Docket DT 99-603
Filed: April 30, 1999
Summary of Position Statement of MediaOne, Inc.
The historical method of telephone number distribution is both archaic and
inefficient. The result is that New Hampshire's 603 area code is close to being exhausted
of new telephone numbers available for distribution to providers of local telephone
service. A lack of phone numbers would prevent competitive local exchange providers
("CLECs") from serving the New Hampshire telecommunications market. Without
competition, New Hampshire and its consumers will not experience the benefits of a
competitive marketplace, such as lower prices, new products and increased service and
MediaOne believes that competition will best be promoted and the public interest
best served by introducing a geographic split as the method of area code relief. A
geographic split creates a geographic boundary within the state, with one side of the
boundary retaining 603 NPA and the other side receiving a new area code. A geographic
split would cause the least amount of customer confusion disruption by retaining
seven-digit dialing as well as maintaining geographic identity within each area code. A
split would also provide for the smoothest transition into a second area code and avoid
the disruption associated with an overlay, such as mandatory ten-digit dialing, and the
difficulties of having different area codes within the same town, the same street or
possibly the same house. Also, if implemented along with conservation measures, the
need for additional area code relief will be minimized. Finally, a split would help to
alleviate the unfair advantage of incumbent local exchange carriers, such as Bell Atlantic,
which have extensive inventories of unassigned 603 telephone numbers ready for
distribution, even after 603 exhausts. Competition, and thus consumers, would benefit
most from a geographic split over the short and the long term.
If, however, the Commission determines that an overlay is the best method of
relief, it is imperative that the inherent anti-competitive aspects of overlay be mitigated.
The Commission must ensure that that Bell Atlantic, and all carriers, to which local
number portability (LNP) applies are not only LNP capable, but are prepared to offer
LNP at a commercially acceptable level. Anything less than a flawless transition from
the old carrier to the new carrier has a negative effect on the new carrier. Pursuant to
FCC regulation, the Commission must also order mandatory ten-digit dialing.
MediaOne also respectfully requests that the Commission order that all unassigned 603
numbers at the implementation of the new area code be reserved for CLECs, and that the
incumbents be prohibited from using their access to 603 numbers to market their services
after 603 exhausts. Only if these measures are available will the true anti-competitive
effects of an overlay be mitigated.
Finally, MediaOne also supports the implementation of conservation measures
such as rate center consolidation, thousands-block pooling and the enforcement of NXX
code reclamation procedures, which should be implemented along with the new area code
to mitigate the need for future area code relief.
MediaOne commends the Commission for opening this area code relief
proceeding, and ensuring that New Hampshire will continue to have an uninterrupted
supply of numbering resources.
SUMMARY OF TESTIMONY OF FRANK COLACO
ON BEHALF OF
LOCKHEED MARTIN IMS
Frank Colaco, NPA Relief Planner for Lockheed Martin
IMS ("LMIMS"), submits his prefiled testimony to explain the
role of LMIMS in the relief proceeding for the 603 NPA. Mr.
Colaco explains the relief proceeding, the relief
alternatives considered by the industry. Mr. Colaco also
discusses the projected exhaust date and the extraordinary
jeopardy procedures employed in the 603 NPA.
SUMMARY OF TESTIMONY OF PAUL S. KELLER
ON BEHALF OF
Along with Commission Staff and the majority of
industry participants, I believe that an all-services
overlay is the most beneficial solution for New Hampshire
customers. No existing customer numbers will be changed
with the overlay approach, and the costs to businesses will
be lower, in the aggregate, than those that would be faced
under a geographic split. Further, I believe that an
all-services overlay offers the best opportunity to
potentially delay the addition of a new area code in New
Hampshire. I would also note that mandatory 10-digit
dialing may be imposed nationwide at some point in the
future, negating an advantage of the geographic split
SUMMARY OF TESTIMONY OF DANIEL E. MULLIN
ON BEHALF OF
BELL ATLANTIC MOBILE
Bell Atlantic Mobile ("BAM") supports an all-services
overlay as area code relief for New Hampshire. (BAM is a
signatory to a Stipulated Agreement submitted on April 30,
1999 by a consensus of the industry.) The many advantages
of an overlay in a single-NPA state include minimal cost to
consumers and providers, fair treatment to all providers,
future-looking relief, faster implementation, less cost to
customers, no burden on wireless customers to reprogram
handsets, less public education, ease of addition of future
relief, and equal treatment of all service providers.
