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Before The Public Utilities Commission Of The State Of California
REPORT ON THE 818 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 818 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 DeLa Cruz Maryam Ebke
CHAPTER TWO: 3.9 MILLION UNUSED NUMBERS IN THE 818 AREA CODE
CHAPTER THREE: NUMBER POOLING AND OTHER NUMBER CONSERVATION MEASURES
EXECUTIVE SUMMARY Like much of the country, California currently is experiencing a numbering crisis. From 1947 to January 1997, the number of area codes in this state increased gradually from 3 to 13. During the next three years, however, the number of area codes in California nearly doubled. By the end of 1999, California had 25 area codes statewide. The California Public Utilities Commission (CPUC) recently has implemented several measures intended to ensure efficient use of telephone numbers. Without these measures, the CPUC projects that 16 more area codes would need to be opened by the end of 2002, resulting in a statewide total of 41 area codes.
FINDINGS The 818 area code contains approximately 7.9 million telephone numbers available for consumer use. These numbers are available to telecommunications companies which obtain the numbers from the North American Numbering Plan Administrator (NANPA)1, and in turn, assign the numbers to their customers for their immediate use. Alternatively, companies may reserve numbers for future use, or retain numbers for some internal (administrative) use. Some companies provide blocks of numbers to resellers or "dealers", which then assign those numbers to customers. The FCC deems numbers which companies allocate to resellers to be "intermediate" numbers. In addition, each assigned number, after disconnection, must "age" during a transition period before assignment to the next customer. Many companies have inventories of numbers in the "aging" process. Finally, some numbers are not available for public use, as they have been set aside for emergency purposes, for technical network support, or for other reasons. The FCC has determined that numbers in these five categories - assigned, administrative, reserved, intermediate, or aging - are unavailable, either because they are already in use or are designated for some present or future use. Of the 3.9 million available numbers, 1.23 million have been set aside by the CPUC to use in a lottery for companies seeking numbers. Companies possess the remaining 2.7 million unused numbers. Wireline carriers, such as Pacific Bell and many competitive local exchange carriers, hold roughly 1.8 million available numbers, while wireless carriers hold approximately 834,000 available numbers. Because there is no "number pool" 2 in the 818 area code, all the 2.7 million unused numbers are left stranded in company inventories. Should a pool be implemented, the FCC has determined that wireless carriers do not have to participate in pooling 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 contaminated4, 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 month. The study further finds that a maximum of 3.2 million numbers5 could be available to all companies through pooling if a) the companies were required to donate blocks with higher contamination levels in a pooling trial and b) wireless carriers were required to participate in a pooling trial. 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 4.0 million numbers as unavailable. TD staff recommends 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 818 Area Code Report recommendations are summarized in Appendix I. CHAPTER ONE: OVERVIEW OF NUMBERING
California is currently experiencing an explosive demand for telephone numbers and area codes. The increased demand for numbering resources 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 company6 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 companies7 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 sixteen more area codes would need to be opened by 2002. With more and more companies needing numbers of their own, new area codes are not necessarily the best solution. The 818 Numbering Plan Area (NPA) is one example of area code proliferation in California. The 818 area code was implemented in 1984 when it was geographically split from the 213 area code, one of the three original area codes assigned to California in 1948 when the North American Numbering Plan was implemented. In June of 1997, the 818 area code was geographically split with the implementation of the 626 area code. The current 818 area code serves the greater San Fernando Valley area in Southern California. Despite the introduction of an additional area code to provide relief to the 818 area code, the North American Numbering Plan Administrator (NANPA) determined the 818 area code required further relief in early 1998. On October 7, 1999, by Decision 99-10-022, the CPUC ordered the implementation of a variety of conservation measures to address the exhaustion of numbers in the 818 area code. As a back-up plan, the CPUC adopted a geographic split, but deferred an implementation date until and unless it can be determined that number conservation measures have failed to provide enough numbering resources to facilitate competition in the 818 area code. 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 818 lottery began May 1997. Currently, the CPUC distributes three prefixes (two initial and one growth8) in the monthly 818 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 the following month's lottery in the order they were drawn. Once every company requesting a prefix has received numbers, a new drawing is held and additional companies are eligible to receive prefixes. The CPUC has allocated 27 prefixes in the 818 area code through this process between January 1, 2000 and August 31, 2000. As of the utilization study date of April 30, 2000, there were 123 prefixes available for assignment. By the end of August 2000, 115 prefixes were available for assignment in the 818 area code. 