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. 1 Verizon Wireless Testimony Docket No. 00-0677 Exhibit 1.0 (Smith) 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. 2 Verizon Wireless Testimony Docket No. 00-0677 Exhibit 1.0 (Smith) 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 3 Verizon Wireless Testimony Docket No. 00-0677 Exhibit 1.0 (Smith) 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. 4 Verizon Wireless Testimony Docket No. 00-0677 Exhibit 1.0 (Smith) 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.