Docket DT 99-603
                   EXECUTIVE SUMMARIES 
                     DIRECT TESTIMONY
                   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 value. 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 COMMISSION STAFF 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 option.
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 New Hampshire. 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, respectively.
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 Hampshire.