STATE OF ILLINOIS

ILLINOIS COMMERCE COMMISSION

NANPA, on behalf of the Illinois ) Telecommunications Industry ) ) Docket No. 00-0677 Petition for Approval of Numbering Plan ) Area Relief Planning for the 618 Area Code )

DIRECT TESTIMONY OF DANA SMITH

ON BEHALF OF VERIZON WIRELESS

January 15, 2002 Verizon Wireless Testimony Docket No. 00-0677 Exhibit 1.0 (Smith)

1 Introduction 2 Please state your name and business address. 3 A. My name is Dana Smith and my business address is Six Campus Circle, Westlake, Texas 4 76262.

5 Q. By whom are you employed and in what capacity? 6 A. I am employed by Verizon Wireless (“VZW”) as a Member of the Technical Staff in the 7 Numbering Policy and Standards group within VZW’s Network Planning Organization.

8 Q. Please summarize your education and work experience. 9 A. I received a Bachelor’s of Business Administration degree from the University of North 10 Texas in Denton, Texas in 1992. I have been employed with Verizon Wireless and its 11 predecessor companies since 1995, holding several positions within the Network 12 organization. I have worked exclusively on numbering issues for the past four years, 13 supporting fifteen states in the South and Midwest. My responsibilities have included 14 code administration, area code relief planning and implementation, and representing the 15 company’s interests at several national forums, including the Industry Numbering 16 Committee.

17 Q. Have you previously testified before this Commission? 18 A. Although I have not testified before this Commission, I have testified before other state 19 commissions as an expert on numbering issues. Moreover, I routinely participate on 20 behalf of Verizon Wireless in industry numbering meetings and particularly in NANPA 21 relief planning meetings.

22 Q. Does Verizon Wireless have a significant presence in Illinois? 23 A. Yes. Verizon Wireless provides wireless services to customers in many states, including 24 Illinois. Verizon Wireless has customers in every NPA within Illinois, and tens of 25 thousands of customers that will be affected by the area code relief plan chosen for the 26 618 NPA.

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27 Q. Has Verizon Wireless previously filed testimony in this matter? 28 A. No. However, Verizon Wireless is an active industry participant in relief planning 29 meetings in virtually every state across the nation, and has participated in the relief 30 planning process in other NPAs in Illinois.

31 Q. What is the purpose of your testimony? 32 A. The purpose of my testimony is to present Verizon Wireless’s position regarding the 33 alternatives for relief in the 618 Numbering Plan Area (“NPA”). Specifically, Verizon 34 Wireless supports the consensus position reached by the industry group for an all-services 35 distributed overlay as the best solution for the 618 NPA.

36 Q. Which option does Verizon Wireless view as the most appropriate in the 618 NPA? 37 A. After considerable review, discussion and evaluation of the available alternatives by 38 industry participants, Verizon Wireless supports the all-services distributed overlay relief 39 option (Alternative No. 3 described in Neustar’s petition in this Docket) for the 618 NPA 40 as the best choice. Verizon Wireless urges the Illinois Commerce Commission 41 (“Commission”) to allow implementation of the overlay to proceed as soon as possible.

42 Q. Why does Verizon Wireless view the all-services overlay plan as the best option for 43 relief? 44 A. An overlay plan has several advantages. Overlays avoid the problems associated with

45 splintering communities of interest into ever-smaller parts, including forced number

46 changes, and allow more flexibility to assign resources once number conservation

47 measures are implemented. An overlay also allows customers to retain their existing

48 telephone numbers. As the Federal Communications Commission has recognized,

49 overlays yield numbers that are available for use throughout the entire geographic area

50 covered by the old NPA, allowing resources to follow demand throughout an area

51 receiving relief.

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52 Each of the geographic split alternatives considered by the industry in this

53 proceeding would impact VZW’s customers and business negatively. A geographic split

54 will require area code changes for tens of thousands of VZW customers. Because the

55 proposed boundary line is similar in each of the split alternatives, i.e., an east-west split,

56 each geographic split proposal before the Commission is unacceptable.

57 Q. At this point, the Commission is reconsidering the relief options for the 618 NPA. 58 Has VZW given careful consideration to the various geographic split options 59 available? 60 A. Yes. After careful evaluation of the various geographic split alternatives, VZW found 61 that the geographic split options contain serious problems for both customers and 62 providers. These concerns are discussed below.

