an extension until December 1, 2000 for companies to comply with the 45-day rule40. The extension allows companies time to upgrade their number tracking mechanisms, which tally the quantities of reserved numbers they hold. While companies reported a total of approximately 316,000 reserved numbers in the 415 utilization study41, it is unclear whether the reported amount is accurate. Since companies could reserve numbers for longer than 45 days prior to the NRO Order, the quantity of reserved numbers reported may be overstated and, correspondingly, the quantity of available numbers reported may be understated. Wireline carriers reported approximately 305,000 reserved numbers. If the quantity of reserved numbers held by wireline carriers can be minimized, additional numbers could be available for reallocation in the 415 number pool42 and for immediate use by the companies from within their own number inventories. Currently there are no limitations on the quantity or percentage of numbers a company can classify as reserved before requesting new number resources. Similarly, companies are not required to use their reserved numbers stock before they can request that new numbers be allocated to them. The situation in the San Francisco-Central rate center illustrates this problem. In that rate center, wireline carriers predict that they will need 357,000 telephone numbers allocated to them from the 415 pool over the next 18 months43. At the same time, wireline carriers reported in the study that they hold 190,038 reserved telephone numbers in that same rate center. In another example, one company reported that it held nearly 9,300 reserved telephone numbers and only assigned 40 numbers to customers in one prefix in the San Francisco Juniper rate center; but it forecasted that it needed 9,000 numbers in that rate center from the 415 pool over the next 18 months. If the CPUC orders efficient use practices specific to reserved numbers, carriers will more efficiently use number resources. Wireless carriers reported 11,000 reserved numbers in the 415 area code. While these companies cannot currently participate in number pooling, the CPUC should also adopt efficient number use practices specific to the reserved numbers these companies hold. Such practices could immediately free up numbers within these companies' inventories for use and, thus, could slow the rate at which new prefixes are allocated to these companies. Once wireless carriers are able to participate in number pooling, these practices could have the same efficiency gains as those for wireline companies. Recommendations for Reserved Numbers
Administrative numbers are those not assigned to customers and are generally used for a wide range of applications for companies' internal use, including testing, internal business, and other network purposes. Companies self-reported slightly more than 44,000 administrative numbers in the 415 area code. Wireline carriers hold approximately 30,000 of these numbers and wireless carriers hold approximately 14,000 of these numbers. The utilization study revealed that there is a potential for companies to over-assign administrative numbers within a particular 1,000 block, prefix or rate center in the 415 area code. For example in the Belvedere rate center, a large wireline carrier reported 51 administrative numbers while a smaller wireline carrier reported 600 administrative numbers. Moreover, the large wireline carrier reported serving nearly 13,000 customers in that rate center and the smaller wireline carrier reported serving 100 customers. Although one might assume that a greater need for administrative numbers exists for companies serving more customers in a given rate center, this example illustrates that companies are not necessarily using the number of customers as a criteria for determining how many administrative numbers are needed. Also, the high level of administrative numbers prevents the smaller company in the example from donating certain blocks to the 415 number pool when the blocks are not otherwise used to serve customers44. Given the variances in the levels of administrative numbers between companies, it is unclear what basis companies use for placing numbers in this category. The CPUC should therefore pursue an investigation in this area. In addition, some companies randomly assign administrative numbers and are thereby wasting number resources. Companies could conserve numbers by changing the way in which these types of numbers are assigned. First, some companies randomly assigned administrative numbers in multiple thousand blocks within the same prefix when they have available number resources to centralize those assignments within one or a few thousand blocks. This means that wireline carriers contaminated multiple thousand blocks and prevented them from being candidates for reallocation to other companies in the 415 number pool or other LNP-based conservation measures. For wireless carriers, this practice means that they will already have contaminated multiple thousand blocks and prevent them from being donated once they can participate in number pooling, or from being used in other LNP-based conservation measures. Second, some companies holding multiple prefixes in a given rate center randomly assign administrative numbers throughout different prefixes when they have the available number resources to centralize the assignment of these numbers in one prefix in that rate center. TD questions the need for companies to hold multiple prefixes in a given rate center, when they are using multiple prefixes to serve their internal purposes and not necessarily to serve customer needs. Moreover, since these companies contaminated many more thousand blocks in multiple prefixes versus in one prefix, this practice exacerbates the problem of contaminating number resources and preventing them from being donated to the pool, as described above. Recommendations for Administrative Numbers
