ARCHIVED - Telecom Decision CRTC 2002-25

Telecom Decision CRTC 2002-25

Ottawa, 22 April 2002

Area code 519 relief plan

Reference: 8698-C12-17/01

Summary

Customers in southwestern Ontario have been using area code 519 since 1953. It is expected that area code 519 will run out of telephone numbers by the second quarter of 2006. In September 2001, the Commission issued a public notice (Public Notice CRTC 2001-101) to request comments on various relief planning options.

In this decision, the Commission makes a number of determinations on a specific solution. In particular, the Commission directs the addition of a new area code to the area code 519 region in the first quarter of 2005 using the distributed overlay method. Ten-digit local dialing will be introduced within area code 519 and in both directions between the area code 519 region and neighbouring area codes, coincident with the introduction of the new area code.

Background

1.

Area code 519 has served southwestern Ontario since 1953. It comprises 210 telephone company exchanges, 15 of which are experiencing rapid growth. More than a dozen large cities are located in area code 519 including Brantford, Chatham, Galt, Guelph, Kitchener-Waterloo, London, Orangeville, Owen Sound, Sarnia, Simcoe, Stratford, Windsor and Woodstock. Several suburban and rural communities with varying levels of growth surround many of these cities.

2.

The supply of telephone numbers in area code 519 is projected to exhaust by the second quarter of 2006. In order to ensure that all carriers can implement a relief plan, the Canadian NPA [Numbering Plan Area] Relief Planning Guidelines document, which was approved by the Commission in Decision CRTC 2001-607, 26 September 2001, recommends establishing a relief method with an implementation date set at least
48 months prior to the projected exhaust date, which, in this case, would be by the second quarter of 2002.

3.

A CRTC Interconnection Steering Committee (CISC) ad hoc sub-committee, the Relief Planning Committee (the RPC), was established to examine relief options and to develop a planning document that would provide information on various relief options for the public.

4.

Relief options include an area code split (split) and a distributed overlay. In a split, the existing area code region is divided into two or more geographic regions, each of which is assigned its own unique area code. In a distributed overlay, a new area code is super-imposed over an existing area code. Under this option, central office (CO) codes from a new area code are made available for assignment to subscribers in all exchanges in the existing area code.

5.

The RPC issued the RPC Planning Document NPA 519 Numbering Relief (the planning document), dated 17 August 2001, for the relief of area code 519 on 24 August 2001. In the planning document, the RPC recommended a distributed overlay relief method for area code 519 in either the first or second quarter of 2005. The RPC also recommended a two-month permissive dialing period in which a network announcement would be used to remind customers of the transition from seven- to 10-digit dialing.

6.

The Commission issued Providing relief for the diminishing supply of telephone numbers in area code 519, Public Notice CRTC 2001-101, 17 September 2001 (PN 2001-101), to request comments on the various relief options contained in the planning document and on the RPC's recommendation.

Positions of parties

7.

The Commission received comments from consumers Sandi Burgess, Amanda Carson, Donna and David Couvillon, Kathleen Cullen, Thomas Fletcher, Janis Hartford, Anita Healey, Al Hodgson, K.A. Hunking, and Mark Rutledge, as well as the City of London and the County of Norfolk, and AT&T Canada, Bell Canada, and Rogers Wireless Inc. (RWI), in response to PN 2001-101.

8.

Several parties argued for a split of area code 519 and against the distributed overlay recommended by the RPC, in order to avoid the need to introduce 10-digit local dialing. In general, these parties argued that 10-digit local dialing is more difficult and time-consuming, and that it represents an unnecessary burden on small communities. In addition, they noted that some telephones and fax machines may not be equipped for
10-digit dialing; and that subscribers would have difficulty in determining whether a call is local or long distance.

9.

AT&T Canada, Bell Canada and RWI supported the RPC's recommendation to introduce a distributed overlay to relieve area code 519. These parties argued against a split since this would require many customers to change their telephone numbers and reprogram their wireless handsets. Bell Canada and RWI both argued that any benefits realized through the maintenance of seven-digit dialing in a split scenario would be outweighed by the cost and disruption resulting from telephone number changes and the reprogramming of wireless handsets. Bell Canada also opposed a split or any other option that would involve the alteration of an existing exchange boundary since this might involve physically reconnecting customers to different switching facilities.

10.