63 Implications of a Geographic Split 64 Q. From the customer’s perspective, what are the disadvantages of a geographic split 65 option for relief in the 618 NPA? 66 A. Any geographic split option will have several significant drawbacks. From the customer 67 perspective, roughly one-half of the customers in the existing 618 NPA would have to 68 change their area code. Business customers must endure the significant effort and 69 expense associated with changing stationary, business cards, advertising materials, 70 company signage and directory listings, among other things entailed in communicating 71 the number changes to their existing base of customers and suppliers. Residential 72 customers must also communicate the number changes to friends, relatives, schools, 73 doctors and other service providers. Wireless customers must also endure handset 74 reprogramming. All of these changes impose costs and inconvenience. 75 Although overlays require ten-digit dialing, geographic splits may also increase 76 the amount of ten-digit dialing for customers. Once a split is adopted, the frequency of

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77 ten-digit dialing may increase because the universe of numbers dialable with seven digits 78 shrinks. As NPA boundaries are re-drawn, communities are further fractured and 79 additional dialing confusion is created. Some customers may perceive a mix of seven- 80 and ten-digit dialing, which would be even more confusing than mandatory ten-digit 81 dialing everywhere.

82 Q. Are there any disadvantages related to a geographic split option that are unique for 83 wireless customers? 84 A. Yes. Geographic splits impose a disproportionate and unique negative impact on

85 wireless customers and carriers. That burden results from the need to reprogram wireless

86 handsets with the customer’s new telephone number. Unlike wireline telephone

87 numbers, the telephone numbers of VZW’s wireless customers are programmed or coded

88 into our customers’ individual handsets. The assigned number cannot be changed at the

89 switch, but rather must be done for each individual handset. At a minimum, the

90 Commission should grant wireless carriers the option of extended permissive dialing to

91 allow sufficient time to reprogram tens of thousands of handsets, which can only begin

92 once permissive dialing is in place.

93 Q. What challenges face VZW with respect to a geographic split option? 94 A. As a wireless service provider in the 618 NPA, VZW and other wireless carriers would 95 be faced with the burdensome task of reprogramming customers’ handsets with a new 96 telephone number for those whose NPA would change as a result of the geographic split. 97 VZW would experience considerable cost associated with reprogramming, including 98 customer education/communications and network changes to implement this change.

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99 Q. If the Commission were to adopt a geographic split, which alternative would 100 Verizon Wireless prefer on behalf of its customers and which portion of the two split 101 areas should retain the 618 NPA? 102 A. None of the geographic split alternatives is optimal for wireless customers generally, nor 103 for Verizon Wireless’s customers specifically. Each split option will force Verizon 104 Wireless and its customers to reprogram number changes for tens of thousands handsets. 105 That being said, alternatives 9, 11 and 12 are very similar and would cause the least 106 customer disruption if Area B is permitted to retain the 618 NPA.

107 Q. Should the Commission consider petitioning the FCC for authority to implement a 108 service specific or technology specific area code? 109 A. No, unless it proposes a transitional overlay with no take-backs. The lifting of the 110 prohibition against service specific or technology specific overlays allows state 111 commissions to petition the FCC with specific proposals. However, the FCC stated that 112 such proposals should not be implemented when the underlying NPA has a projected life 113 of less than one year. The 618 NPA is projected to exhaust in October of this year and 114 therefore is not a good candidate for implementing this type of relief. 115 In addition, Verizon Wireless does not support service specific or technology 116 specific overlays that would permanently segregate wireless carriers, take back numbers 117 from wireless customers, or permanently waive the ten-digit dialing requirement. 118 Verizon Wireless’s comments in the federal proceeding support application of phased-in 119 overlays, that transition into all-services overlays and do not involve take-back of 120 numbers or a permanent waiver of the ten-digit dialing rule. Verizon Wireless believes 121 that any overlay that would require wireless customers to give back their numbers for use 122 by landline customers is discriminatory and anti-competitive. 123 If the Commission chooses to petition the FCC for additional numbering 124 authority, Verizon Wireless would like to work with the Commission and the rest of the

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125 industry to formulate a proposal that provides for necessary numbering relief without 126 unduly burdening wireless customers or imposing a competitive disadvantage on wireless 127 carriers.

128 Conclusion 129 Q. Please summarize your testimony. 130 A. In addition to the numerous problems associated with a geographic split solution already 131 outlined in the record of this docket, and for the reasons described in this testimony, 132 VZW strongly recommends that the Commission order an all-services overlay plan as the 133 solution for the 618 NPA. The Commission should order the implementation of the all- 134 services overlay pursuant to the Proposed Second Interim Order dated October 29, 2001.

