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Before The Public Utilities Commission Of The State Of California
REPORT ON THE 714 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 March 13, 2001 Jack Leutza, Director Telecommunications Division 505 Van Ness Avenue, 3rd Floor San Francisco, CA 94102 REPORT ON THE 714 AREA CODE CALIFORNIA PUBLIC UTILITIES COMMISSION TELECOMMUNICATIONS DIVISION March 13, 2001 Prepared by Telecommunications Division: Michael Amato John Miller Victor Banuelos Craig Stevens Robert Benjamin Eleanor Szeto Mary Jo Borak Karen Watts-Zagha Cherrie Conner Sue Wong Jack Leutza TABLE OF CONTENTS Page EXECUTIVE SUMMARY 5 FINDINGS 6 CHAPTER ONE: OVERVIEW OF NUMBERING 10 A. Inefficient Use and Increasing Demand for New Numbers in California Is Causing Area Code Proliferation 10 B. 714 History and CPUC Decisions 11 1. Monthly Lottery Allocates Prefixes 12 C. CPUC Efforts to Resolve Area Code Proliferation 13 1. Number Pooling 13 2. Improved Number Inventory Management 14 3. CPUC Efforts at Federal Level 15 a. Authority Regarding Pooling 16 b. Authority Regarding Technology-Specific Area Codes 18 4. Utilization Studies 18 CHAPTER TWO: 3.9 MILLION UNUSED NUMBERS IN THE 714 AREA CODE 20 A. The Scope of the Utilization Study 20 B. 3.9 Million Numbers Available in the 714 Area Code 22 C. Analysis of "Available" Numbers 25 1. Analysis of Wireline Carriers' Contamination Rates 25 2. Analysis of Wireless Carriers' Contamination Rate 27 3. Potential Block Contamination Abuses 29 4. Reclamation of Prefixes 30 D. Analysis of 3.8 Million "Unavailable" Numbers 31 1. 3.1 Million Assigned Numbers 32 a. Non-Working Wireless 32 b. Eliminating Interim Number Portability Releases Numbers for Reallocation 33 c. Expanded Use of the 555 Prefix Could Release Other Prefixes Dedicated to Special Uses 34 2. Reserved Numbers Are a Potential Source of Additional Numbers 36 3. Restrictions on Administrative Numbers Could Yield More Numbers 38 4. Intermediate Numbers 39 a. Type 1 Numbers 40 5. Aging Numbers 42 6. The Need to Audit the Data 43 CHAPTER THREE: NUMBER POOLING AND OTHER NUMBER CONSERVATION MEASURES 45 A. Introduction 45 B. Number Pooling 45 1. More Accurate Forecasting Will Improve Number Pooling 46 C. Lack of Local Number Portability Stands as a Key Barrier to Pooling 47 D. Unassigned Number Porting 48 E. Consolidation of Rate Centers to Maximize Number Use 50 F. Sharing Prefixes May Yield More Efficient Number Use 52 CONCLUSION 53 Appendix A Appendix B Appendix C Appendix D Appendix E Appendix F Appendix G Appendix H Appendix I
At the same time, the 714 study finds that under FCC rules, about 2.1 million numbers cannot be contributed to the 714 number lottery, nor can they be contributed to the 714 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, 2.1 million numbers in the 714 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, a maximum of 3.0 million could be made available to companies through pooling if a) the companies donated blocks with higher contamination levels to the future pool, and b) wireless carriers were required to participate in the 714 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 714 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 three in 1947 to 13 in 1992, and stayed at that level until January 1997. 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. The Telecommunications Act of 1996 sought to open competition for the local telephone service market 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 in California 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 714 area code is a classic example of area code proliferation in California. Originally, the 714 area code was part of the 213 area code, one of the first three area codes created in California in 1947. The 213 area code originally covered all of southern California. The 714 area code was created in 1951 when it was split from the 213 area code. The 714 area code was reduced in size when the 619 and 909 area codes were split from 714 in 1982 and 1992, respectively. The 949 area code was split from the 714 area code in April 1998. Despite the splitting of this one area code into four area codes, the North American Numbering Plan Administrator determined the 714 area code would exhaust and that another area code would be necessary to provide numbers to the area. Most of the current 714 area code is contained within the Orange County and Los Angeles Metropolitan Statistical Areas (MSAs). Despite the continuous splitting of the 714 area code to provide new numbers to the area, the North American Numbering Plan Administrator (NANPA) determined in 1997 that the 714 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 March 18, 1998. 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 714 area code on October 7, 2000, with mandatory 1 + 10 digit dialing to begin on July 7, 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 and ten digit dialing in September. In December of 1999, by Decision 99-12-051, the CPUC suspended all overlays previously approved, which included the overlay in the 714 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 714 area code. This report fulfills that requirement.7 For those area codes nearing number exhaust, the CPUC has instituted a lottery process to fairly allocate the remaining prefixes among phone companies when demand exceeds supply. The 714 lottery began in December 1998. Currently, the CPUC distributes three prefixes (two initial and one growth8) in the monthly 714 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 714 area code through this process between January 1, 2000 and December 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 establishing 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. In addition, the CPUC has ordered pooling trials for ten other area codes during 2001. 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 714 area code is located in the Orange County and Los Angeles Metropolitan Statistical Areas.