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, beginning in December 1999, suspended all plans for new area codes previously approved. At the same time, the CPUC adopted number conservation measures, including the establishment of number pooling trials, fill rates and sequential numbering. The CPUC, with FCC approval, began pooling trials in four area codes in 2000, in order to boost the efficiency of phone number allocation. Number pooling allows telecommunication providers to receive numbers in smaller blocks than the traditional 10,000 numbers, thus enabling multiple providers are able 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.10 Thirteen of the top 100 MSAs are located in California; the 818 area code is in one of them. 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 pooling. In the area codes with 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. There is currently no number pooling trial underway in the 818 area code. The CPUC issued a Proposed Pooling Schedule for 2001, which included a pooling trial for the 818 area code to begin in October 2001. The ALJ Ruling soliciting comments on the proposed schedule was issued on June 27, 2000. Reply comments have been received and are being considered. No final pooling schedule has been issued to date. While 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 that these policies will potentially free more numbers for use in a potential 818 number pool, to be allocated through the lottery, or to be otherwise used by companies. Indeed, these measures 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 818, CPUC staff has observed that the demand for growth prefixes in each month's lottery has declined. The FCC has exclusive jurisdiction over numbering in the U.S. Therefore, the CPUC's number conservation and allocation policies (pooling, lottery, 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 own 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 of 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 authority to create service-specific or technology-specific area codes. In the 818 area code, wireless carriers hold 199 prefixes. If the CPUC were allowed to create a separate area code for those companies, these 199 prefixes in the 818 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 818 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 an 818 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 818 area code. CHAPTER TWO: 3.9 MILLION UNUSED NUMBERS IN THE 818 AREA CODE Of the 7.9 million numbers in the 818 area code, companies hold 6.7 million. The other 1.2 million numbers have yet to be assigned to companies. The CPUC's utilization study found that of the 6.7 million numbers held by companies, 2.7 million remain unused in their inventories. Therefore, 3.9 million numbers in the 818 area code remain unused. A portion of these unused numbers can be made available for use by all companies, either through a potential number pool or through the monthly lottery allocation process. In addition, companies have reported 4.0 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 fifty-five companies in the 818 area code to report their utilization data, with a reporting cut-off date of April 30, 2000. Table 2-1 shows the distribution of prefixes by type of company: incumbent local exchange carrier (ILEC), competitive local exchange carrier (CLEC), 14 and wireless carrier.
Of the 55 companies, 51 companies submitted utilization data; one company submitted data too late to be included in the summaries provided by NeuStar. TD has considered this late filer in its analysis. CRL Network Services wrote to NeuStar that it was returning all its prefixes in California. NANPA has confirmed that CRL Network Services has returned all five of its prefixes in the 818 area code. The remaining three companies, of the 55 companies, failed to report utilization data. These three companies hold four prefixes. Table 2.2 summarizes this information. ________________________________________________________________________ Table 2-2 Non-Reporting Carriers ______________________________________________________________________________ Carrier OCN Rate Center Prefix PageCell, Inc.- CA 6586 Van Nuys 278 PagePrompt, Inc. 6588 Van Nuys 214 PagePrompt, Inc. 6588 Van Nuys 418 Paging Dimensions 6869 Van Nuys 412 Administrative Law Judge's Ruling Ordering Carriers to Submit Utilization Data, dated June 15, 2000, directed twelve delinquent companies to submit utilization data within 20 days or be subject to sanctions. PageCell, PagePrompt, and Paging Dimensions were listed among the twelve companies. In addition, the CPUC has already issued a report on number utilization in the 310 area code on March 16, 2000. After the report's issuance, the CPUC issued Administrative Law Judge's Ruling Ordering Carriers to Submit Utilization Data, dated May 11, 2000. It should be noted that PageCell, PagePrompt, and Paging Dimensions were listed as companies that did not submit utilization data for the 310 area code. Recommendation for Data Submittal