135 Q. Does this conclude your testimony? 136 A. Yes.

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CERTIFICATE OF SERVICE

The undersigned certifies that a copy of the foregoing Direct Testimony of Dana Smith was served upon the parties of record herein, by enclosing same in an envelope with postage fully prepared and by depositing said envelope in a U.S. Post Office mailbox this 15th day of January, 2002:

Judith D. Argentieri Janice A. Dale AT&T Wireless Services Assistant Attorney General Legal and External Affairs Public Utilities Bureau 804 W. University Avenue 100 W. Randolph St., 11th Floor Champaign, IL 61820 Chicago, IL 60601

Scott BohlerManager, Matt C. Deering State Government Affairs Meyer Capel, a Professional Corporation Citizens Communications Company 306 W. Church Street, 2378 Wilshire Blvd. P.O. Box 6750 Mound, MN 55364 Champaign, IL 61826-6750

Edward A. Butts Joseph E. Donovan Attorney for Illinois Bell Telephone Harry T. Kelly Company O'Keefe, Ashenden, Lyons & Ward 1800 W. Hawthorne Lane, Room 102 30 No. LaSalle St., Suite 4100 West Chicago, IL 60185 Chicago, IL 60602

Frank Colaco Douglas A. Dougherty Neustar, Inc. Illinois Telecommunications Assn., Inc. 1120 Vermont Ave., NW P.O. Box 730 Washington, DC 20005 Springfield, IL 62705

Lee Ann Conti Patricia Fleck AssociateGeneral Counsel Illinois Bell Telephone Company29b Citizens Telecommunications Company 225 W. Randolph 1000 Internationale Pkwy. Chicago, IL 60606 Woodridge, IL 60517 J. Seamus Glynn Citizens Utility Board James T. Coyle 208 S. LaSalle, Suite 1760 President Chicago, IL 60604 Shawnee Telephone Company P.O. Box 69 Equality, IL 62934

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Michael Guerra Sonnenschein Nath & Rosenthal Marcus Y. Milam 8000 Sears Tower AT&T Wireless Services Chicago, IL 60606 651 Gateway Blvd., Suite 1500 South San Francisco, CA 94080 Kevin E. Jacobsen ExecutiveVice President Egyptian Telephone Cooperative Dennis K. Muncy Association Joseph D. Murphy 1010 W. Broadway Meyer Capel, a Professional Corporation PO Box 158 306 W. Church Street Steeleville, IL 62288-0158 P.O. Box 6750 Champaign, IL 61826-6750 Mark G. Kaminski Assistant Attorney General John E. Rooney Public Utilities Bureau Sonnenschein Nath & Rosenthal 100 W. Randolph St., 12th Floor 8000 Sears Tower Chicago, IL 60601 Chicago, IL 60606

Peter J. Long David O. Rudd SBC Wireless - Great Lakes Region Gallatin River Communications LLC 2000 W. Ameritech Center Dr., h82 625 S. Second St., Suite 103-d Hoffman Estates, IL 60195-5000 Springfield, IL 62704

Julie B. Lucas Kevin Saville Citizens Utility Board Citizens Communications Co. 208 South LaSalle Street, Suite 1760 2378 Wilshire Blvd. Chicago, IL 60604 Mound, MN 55364

Karen L. Lusson Dana Smith Citizens Utility Board Verizon Wireless 349 S. Kensington Ave. 6 Campus Circle LaGrange, IL 60525 Westlake, TX 76262

Michael McDermott Tom Stanton Verizon Wireless Illinois Commerce Commission 1515 Woodfield Road, Suite 1400 Suite C-800160 N. LaSalle St. Schaumburg, IL 60173 Chicago, IL 60601

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Louise A Sunderland Nancy Wells Illinois Bell Telephone Company AT&T Floor 3, Floor 29B, 913 South Sixth Street 225 W. Randolph Springfield, IL 62703 Chicago, IL 60601 Kimberly D. Wheeler Morrison & Foerster, LLP 2000 Pennsylvania Ave. NW, Ste. 5500 Washington, DC 20006

Dwight E. Zimmerman Illinois Independent Telephone Association Oakmont Rd. R.R. 12, 24-b Bloomington, IL 61704 Cheryl A. Tritt Morrison & Foerster, LLP 2000 Pennsylvania Ave., NW, Suite 5500 Washington, D.C. 20006

Thomas H. Rowland Rowland & Moore 77 West Wacker Drive, Suite 4600 Chicago, IL 60601

A.. Randall Vogelzang Verizon Services Group 600 Hidden Ridge Irving, TX 75038

Lisa Volpe AT&T Wireless Services, Inc. 1150 Conecticut Avenue, NW, 4th Floor Washington, DC 20036

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