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 in rationing, all phone companies participate in the lottery. The CPUC has been aggressively setting up number pools. In January 2000, the CPUC by an Assigned Commissioner's Ruling set a pooling trial for the 714 area code, which began on September 29, 2000. All LNP-capable companies with numbers in 714 were 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 714 area code on an as-needed basis. There is no rationing process in pooling and the blocks received can be put into service almost immediately upon receipt. All non-LNP capable carriers continue to receive numbers in blocks of 10,000 through the monthly lottery allocation process. 46 blocks of 1,000 numbers were assigned to pooling carriers and 621 blocks of 1,000 numbers remain in the pool as of December 31, 2000. Additionally, the 39 prefixes (390,000 numbers) set aside for use in the number pool remain unused. 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 714, CPUC staff has observed that the demand for growth prefixes in each month's lottery has declined. As of December 31, 2000, there were 62 NXX codes available for lottery assignment in the 714 area code, as well as the 39 NXX codes set-aside for number pooling. The FCC has exclusive jurisdiction over numbering in the United States. 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 number 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 (first NRO Order).13 The first 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 first 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 first 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. On December 29, 2000, the FCC issued its Second Report and Order on Number Resource Optimization. In the second NRO Order, the FCC ruled on California's Petition for Waiver, concluding that the CPUC may continue to use its utilization thresholds subject to parameters set in this order (when FCC thresholds exceed California's, California must migrate to the more stringent utilization thresholds). The FCC also declined to adopt a transition period between the time that covered CMRS carriers must implement LNP and the time they must participate in any mandatory number pooling. The first NRO Order 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 first NRO Order, 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 714 area code, there are 25 wireless carriers holding 200 prefixes. If the CPUC were allowed to create a separate area code for those companies, the 200 prefixes in the 714 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. In the Second Report and Order, the FCC asks for further comments on technology specific or non-geographic area codes. 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 714 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 714 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. NeuStar submitted the aggregated data in its entirety to TD on August 18, 2000. A list of the companies who have been allocated numbers in the 714 area code, the study parameters and filing requirements appear in Appendix A.
Of the 7.7 million numbers in the 714 area code, companies hold 6.5 million numbers. The other 1.2 million numbers have yet to be assigned to companies. The CPUC's utilization study found that of the 6.5 million numbers held by companies, 2.7 million remain unused in their inventories. Therefore, 3.9 million numbers in the 714 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 55 companies, holding 654 prefixes (6.5 million numbers) in the 714 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 17 rate centers and one special code area. 15
Of the 55 companies in the 714 area code, 50 submitted utilization data. Although one company submitted data too late to be included in the summaries provided by NeuStar, TD has considered this late filer in its analysis. The remaining five companies holding nine prefixes in the 714 area code are no longer offering service in the 714 area code or failed to provide utilization data. CRL Network Services, Inc. and Preferred Networks, Inc. informed NeuStar that they were returning all their prefixes in the 714 area code. NANPA has confirmed that CRL and Preferred Networks have returned all four of their 714 prefixes. The other three companies, holding five prefixes, failed to provide utilization data. Table 2-2 summarizes this information. Table 2-2 Non-Reporting Companies Company OCN Rate Center Prefix PageCell, Inc. - CA 6586 Anaheim 819 PagePrompt, Inc. 6588 Anaheim 275 PagePrompt, Inc. 6588 Anaheim 298 Paging Dimensions 6869 Anaheim 303 Paging Dimensions 6869 Anaheim 344 ________________________________________________________________________ Administrative Law Judge's Ruling Ordering Carriers to Submit Utilization Data, dated June 15, 2000, ordered twelve delinquent carriers 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 issued its first 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 in that ruling as companies who did not submit utilization data for the 310 area code. Recommendation for Data Submittal
The 714 area code has 3.9 million unused numbers. Of these unused numbers, TD found that companies held 2.7 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 1.2 million unused numbers are not yet assigned to companies: 390,000 numbers have been set aside for number pooling17 and 790,000 numbers are available for allocation in the 714 monthly lottery. The breakdown of available numbers is shown in the table below. ________________________________________________________________________ Table 2-3 Summary of Available Numbers Wireline Carriers 1,928,722 Wireless Carriers 654,447 Type 1 Carriers18 135,555 Total Available/Unused Numbers Held by Carriers 2,718,724 Numbers Set Aside for the 714 Pooling Trial 390,000 Numbers Available for the 714 Lottery 790,000 Total Available Numbers in the 714 Area Code 3,898,724 ________________________________________________________________________ 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 1.8 million numbers19 is available to all companies via the pooling trial or the lottery. The remaining 2.1 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 3.0 million numbers21 available to all companies with the remaining 0.9 