The 818 area code has 3.9 million unused numbers. Of these unused numbers, the 818 study found that companies held 2.7 million numbers in their inventories. 15 These numbers held inventory are currently not used for any purpose, but held in anticipation of future need. The remaining 1.2 million unused numbers are not yet assigned to companies; these numbers are available for allocation in the monthly 818 lottery. The summary of available numbers is shown in the table below. ______________________________________________________________________________ Table 2-3 Summary of Available Numbers Wireline Carriers 1,828,826 Wireless Carriers 705,730 Type 1 Carriers16 128,201 Total Available Numbers Held by Carriers 2,662,757 Numbers Available for the 818 Lottery 1,230,000 Total Available Numbers in the 818 Area Code 3,892,757 ___________________________________________________________________________ Not all of the 3.9 million unused numbers are immediately available to every company that wants numbers. Of the 3.9 million numbers, only the 1.23 million numbers for the lottery are currently available to all companies. The remaining 2.7 million numbers are only available to the companies that hold them. The 818 area code is currently not in a pooling trial and no schedule for pooling has yet been adopted.17 However, should pooling be started with the current FCC rules specifying donations of 10% or less contaminated blocks of LNP-capable carriers, the pooling trial could start with a maximum of the 1.35 million numbers in wireline carriers' 10% or less contaminated blocks. However, the passage of time may lessen this number as companies use numbers. In addition, if the CPUC were to allow companies to retain a six-month inventory, as in the other pooling trials set up in California, some blocks in the 0% to 10% contamination levels would not be donated to the pool. By adopting the recommendations18 in this report, the CPUC could shift numbers from one availability category to the other as shown in the table below. Those actions could result in making a maximum of 3.2 million numbers19 of 3.9 million unused numbers available to all companies, with the remaining 0.7 million numbers available to the companies that hold them.
Although a number pooling trial has not yet been scheduled for the 818 area code, TD analyzed the 818 utilization data by percentage contamination to determine the availability of numbers that potentially could be used in a number pool. Current technology requires a company to be LNP-capable in order to donate numbers for another company to use. All wireline carriers in the 818 area code are required to be LNP capable.20 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.21 1.35 million of wireline carriers' 1.8 million unused numbers are contained in 1,369 thousand-blocks held by LNP-capable carriers that are 10% or less contaminated. However, if a number pool were to start in the 818 area code, not all of these 1.35 million numbers can be retrieved from companies' inventories for the pool because companies need to have enough numbers to meet anticipated future need.22 Both the CPUC and the FCC have determined that six-months of inventory is a reasonable quantity to hold in inventory. The remaining 476,000 of the 1.8 million unused numbers would not be retrieved, either because they 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 426,000 numbers in blocks that are more than 10% contaminated.23 Non-LNP capable wireline carriers hold 40,000 of the 1.8 million unused numbers. Special use prefixes24 are generally not LNP-capable and constitute 10,000 of the 1.8 million unused numbers. Wireless carriers hold 706,000 unused numbers in the 818 area code. Of these unused numbers, 367,000 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. If pooling takes place in the 818 area code under current rules, the CPUC would require each company participating in the 818 number pool to donate blocks that are 10% or less contaminated, excluding those retained for the six-month inventory. 25 Although a number pooling trial has not yet been scheduled for the 818 area code, TD analyzed the 818 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 rate by rate center for wireline carriers. ______________________________________________________________________________ Table 2-5 Available Numbers by Percentage Contamination for LNP Capable Wireline Carriers
______________________________________________________________________________ The first two numeric columns of Table 2-5 show the potential numbers available to a 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 2-5 shows that, except for three rate centers, the rest of the rate centers have available numbers that companies could potentially donate to an 818 pooling trial. The last three columns of Table 2-5 capture available numbers in blocks that are more than 10% contaminated but no more than 25% contaminated. Under the current number pool rules, companies retain thousand number blocks that are more than 10% contaminated in their inventories. Increasing the contamination rate threshold for donations from 10% to 25% would potentially free up an additional 138,00026 numbers for use in the number pool. TD cautions that, although Table 2-5 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 blocks that could be added to the pool while still leaving companies with a six-month inventory. As shown by Table 2-5, and also shown graphically in Table B-3 of Appendix B, most rate centers have available numbers from blocks of differing contamination levels up to 25%. The tables show that, if the contamination level were increased from 10% to 25%, more unused numbers exist in most rate centers that potentially could 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.27 Table 2-6 shows available blocks of numbers in differing contamination levels held by wireless carriers. Wireless carriers hold 367,000 available numbers in blocks which are 10% or less contaminated as shown in the first two numeric columns of Table 2-6. Wireless carriers also have 19,600 available numbers in blocks with contamination levels greater than 10% but less than or equal to 25% as indicated by the last three columns