DT 99-603
          North American Numbering Plan Administrator
               Petition for Area Code Relief Plan
               Order Approving Interventions and
               Establishing a Procedural Schedule
                    O R D E R   N O.  23,199
                               April 19, 1999
     Appearances: Kimberly D. Wheeler on behalf of the Petitioner,
     Lockheed Martin (North American Numbering Plan Administrator or
     NANPA); Victor D. Del Vecchio, Esq. on behalf of Bell
     Atlantic-New Hampshire (BA-NH); Frederick J. Coolbroth, Esq. on
     behalf of Granite State Telephone, Inc., Merrimack County
     Telephone Company, Inc., Contoocook Valley Telephone Company,
     Inc., Wilton Telephone Company, Inc., Hollis Telephone Company,
     Inc., Dunbarton Telephone Company, Inc., Northland Telephone
     Company of Maine, Inc., Bretton Woods Telephone Company, Inc.,
     and Dixville Telephone Company (collectively referred to herein
     as the Independent Companies or the ICOs); Curtis L. Groves, Esq.
     on behalf of MCI WorldCom, Inc. (MCI); James A. Sanborn on behalf
     of Union Telephone Company (Union); Stacy L. Parker, Esq. on
     behalf of MediaOne; Kenneth Ira Spigle, Esq. on behalf of Sprint
     Spectrum L.P. dba Sprint PCS (Sprint); Kath Mulholland on behalf
     of BayRing Communications (BayRing); Nathan T. Foose, Esq. on
     behalf of Nextel Communications of the Mid-Atlantic, Inc.
     (Nextel); Robert Aurigema, Esq. on behalf of AT&T Communications
     of New Hampshire, Inc. (AT&T); Teresa L. Moore, Esq. on behalf of
     Cellco Partnership dba Bell Atlantic Mobile (BA-M); William
     Homeyer, Office of Consumer Advocate (OCA)on behalf of
     residential utility customers; and Larry S. Eckhaus, Esq. on
     behalf of the Staff (Staff) of the New Hampshire Public Utilities
     Commission (Commission).
     I.  Procedural History   
               Pursuant to Order No. 23,166 (March 19, 1999), on April
     7, 1999, the New Hampshire Public Utilities Commission
     (Commission) held a duly noticed Prehearing Conference regarding
     the NANPA's Petition for approval of an area code relief plan. 
     Since November 6, 1998, when NANPA declared an Extraordinary
     Jeopardy Situation for New Hampshire's 603 area code, NANPA
     conducted state-wide telecommunications industry meetings at
     which the industry reached an "industry consensus" on an area
     code relief plan.  NANPA's petition requests the Commission
     approve the industry consensus to implement an overlay solution
     to the area code exhaust projected by NANPA to occur in the
     fourth quarter of the year 2000.
     II.  Interventions
               In addition to the appearances noted above, timely
     filed petitions to intervene were received from the Business and
     Industry Association of New Hampshire, the Greater Portsmouth
     Chamber of Commerce, NEVD of NH, Rep. Jeb E. Bradley and Vitts
     Networks, Inc.  There being no objection to the interventions,
     the Commission grants full intervention to all parties who
     appeared who filed petitions to intervene.
     III. Positions of the Parties and Staff
               At the Prehearing Conference, all parties and Staff
     outlined their respective positions regarding area code relief. 
     The parties offered two main solutions to the problem: (1) an
     overlay, or (2) a geographic split relief plan, to provide a new
     area code when one becomes necessary.  In addition, there was
     discussion as to whether numbering conservation efforts should be
     undertaken before beginning to implement a relief plan.
               An overlay plan may be for all services or for specific
     services.  Under an all services overlay plan as proposed by
     NANPA, all existing customers would retain the 603 area code and
     number changes would not be required for existing customers.
     However, ten-digit local dialing would be required.  When the 603
     area code exhausts, all code assignments would be made in the new
     overlay area code, which would be assigned to the same geographic
     area as the 603 area code. 
               The geographic split relief plan would divide the State
     geographically into two, as yet undetermined, area codes
     Numbering Plan Areas or NPAs which would have different area
     codes.  Existing customers in one NPA would be assigned new
     ten-digit numbers. While seven digit dialing would be required
     within an NPA, ten-digit dialing would be required between NPAs.
               The NANPA described its role as facilitating the New
     Hampshire the New Hampshire telecommunications industry to reach
     consensus to recommend a single relief plan for the 603 area code
     to the Commission.  As the neutral third party administrator,
     Lockheed Martin has no independent view regarding the relief
     option selected by the industry. 
               Generally, the ICOs, BA-M, Nextel, Union and Sprint
     either favor, or do not object to, a state-wide all-services
     overlay.  MCI, and MediaOne support a geographic split. AT&T
     would support either option which is more likely to make numbers
     available on a timely basis.  BayRing supports a geographic split
     but does not expect to oppose an overlay plan. The OCA and Staff
     expressed no preference at this time.  