If the Commission were to order a geographic split, BAM
urges that Type II wireless customers be "grandfathered" in
order to minimize the unique burdens to wireless customers
of a geographic split.
SUMMARY OF TESTIMONY OF BETH H. OSLER
ON BEHALF OF
Bretton Woods Telephone Company, Inc.
Contoocook Valley Telephone Company, Inc.
Dixville Telephone Company
Dunbarton Telephone Company, Inc.
Granite State Telephone, Inc.
Hollis Telephone Company, Inc.
Merrimack County Telephone Company
Northland Telephone Company of Maine, Inc.
and Wilton Telephone Company, Inc.
The companies above understand the urgency of finding means to conserve
numbering resources, and fully support the industry consensus that conservation of
numbering resources is a worthy goal. However, it is our belief, based on the
discussions at both the NANPA industry meetings and the Commission's forum, that
number conservation does not appear to offer a timely solution to the current jeopardy
situation. For that reason, we supported the need to move forward with a plan for area
code relief. The companies in our group all concurred in the industry consensus position
that an all-services overlay approach was the best choice available for area code relief in
The group considered the same criteria that the Commission intends to consider in
making its decision as to the best way to implement area code relief. An all-services
overlay is the least disruptive to customers and is the only option that has all citizens
bearing the burden of a new area code equally.
These companies are also a signatories to the stipulation reached among numerous
parties in this docket. The signatories ( including AT&T, Vitts Networks, Inc., New
England Voice and Data of New Hampshire, and Nextel Communications, Inc.) find that
an all services overlay achieves an acceptable level of competitive neutrality when
implemented as described in the stipulation.
Therefore, we ask the Commission to approve all services overlay as the
appropriate means to implement a new area code for New Hampshire and to establish an
implementation schedule that avoids any exhaust of the 603 area code.
SUMMARY OF TESTIMONY OF EILEEN P. RUSH
ON BEHALF OF
NEW ENGLAND TELEPHONE AND TELEGRAPH COMPANY
d/b/a BELL ATLANTIC - NEW HAMPSHIRE
Ms. Rush's direct testimony explains why an
all-services overlay is the best method of area code relief
for New Hampshire, why Bell Atlantic-New Hampshire ("BA-NH")
opposes a split area code, and how the overlay best
addresses the criteria set forth by the Commission in Orders
23,166 and 23,199, issued March 19 and April 19, 1999,
SUMMARY OF TESTIMONY OF JAMES A. SANBORN
ON BEHALF OF
UNION TELEPHONE COMPANY
My testimony on behalf of Union Telephone Company
(Union) supports utilization of an all-services overlay in
provision of an additional area code for New Hampshire.
Union supports and is a signatory to the "STIPULATED
AGREEMENT SUPPORTING AN ALL-SERVICES OVERLAY AREA CODE FOR
NEW HAMPSHIRE" which Union understands will be filed by Bell
Atlantic in this docket.
Union also wishes to emphasize tow areas where an
overlay serves the New Hampshire public interest better than
a geographic split. These areas are:
Union also urges the Commission to act quickly to deal
with area code relief, so that there will be adequate time
for customer education and necessary network changes.
Union recommends utilization of an all-services area
code overlay in provision of an additional area code for New
- Customer dialing consistency with an overlay,
customer dialing confusion with a split.
- No number changes with an overlay, many number
changes with a split, which would cause confusion,
incur unecessary cost, and cause revenue loss to New