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 714 area code are required to be LNP capable.22 Wireline carriers hold 1.9 million unused numbers in the 714 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 1.3 million of wireline companies' 1.9 million unused numbers are contained in 1,297 thousand-blocks held by LNP-capable carriers and are 10% or less contaminated. However, not all of these 1.3 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 1,297 thousand-blocks eligible for donation, 630 blocks remain with companies for their six-month inventory while 667 blocks are now available for pooling.25 The remaining 656,000 of the 1.9 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 636,000 numbers in blocks that are more than 10% contaminated.26 The one non-LNP capable wireline carrier holds 10,000 of the 1.9 million unused numbers. Special use codes27 are generally not LNP capable and constitute 10,000 of the 1.9 million unused numbers. Wireless carriers hold 654,000 unused numbers in the 714 area code. Of these unused numbers, 300,000 are in blocks that are 10% or less contaminated, while 354,000 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 714 number pool to donate blocks that are 10% or less contaminated, excluding those retained for the six-month inventory.28 TD analyzed the 714 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 2-5 Available Numbers by Percentage Contamination for LNP Capable Wireline Carriers ________________________________________________________________________
________________________________________________________________________ The first two columns of Table 2-5 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 2-5 shows that all rate centers except Capistrano Valley, Irvine, Laguna Beach, and Saddlebrook Valley have available numbers that companies could donate to the pool. Wireline carriers do not hold any prefixes in Capistrano Valley, Laguna Beach or Saddlebrook Valley.29 The Irvine rate center is comprised of only one prefix: a special use prefix used for Emergency Preparedness. The last three columns of Table 2-5 capture available numbers in blocks that are greater than 10% contaminated but no more that 25% contaminated. Under the current 714 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 158,00030 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 numbers that can 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 table shows that if the contamination level was increased from 10% to 25%, more unused numbers exist in most rate centers 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 the LNP requirement. Table 2-6 shows available numbers in differing contamination levels held by wireless carriers. Wireless carriers hold 300,000 available numbers in blocks which are 10% or less contaminated as shown in the first two columns of Table 2-6. Wireless carriers also have 48,000 available numbers in blocks with contamination levels greater than 10% but less than 25% as indicated by the last three columns of Table 2-6. Of these 348,000 unused numbers held by wireless carriers, TD estimates that paging companies hold 132,000. 31 Staff is investigating whether there are methods to make some of these 132,000 unused numbers available to other companies despite the FCC's exemption of paging companies from the LNP requirement. ________________________________________________________________________ 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 714 area code have implemented LNP. Thus, wireless carriers cannot participate in number pooling at this time, resulting in 348,000 unused numbers in blocks between 0% to 25% contaminated in the 714 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. Recommendations 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. As shown in Appendix B-1, wireline carriers and wireless carriers hold 823,000 unused numbers and 235,000 unused numbers, respectively, in the 0% contaminated blocks. Of these 0% contaminated blocks, 270,000 numbers are in 27 whole prefixes33, i.e. spare prefixes, while 788,000 numbers are scattered throughout many different prefixes. The following table shows the breakdown between wireless and wireline carriers. ________________________________________________________________________ Table 2-7 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 823,000 170,000 653,000 Wireless Carriers 235,000 100,000 135,000 270,000 788,000 ________________________________________________________________________ As shown above, 270,000 numbers in 27 prefixes can possibly be reclaimed if not used within six months. However, as a result of the FCC's March 31, 2000 (first) 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 first NRO order.34 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. NANPA has provided to the CPUC a list of companies that have failed to report whether their assigned prefix(es) have been placed in service. The CPUC issued Assigned Commissioner's Ruling Requiring Carriers to Comply With NXX Code Reclamation Rules, dated December 21, 2000. In this ruling, the CPUC instructed the delinquent companies to comply immediately. Companies are to inform the CPUC that the prefix(es) have been placed in service or returned, the company was incorrectly included in NANPA's delinquent list, or the reasons why the prefix(es) have not been placed in service. The CPUC will review the reasons and make a determination on whether the prefix(es) must be returned or reclaimed by NANPA or whether an extension of time is to be granted to the company to place the prefix(es) in service. Any delinquent company that fails to comply will be subject to penalties and sanctions. 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 714 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 714 area code, 3.1 million assigned numbers exist with 2.0 million assigned to customers by wireline carriers and 1.1 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) ________________________________________________________________________ Total Nos. Assigned Numbers Held by Companies Percentage Wireline Carriers 2.0 4.5 44.1% Wireless Carriers 1.1 2.0 54.9% ________________________________________________________________________ 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 are no non-working wireless numbers reported for this 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 numbers to remain idle for an unspecified period. 