The "intermediate number" category is a new one only recently introduced by the FCC in its NRO Order. This category tracks numbers that companies make available for use by another telecommunications carrier or non-carrier entities. Companies reported approximately 206,000 intermediate numbers in use in the 415 area code. Wireline carriers hold close to 121,000 of those numbers and wireless carriers hold just over 85,000. The quantity of intermediate numbers varied significantly among rate centers in the 415 area code45. Since the intermediate number category is new, the quantity of numbers reported by companies may increase over time as more companies become familiar with this category. TD notes that this number use category has the potential for abuse by companies if they use significant quantities of number resources for intermediate purposes and take away available resources that could be assigned to customer uses. Therefore, TD recommends the CPUC continue to monitor intermediate number use in the future. Recommendations for Intermediate Numbers
Wireline carriers allocate numbers for use by wireless carriers through Type 1 interconnection agreements.46 Because wireline and wireless carriers share responsibility for Type 1 numbers, both types of carriers reported on these numbers. Wireline carriers report Type 1 numbers in the Intermediate category since they provide these numbers to another company. Wireless carriers report on the same numbers in greater detail since they actually use these numbers, placing them in the Assigned, Administrative, Reserved, Intermediate, Aging, or Available categories. Reporting of Type 1 numbers is complicated as wireline and wireless reports often do not match. In the 415 area code, nearly one-third of all Type 1 numbers are unaccounted for or mismatched.47 Wireline donor carriers do not monitor wireless Type 1 inventories, nor do they proactively reclaim unused Type 1 numbers from wireless carriers. TD recommends that wireline carriers perform an annual inventory check on Type 1 numbers and reclaim any unused Type 1 numbers within 60 days.48 As described in Chapter 1, state and federal mandates require most companies to demonstrate efficient numbering practices before becoming eligible to obtain more numbers. In contrast, Type 1 wireless carriers have no check on their number use because they draw numbers directly from wireline companies, therefore avoiding the scrutiny of the official number and pooling administrators. TD recommends that Type 1 wireless carriers be subject to number conservation measures and a system to ensure compliance. Improved Type 1 number management is particularly crucial because unlike numbers held by most wireless carriers, Type 1 numbers are eligible for number pooling.49 Therefore, Type 1 numbers are not only available to be recovered, but these numbers will also contribute to the success of pooling. Despite the problems with reporting, TD has identified three blocks of numbers in the 415 area code that may be eligible for donation to the pool.50 The CPUC should recognize Type 1 numbers as a resource for number pooling and take steps to have wireless carriers donate excess blocks to the pool. Recommendations for Type 1 numbers:
The FCC's NRO Order, adopted March 17, 2000, defines aging numbers as disconnected numbers that are not available for assignment to another end user or customer for a specified period of time. Consistent with the INC Guidelines, the CPUC adopted the FCC upper-limits for aging numbers as 90 days for residential numbers and 365 days51 for business numbers. In the 415 area code, there are approximately 190,000 numbers in aging, representing 5% of the total unavailable numbers. While most service providers track aging telephone numbers by business and residential categories, Pacific Bell, the largest single holder of telephone numbers in the 415 area code, does not differentiate between business and residential customers when tracking aging numbers. Since Pacific Bell did not differentiate, the consultant chose to place those in the business category. Therefore, the vast majority of aging numbers is categorized in the business category and may give a false impression that most of the aging numbers are business numbers. Because Pacific Bell does not differentiate between residential and business in reporting aging numbers, it is uncertain whether the maximum 90-day aging period for residential numbers is governing their aging policy, and whether at the end of the 90-day period, Pacific Bell is properly reassigning these numbers to the available category. Pacific Bell may be allowing residential numbers to be in the aging category for nine months longer than is permissible under both FCC and CPUC rules. A higher percentage of aging numbers occurs in the wireless category, as compared to the wireline category. Aging numbers represent 8.1 percent of the total unavailable wireless numbers, or about 74,000 numbers. Aging numbers represent 4.0 percent of the total unavailable wireline numbers, about 116,000 numbers. This number is consistent with the higher turnover or "churn" that occurs in the wireless industry. Table G-1, in Appendix G, shows the breakdown of aging numbers by wireless and wireline categories. Recommendation for Aging Numbers