               BA-NH supported the all services overlay approach and
     had serious concerns regarding a geographic split.  In addition,
     BA-NH recommended a minimum of 12 to 15 months for the
     introduction of the new area code which included six months of
     technical preparation and customer education, and a six month
     period during which a customer could dial either the old number
     or the new number. 
               AT&T indicated either option is acceptable to them if
     certain conditions are met.  For overlay, these include mandatory
     ten-digit dialing and individual number portability.  AT&T
     opposed technology specific overlays.  For geographic split, AT&T
     proposed wireless grandfathering in the existing NPA, as did
     BA-M.  MCI supported geographic split but maintained that if an
     overlay is chosen, the Commission should order unassigned number
               Sprint supports an all services overlay and recommends
     that the Commission consider including competition in its
     definition of "consumer friendly" when deciding which option to
     adopt.  In addition, Sprint suggested that in the event
     conservation measures are adopted and are successful in delaying
     the implementation of an overlay, new numbers can be issued in
     the existing NPA, while under a geographic split that would not
               The OCA stated that with only about 1.5 million of 7.5
     million available numbers used in New Hampshire, it should not be
     necessary to add a new area code at all.  At this time, the OCA
     indicated that it has no firm position on either a split or an
     overlay, but intends to discuss this matter with its Advisory
               Staff indicated that its goals for this docket are to
     identify the causes of the numbering problem, assess the impact
     of every relief option, and make a recommendation that balances
     the short and long term effects of any choice, as well as the
     various interests that are represented and or affected.  Staff
     proposed that the parties file testimony supporting their
     position vis a vis other options and addressing, at a minimum,
     the criteria listed in the Commission's Order 23,166:
               including, but not limited to, minimizing customer
          disruption, cost, and confusion, conserving the total pool
          of telephone numbers if a new area code is created,
          minimizing geographic controversy and the chances of future
          area code changes, ensuring public safety, equitable
          treatment of consumers and competitive neutrality.  
               All parties and Staff agreed that conservation efforts
     should be undertaken as soon as possible.  However, Bell
     Atlantic, AT&T, MCI, Union, the ICOs, Sprint, NexTel and
     MediaOne, while supporting conservation, urged the Commission not
     to mistake conservation as a substitute for area code relief. 
     The OCA, on the other hand, urged the Commission to pursue
     conservation measures until a date certain in order to see if
     conservation measures alone will forestall area code exhaust. 
     Staff also supported conservation efforts and suggested that the
     Commission hold public hearings and use its website to inform and
     permit comment by consumers.  
     IV.  Commission Analysis
               Because the implementation of any area code relief plan
     will entail inconvenience and expense for New Hampshire
     customers, we will thoroughly examine the need for and
     ramifications of such a plan.  Although we appreciate the efforts
     made to reach an industry consensus, we do not, at this juncture,
     rule out any area relief plan.  
               In its petition, NANPA passed on an industry request
     that we issue our decision as to the choice of area code relief
     by June 1, 1999, in order to allow sufficient time to implement
     whatever plan is chosen.  Although this proposed schedule
     represents a very condensed schedule for considering such an
     important issue, we find that the procedural schedule proposed by
     the parties and Staff, which will approximate the requested
     schedule, will be adequate. 
     V.  Procedural Schedule
               The proposed procedural schedule to be followed in this
     proceeding, as agreed to by the parties and Staff at a technical
     session following the hearing is as follows:
          Data Requests to NANPA                  April 14
          Data Responses from NANPA               April 21
          Testimony with Executive Summary, 
               to include demarcation of 
               geographic boundary if
               supporting a split approach        April 30
          Public Hearings in Hanover, 
               Keene, Littleton, Laconia,         between May 7
               Manchester, Portsmouth               and May 21
          Data Requests on testimony              May 7
          Data Responses on testimony             May 21
          Rebuttal Testimony                      June 2
          Hearings                                June 16-17
          Briefs, if necessary                    TBD
          Recommended Order                       July 8
               Due to the compressed schedule, filings must be
     received (rather than mailed) by the dates set forth above.  In
     order to expedite receipt of a filing, the parties and Staff may
     consider using fax or e-mail, in addition to hard copies by mail,
     to deliver the documents.
               Based upon the foregoing, it is hereby
               ORDERED, that the Motions to Intervene described above
     are GRANTED; and it is
               FURTHER ORDERED, that the proposed procedural schedule
     as outlined above is GRANTED.
               By order of the Public Utilities Commission of New
     Hampshire this nineteenth day of April, 1999.
           Douglas L. Patch       Susan S. Geiger     Nancy Brockway
               Chairman           Commissioner          Commissioner
     Attested by:
     Kimberly Nolin Smith
     Assistant Secretary