of Table 2-6. ______________________________________________________________________________ Table 2-6 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 818 area code are capable of implementing LNP. Thus, wireless carriers cannot participate in number pooling at this time, resulting in 386,000 unused numbers in blocks between 0% to 25% contaminated in the 818 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 potential pool. TD found instances where companies have contaminated several blocks in one prefix just over 10%. The CPUC's rules on sequential numbering 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 or prefixes. Sequential numbering minimizes contamination by requiring companies to move to the next thousand block only once a 75% fill rate has been attained in the prior block. Where companies have significant available numbers in a given rate center, these two efficiency measures could prevent the opening of new blocks or prefixes. Carriers reported utilization data as of April 30, 2000. The sequential numbering and fill rate decision was issued in July 2000. Therefore, TD does not expect companies to continue to contaminate blocks unnecessarily. Recommendation for Block Contamination Issues Affecting All Carriers
Decision 00-07-052 directed companies to return prefixes that are held unused for more than six months.29 Wireline carriers and wireless carriers hold 866,000 unused numbers and 262,000 unused numbers respectively, in the 0% contaminated blocks. Of these 0% contaminated blocks, 210,000 are in 21 whole prefixes, i.e. space prefixes, while 918,000 numbers are scattered throughout many different prefixes. The following table shows the breakdown. ________________________________________________________________________ Table 2-7 Breakdown of Numbers in 0% Contaminated Blocks ________________________________________________________________________ Avail. Nos. in Avail. Nos. in Avail. Nos. in 0% Contam. Blocks Spare Prefixes Differing Prefixes Wireline Carriers 866,000 120,000 746,000 Wireless Carriers 262,000 90,000 172,000
________________________________________________________________________ As shown above, 210,000 numbers in 21 spare 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. Substantial cooperation between the CPUC and the NANPA will be required in order for the CPUC to exercise this new authority to 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, 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 a potential pool, to be allocated through the monthly lottery, or to be otherwise used by companies. Companies report that 4.0 million numbers in the 818 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 refer to these numbers as "unavailable". Unavailable numbers include not only those actually in use by customers, but also the following categories:
In the 818 area code, there are 3.1 million assigned numbers, with 2.1 million assigned to customers by wireline carriers and 1.0 million assigned to customers by wireless carriers. The percentage of assigned numbers to total numbers held by companies is shown in the table below. ________________________________________________________________________ Table 2-8 Assigned Numbers to Numbers Held by Companies (in millions) ________________________________________________________________________ Assigned Numbers Nos. Held by Carriers Percentage Wireline Carriers 2.1 4.5 46.1% Wireless Carriers 1.0 2.0 50.8% ________________________________________________________________________ Non-working wireless describes numbers assigned to wireless customer equipment, but which are not yet working. These numbers are considered 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. There were no non-working wireless numbers reported in the 818 area code. While the quantity of non-working wireless numbers is zero, 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. 30 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 customer changes companies because customers can take their numbers with them. Since the 818 area code is included in one of the top 100 MSAs in the nation, all wireline carriers should have become LNP-capable by the end of December 1998.31 The only companies who reported INP numbers were ILECs. They reported a total of 198 INP numbers in the 818 area code. Since all the reported INP numbers were from ILECs' and none were from their competitors, it does not appear that INP exists in the 818 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 198 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, weather forecasts, high-volume call- in numbers, and emergency access32 numbers. These prefixes are not made available for general commercial use and as such, numbers that are not in actual use lie vacant. In 1999, companies decided not to duplicate the special use prefixes 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 seven prefixes are dedicated for special uses, two for Pseudo 800 service code and one each for high volume calling, emergency preparedness, time, directory assistance and information provider service.33 Except for one prefix in the Pseudo 800 Service Code, companies reported 60,000 assigned numbers in six prefixes. TD questions the necessity of assigning an entire prefix for each purpose. Furthermore, having multiple special use prefixes is an inefficient use of numbers in the 818 area code from which the special use numbers are drawn. For example, if the 555 prefix34 currently reserved only for directory assistance could be used to provide time and emergency preparedness, then two more prefixes could be returned for reallocation in the 818 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. The study indicates that of the two prefixes dedicated to Pseudo 800 Service, one prefix is fully utilized while only one number in the other 10,000 block is assigned. The remainder of these numbers can be a potential source of numbers for pooling. Recommendations for Special-Use Prefixes