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 180 days (similar to the requirement the FCC has established for reserved numbers). 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. 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. 35 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 714 area code is included in one of the top 100 MSAs in the nation, all wireline carriers should be LNP-capable.36 The only companies that reported INP numbers were ILECs. They reported a total of 333 numbers in the 714 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 714 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 333 numbers that are currently dedicated to INP. Recommendations for INP-Related Conservation Measures
Historically, the telecommunications industry has designated certain prefixes for special uses, usually to an ILEC. These include numbers for recorded public information announcements such as time-of-day, weather forecasts, high-volume call-in numbers, and emergency preparedness37 numbers. These prefixes are not made available for general commercial use, and thus numbers within these prefixes 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 these prefixes should be duplicated in each new area code. The utilization study shows that 13 prefixes are dedicated for special uses: one each for directory assistance, high volume calling, time, and emergency preparedness, and nine for Mobile Radio. TD questions the necessity of assigning an entire prefix for each of the purposes listed above. Furthermore, having multiple special use prefixes is an inefficient use of numbers in the 714 area code as well as in other area codes in California. For example, if the 555 prefix 38 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 714 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. In addition to the other utilization of these numbers, the distribution of these numbers among blocks also demonstrates inefficient utilization practices. Consistent with our statewide conservation measures adopted in July, TD recommends that CPUC require companies to assign numbers sequentially within each 1,000 block. Recommendations for Special-Use Prefixes
Carriers "set aside" numbers for future use by customers.39 Previously, industry number assignment guidelines allowed companies to reserve a prefix for up to 18 months for customers' future use.40 The FCC's first NRO Order modified the number reservation period to 45 days. This 714 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. 41 The extension allows companies time to upgrade their number tracking mechanisms, which tally the quantities of reserved numbers they hold. The FCC's second NRO Order on Reconsideration changed the number reservation period to 180 days. This took effect on December 29, 2000.42 Companies reported a total of 205,00 reserved numbers in the 714 utilization study. 43 Wireline carriers reported a total of 166,000 reserved numbers in the 714 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, thus slowing the rate at which new prefixes are allocated to these companies. Numbers could also be freed up for reallocation in the 714 number pool. Currently there are no limitations on the quantity or percentage of numbers a company can classify as reserved before requesting new numbers. Similarly, companies are not required to use their reserved numbers stock before they can request that new numbers be allocated to them. Comparing the data on the Westminster rate center and the Buena Park rate center illustrates wide discrepancies between the quantity of reserved numbers companies hold. Ten wireline carriers reported having reserved numbers in each of those rate centers. However, wireline carriers have over five times as many reserved numbers in the latter rate center. 44 In another example, one company holds over 4,500 reserved numbers in one prefix in the Orange rate center. Other companies in that same rate center hold as few as zero reserved numbers. If the CPUC orders efficient use practices specific to reserved numbers, more numbers could be made available for customer use. Wireless carriers reported 36,000 reserved numbers in the 714 area code. Wireless carriers also reported wide variances in reserved numbers. In the Santa Ana rate center, many wireless carriers reported between 0 and 300 reserved numbers for a given rate center. By contrast, there were three instances in that rate center where reported reserved numbers were between 2,500 and 3,500 in a given prefix. Just as for wireline carriers, efficient number use practices specific to reserved numbers 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 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. Companies reported almost 45,000 administrative numbers in the 714 area code. Wireline carriers hold approximately 26,000 of these numbers and wireless carriers hold approximately 19,000 of them. The utilization study revealed that there is a potential for companies to over-assign administrative numbers within a particular thousand block, prefix or rate center in the 714 area code. The following examples demonstrate this potential for over-assignment. First, in the Huntington rate center, a company is using over 1,100 numbers in one prefix for administrative purposes, while the average across all companies is 68. Also, while the Anaheim and Santa Ana rate centers report approximately the same number of administrative numbers used, the Anaheim rate center has approximately one-third of numbers assigned, essentially using administrative numbers at 3 times the rate. Given the variances in the levels of administrative numbers between companies and rate centers, 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 prevents them from donating blocks once they can participate in number pooling, or from 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 administrative numbers in 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. Recommendations for Administrative Numbers