The data analyzed in this 415 utilization study was self-reported by companies. Given the area code crisis in California, the CPUC should audit this data for two reasons. First, verifying number usage data is important to ensure that the public resource of telephone numbers within area codes is efficiently managed. Second, audits will help verify whether companies are complying with CPUC and FCC rules for number usage. Recommendations for Audits
Many of the recommendations in Chapter Two resulted directly from the analysis of the utilization data and address actions that the CPUC should undertake to make additional numbers available for either pooling or for the regular monthly lottery. The recommendations contained in this chapter suggest additional conservation measures as required by Public Utilities Code Section 7935(a). The CPUC could adopt the following conservation measures in the 415 area code and statewide: LNP- related actions, Unassigned Number Porting, Rate Center Consolidation, and prefix sharing. In addition, California should build upon the success of number pooling in 415 by setting up trials in other area codes. When applied, these conservation measures would result in uniform policies which will cause companies to use numbers more efficiently across California and would minimize customer confusion. Number pooling is an excellent method of number conservation. The CPUC worked aggressively to bring number pooling to California and the results have been dramatic. Pools are underway in the 310 and 415 area codes and the CPUC plans to roll out the maximum possible number of pools before national number pooling begins. In the 310 area code, number pooling has been in effect for over six months. The pool has satisfied the numbering needs of all companies participating in the pool without opening a single prefix.52 Prior to pooling, 98 prefixes would have been opened to satisfy the demand for numbers. Number pooling has avoided the need to open prefixes and extended the life of the 310 area code by at least 15 months.53 The positive experience in 310 is mirrored in 415. The 415 pool opened July 29, 2000. Again, without opening a single prefix, the numbering needs of companies have been met.54 After just two months, pooling has saved 12 prefixes. Pooling benefits not only the public but the companies as well by reducing the time necessary to acquire numbering resources. Without pooling, activating new numbers takes at least 66 days.55 With number pooling, companies can activate new numbers in three weeks. In California, number pooling has worked well because companies have met their numbering needs from blocks numbers other companies donate to the pool. The CPUC has set aside prefixes in each area code that will be used to replenish the pools if and when donations are no longer sufficient. There are a limited number of set aside prefixes, so it is crucial that these prefixes be opened only when there is truly a need. If donated numbers are not sufficient to meet the companies' forecasts, a new prefix may need to be opened. Industry guidelines suggest replenishing a pool at least 66 days in advance when the forecast shows a company will need more numbers than the pool has on hand. This presents a problem, as companies in California have, on average, forecast seven times more numbers than they will take from the pool. In many cases the forecasts are incredibly exaggerated. For example, in the San Francisco Central Rate Center in the 415 area code, companies predicted they would use 75 blocks in the first two months of the pool. However, they have used none. Had the pool administrator opened prefixes based on the forecast, the prefixes would lie unused in the rate center.56 The CPUC has thus far prevented prefixes from being unnecessarily opened by ordering the Pooling Administrator (PA) to consult with TD staff prior to opening any new prefix. However, the CPUC believes this issue should be addressed for the long term. Industry guidelines encourage companies to over-forecast, because a company can only be assured numbers for which it forecasts.57 In essence, a company could be penalized for under-forecasting. Since there is no penalty for over-forecasting, it is in companies' interests to err on the side of over-forecasting. TD recommends the CPUC develop specific rules guiding company forecasting. TD also recommends that the PA take historical usage into account when determining when to open a fresh prefix of 10,000 numbers. Recommendations for Number Pooling
Companies were required to file Donation Identification Reports with the PA on May 2, 2000 for the 415 number pooling trial. On the same date, the CPUC requested reports from the companies regarding block donations and blocks held for six-month inventory. The pool started on July 29, 2000 with 565 donated blocks. Because the CPUC did not receive reports on block donations and blocks held for six-month inventory from four companies in the 415 area code, TD subsequently contacted these companies. As a result of these contacts, three companies donated an additional 75 blocks to the 415 pool. Optel California Telecom has yet to file with the CPUC the block donations and blocks held for six-month inventory. TD has confirmed with the PA that the additional 75 blocks from the three companies have been donated and confirmed that the PA has not yet received any reports from Optel California Telecom. The latest update on the numberpool.com website shows 18 blocks assigned from the pool as the pool started on July 29, 2000. A total of 622 blocks are available for assignment as of August 18, 2000. Adding the set aside 360 blocks, a maximum of one million numbers is available for pooling. Further donations can still come into the pool. Recommendation for non-compliant companies
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