Carriers "set aside" numbers for future use by customers.35 Previously, industry number assignment guidelines allowed companies to reserve a prefix for up to 18 months for customer future use.36 The FCC's NRO Order modified the number reservation period to 45 days. This 818 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 rule. 37 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 199,000 reserved numbers in the 818 utilization study38, 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 176,000 reserved numbers in the 818 area code. If the quantity of reserved numbers held by wireline carriers can be minimized, additional numbers could be available for immediate use by the companies from within their own number inventories and, thus, could slow the rate at which new prefixes are allocated to these companies. Once it is established, numbers could also be freed up for reallocation in the potential 818 number pool. 39 Currently there are no limitations on the quantity or percentage of numbers a company can classify as reserved, even though the company may still be 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. In the Van Nuys rate center40, for instance, one wireline carrier has reserved an entire prefix or 10,000 numbers. TD questions whether this company and other companies with high levels of reserved numbers truly need new number resources when they have unused number resources in their inventories. Other companies serving the Van Nuys rate center reported anywhere from 0 to 5,700 reserved numbers within a single prefix. If the CPUC orders efficient use practices specific to reserved numbers, companies will more efficiently use number resources. Wireless carriers reported just over 23,000 reserved numbers in the 818 area code. Wireless carriers also reported wide variances in reserved numbers. In the Van Nuys rate center, two wireless carriers reported approximately 6,500 reserved numbers each. The other companies serving that rate center averaged 150 reserved numbers. Like wireline carriers, efficient number use practices specific to the reserved numbers could immediately free up numbers within these companies' inventories for use. Once wireless carriers are able to participate in number pooling, these practices could have the same efficiency gains as those for wireline carriers. 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. Carriers self-reported a total of approximately 63,000 administrative numbers in the 818 area code, with about half of those held by wireline carriers and half held by wireless carriers. 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 818 area code. For example, one company serving the Canoga Park rate center reported that about 10% of its number resources were used for administrative purposes41, while all other companies in that rate center used between 0 and 3% of their resources for those purposes. Given the variance 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. 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 blocks. This practice means that both wireline and wireless carriers 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. Also, 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 prevents them from being donated to the pool when one is established in the 818 area code, 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 entity. Carriers reported a total of approximately 402,000 intermediate numbers in the 818 area code. Wireline carriers hold 296,000 intermediate numbers and wireless carriers hold almost 106,000. The quantity of intermediate numbers varied significantly among rate centers in the 818 area code, with six rate centers having no intermediate numbers at all. 42 Since the intermediate number category is a new one, 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.43 Because wireline and wireless carriers share responsibility for Type 1 numbers, both types of companies 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 818 area code, over 40% of all Type 1 numbers are unaccounted for or mismatched.44 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.45 As described in Chapter 1, state and federal 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 administrator. TD recommends Type 1 wireless carriers be subject to number conservation measures and the CPUC should develop 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.46 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 10 blocks of numbers in the 818 area code that may be eligible for donation to the pool.47 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 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 Industry Numbering Committee (INC) Guidelines, the CPUC adopted the FCC upper-limits for aging numbers as 90 days for residential numbers and 365 days 48 for business numbers. In the 818 area code, there are about 226,000 numbers in aging, representing 5.7% 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 818 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 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 8.7 percent of the total unavailable wireless numbers, or about 112,000 numbers. Aging numbers represent 4.2 percent of the total unavailable wireline numbers, about 114,000 numbers. This 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 utilization study were 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 would help verify whether companies are complying with CPUC and FCC rules for number usage. Recommendation for Audits
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