The "intermediate number" category was only recently introduced by the FCC in its first NRO Order. This category tracks numbers that companies make available for use by another telecommunications carrier or non-carrier entity. Companies reported a total of approximately 385,000 intermediate numbers in the 714 area code. Wireline carriers hold about 288,000 of those numbers and wireless carriers hold a little over 97,000. The quantity of intermediate numbers varied significantly among rate centers in the 714 area code. 45 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. Therefore, TD recommends the CPUC continue to monitor intermediate number use. Recommendation for Intermediate Numbers
Wireline carriers allocate numbers for use by wireless Type 1 carriers through Type 1 interconnection agreements.46 Because wireline and wireless Type 1 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. Wireline carriers also list the wireless carriers to whom they distributed ranges of numbers. Wireless Type 1 carriers report on the numbers they received, placing them in the Assigned, Administrative, Reserved, Intermediate, Aging, or Available categories. Record keeping of Type 1 numbers is inadequate because, more often than not, wireline carriers' reports disagreed with wireless Type 1 carriers' report. In the 714 area code, over one half of all Type 1 numbers are unaccounted for or mismatched.47 In some cases, wireless Type 1 carriers deny "owning" the numbers that wireline carriers report as distributed. In other cases, wireless Type 1 carriers go out of business and do not return their numbers to the wireline carrier. In either case, numbers are lying dormant, used by neither the wireline or wireless Type 1 carrier. In today's scarce numbering environment, it is unacceptable to let numbers go unused because of inadequate record keeping. Wireline donor carriers currently 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 to confirm that the numbers they have distributed are acknowledged by the recipient wireless Type 1 carrier. If errors are discovered, the wireline carriers should count the numbers as part of their own inventories.48 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, once wireline carriers recover unused Type 1 numbers, these numbers could be made available for pooling. Despite the problems with reporting, TD has identified 14 blocks of Type 1 numbers in the 714 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 wireline companies recover unused Type 1 numbers for donation to the number pool. 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 administrator. TD recommends that Type 1 wireless carriers be subject to number conservation measures, and the CPUC should develop a system to ensure compliance. Recommendations for Type 1 numbers:
The FCC's first NRO Order defines aging numbers as disconnected numbers that are not available for assignment to another 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 days51 for business numbers. In the 714 area code, there are approximately 218,000 numbers in the aging category, representing 5.52% of the total unavailable numbers. While most companies track aging telephone numbers by business and residential categories, Pacific Bell, the largest single holder of numbers in the 714 area code, does not differentiate between business and residential customers when tracking aging numbers. In the cases where only totals were supplied, 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 Pacific Bell is adhering to the maximum 90-day aging period for residential numbers, 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 7.05% of the total unavailable wireless numbers, or about 94,000 numbers. Aging numbers represent 4.73% of the total unavailable wireline numbers, or about 124,000 numbers. This is consistent with the higher turnover or "churn" that occurs in the wireless industry. Appendix G shows the breakdown of aging numbers by wireless and wireline categories.
The data analyzed in this 714 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.
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 714 area code and statewide: LNP-related actions, Unassigned Number Porting, Rate Center Consolidation, and prefix sharing. 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, 415, 714 and 909 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 nine months. The pool has satisfied the numbering needs of all companies participating in the pool without opening a single prefix.52 Prior to pooling, 128 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 18 months. 53 The positive experience in 310 is mirrored in 415, 714 and 909. Only two prefixes have been opened, and the numbering needs of companies have been met.54 Pooling has saved 44 prefixes in these three area codes. 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, activating new numbers can be accomplished in three weeks. So far in California, number pooling has worked well because companies have met their numbering needs from the excess 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 a true 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 been, on average, forecasting over six 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 used only one. 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 prior to opening any 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. Recommendation for Number Pooling
Full LNP deployment in the 714 area code is critical to effective number conservation. As described in Chapter One, LNP enables customers to keep their telephone numbers when they switch companies. Because the number remains with the customer and can be transferred to different companies, there is no need to distribute duplicate numbering resources to both companies. Also, LNP is the technology platform that makes number pooling possible. In an order released in 1997, the FCC ordered all wireline carriers in the top 100 MSAs to become |