Ms. Burgess, Mr. Fletcher and Ms. Hartford recommended "service specific overlays" in which a new area code is opened in all exchanges of the existing area code, but telephone numbers from the new area code are only available for use with a specific type of technology or service, such as wireless services. RWI argued that assigning a new area code to wireless carriers would pose a significant competitive disadvantage for wireless service providers and would not provide any lasting relief for area code 519.

Commission findings

Relief method for area code 519

11.

The Commission notes, as set out in the planning document, that a split of area code 519 would require assigning approximately 1.3 million customers new telephone numbers within the new area code. Under this option, customers who receive new telephone numbers would incur direct costs as stationery, letterhead, advertising materials, etc. would need to be changed to reflect the new telephone number. The Commission also considers that a split could represent a considerable burden for both customers and wireless service providers, as approximately 525,000 wireless handsets would require manual reprogramming by wireless service providers or their representatives.

12.

In contrast to a split, since a distributed overlay adds a new area code into the same geographic region or NPA as the original area code, existing telephone numbers would not change and wireless handsets would not require reprogramming. At the same time, certain changes to older customer-owned switching equipment may be required in order for local calls to be originated or terminated from both area codes.

13.

The Commission notes that a split would only partially preserve seven-digit local dialing. Callers would still have to use 10-digit local dialing within and between area code 519 and the new area code. This would create customer confusion regarding the appropriate use of either seven or 10 digits to dial a local call.

14.

While the use of multiple area codes in the same region under a distributed overlay may result in some customer confusion, the Commission is of the view that it would be appreciably less than the confusion that would arise from a split solution.

15.

The Commission finds, on balance, that the concerns associated with the split option outweigh the inconvenience and costs that are likely to be experienced by customers under a distributed overlay. Accordingly, the Commission concludes that the distributed overlay is the most appropriate relief method for area code 519.

Ten-digit local dialing

16.

17.

The Commission recognizes the concerns of some parties that 10-digit local dialing may be more difficult and time-consuming than seven-digit local dialing. The Commission observes, however, that other changes have been made to the dialing plan since area code 519 was assigned in 1953, such as the nation-wide requirement to include the area code on long distance calls placed within the originating area code. Further, 10-digit local dialing has recently been implemented successfully in the Toronto area of Ontario and the Vancouver area of British Columbia. The Commission is confident that this change in area code 519 can be successfully implemented as well.

18.

Mr. Rutledge suggested that 10-digit local dialing is a particular burden on small communities. The Commission notes that all communities share the benefits of receiving numbering resources for various services from a particular area code and all communities contribute to the exhaust of that area code. Therefore, all communities are also affected by the relief of that area code.

19.

Ms. Hartford expressed concern that telephones and fax machines may not be capable of placing 10-digit local calls. However, given the fact that telephone and fax machines are used to dial 11 digits or more for long distance and international telephone or fax calls, the Commission finds that it is reasonable to assume that most of these machines are currently capable of dialing 10 digits. At the same time, the Commission recognizes that the introduction of 10-digit local dialing will require that pre-programmed telephone and fax lists be re-programmed to include the full 10-digit number.

20.

The Commission received comments contending that 10-digit local calls would be indistinguishable from long distance calls. The Commission notes, however, that long distance dialing is not affected in any way by 10-digit local dialing. The introduction of 10-digit local dialing, in providing relief for area code 519, will not alter the use of the prefix "1" to dial long distance calls.

21.

The City of London argued that 10-digit local dialing would impact internal dialing plans used by some organizations. The Commission notes, however, that existing internal dialing plans of any number of digits can co-exist with 10-digit local dialing. Private branch exchange (PBX) and Centrex systems used to provide internal dialing plans would need to be reprogrammed only for external, local dialing purposes.

22.

The Commission notes that the creation of a single 10-digit local dialing plan for area code 519 is consistent with the North America-wide move toward the Uniform Dialing Plan (UDP) which requires the use of 10-digit dialing on all calls. A 10-digit dialing plan minimizes the waste of numbering resources and thereby delays a future area code relief requirement and the eventual exhaust of the North American Numbering Plan (NANP). In the long term, there will be a need to expand the NANP and the move toward a UDP is a necessary preparatory step for that expansion.

23.

The Commission is of the view that the introduction of 10-digit local dialing will benefit consumers by creating a single, consistent local dialing plan which will, in turn, promote the orderly development of telecommunications services in area code 519. This view is consistent with the following previous Commission rulings on area code relief:

• SAIC Canada - Request for approval of NPA 416 relief plan, Telecom Order CRTC 99-1141, 10 December 1999;

• New area code overlay to be introduced in 905 region, Order CRTC 2000-772, 15 August 2000;

• New area code overlay to be introduced in 604 region, Order CRTC 2000-786, 16 August 2000;

• New area code overlay to be introduced in 514 region, Order CRTC 2000-1187, 22 December 2000;

· CRTC confirms 10-digit dialing plan for area codes 905 and 289, Order CRTC 2001-840, 22 November 2001; and

· CRTC issues relief plans for area codes 613 and 819, Order CRTC 2001-841, 28 November 2001.

24.

In light of the above, the Commission concludes that 10-digit dialing should be applied to all local calls within the current 519 area code region and to local calls to and from points in exchanges bordering the current 519 area code region.

Commission determinations

25.

The Commission directs all Canadian carriers to implement changes to accommodate the provision of a new area code using the distributed overlay method for the area code 519 region in the first quarter of 2005. Where 10-digit local dialing has not already been implemented, 10-digit local dialing will be introduced on all local calls from, to and within area code 519, coincident with the introduction of the new area code.

26.

The Commission also directs that a permissive dialing period of four months be implemented prior to the introduction of mandatory 10-digit local dialing, during which subscribers can make calls using seven or 10 digits. Although the RPC recommended a shorter permissive dialing period, the Commission has found in recent relief activities that a longer permissive dialing period is of benefit to subscribers who are required to make changes to their equipment.

27.

During the permissive dialing period, all service providers will be required to use clear and consistent network announcements to remind customers of the changes to the local dialing plan. Service providers will be permitted to phase-in a permissive dialing message during the first week of the permissive dialing period and phase-in a mandatory dialing message during the week prior to the introduction of the new area code.

28.

In order to monitor area code 519 for any acceleration of exhaust, the following measures will also be implemented:

• effective 1 July 2002, all service providers that use or intend to use CO codes from area code 519 or the new area code will be required to file semi-annual Canadian Numbering Resource Utilization Forecasts (C-NRUFs) with the Canadian Numbering Administrator (CNA). These C-NRUFs should be conducted at the NPA level of detail and all service providers shall include actual and forecast data using the appropriate methodologies outlined in the C-NRUF Guideline, which was approved by the Commission in Decision CRTC 2001-748, 7 December 2001. Since service providers are required to submit an annual C-NRUF regardless of the need for area code relief planning, the CNA may accept the submission of this annual NRUF as the first of the semi-annual reports, if appropriate;

• effective immediately, all service providers that use or intend to use CO codes from area code 519 or the new area code that submit forecasts that deviate by five codes or more in any given forecast year from the previous NRUF submission are required to file with the CNA explanatory information detailing the reasons for the deviation;

• within 30 calendar days following the filing of each C-NRUF, the CNA will prepare and file with Commission staff a report identifying the carriers that have deviated by five codes or more from the most recent forecast submitted. This report should be filed following each NRUF until area code 519 relief has been implemented;

• all new proposed competitive local exchange carriers intending to provide service in the 519 area code are required to file an initial C-NRUF with the Commission and the CNA prior to making a request for an initial code. The CNA should not assign an initial code without receiving a forecast;

• Commission staff may request that the CNA and carriers file more detailed and frequent monthly or quarterly C-NRUF data if the exhaust date is forecast to advance; and

• the CNA is required to notify the Commission when the 700^th NXX has been assigned, in order to trigger a review of the situation and any decisions regarding the disposition of the remaining resources.

29.

Noting that consumer awareness programs are critical to the successful implementation of any NPA relief project, the Commission directs the RPC to develop a comprehensive and consistent consumer awareness program for relief activities in the area code 519 region. The consumer awareness program is to be completed and forwarded to the CISC no later than 1 March 2003.

30.

The Commission notes that following the release of this decision, the CNA will request a new area code from the NANP Administrator for the relief of area code 519. This method of obtaining the new area code is in accordance with telecommunications industry practices.

Secretary General

This document is available in alternative format upon request and may also be examined at the following Internet site: www.crtc.gc.ca