The 619/858/935 Area Code Split

by **Bob Kuczewski** » Fri Dec 09, 2022 9:21 pm

In early 1999, citizens in parts of San Diego began getting notices that their area code would be changing from 619 to either 858 or 935. A small part of San Diego (including the downtown area) would retain their original 619 area code. This was the proposed area code map at that time:

: SPLITCs.jpg (48.45 KiB) Viewed 1000 times

When I first began getting these notices, I thought "This is really stupid. Surely someone will step up to stop this." But month after month, the notices kept coming. Eventually I realized that the "someone" I wanted to step up ... would have to be me.

This topic documents my efforts in 1999 and 2000 to stop the painful and costly area codes splits that were intended to split San Diego into 3 separate area codes. The short term outcome was mixed with the 858 area code split going forward, but also with the 935 area code being delayed indefinitely. In the long term, my proposal was vindicated, and in 2018 the two previously split area codes were "reunited" into a single overlay similar to my 1999 proposal. However, my recommendation that 7-digit dialing be preserved within an area code has not yet come to pass. Maybe in another couple of decades?

Here's a condensed history of the events:

History (as written in 2000)

On June 5th of 1999, Robert M. Kuczewski sent an email message to the CPUC requesting an alternative to the announced split. The proposed alternative was an overlay which allowed 7-digit dialing within the same area code.
On July 29th of 1999, Marti Emerald of KGTV interviewed Kuczewski for an upcoming area code story.
On August 27th of 1999, Kuczewski filed a Petition requesting a 6-month delay of the 619/858 split so that 7-digit overlays might be investigated.
On August 31st of 1999, Kuczewski solicited support for the Petition from a wide range of public officials and organizations. Responses were posted on the Save 619 Area Code Petition Page.
On September 9th of 1999, Kuczewski's July interview with Marti Emerald was shown on KGTV. It was pessimistic about stopping the 619/858 split.
On September 27th of 1999, Pacific Bell filed its comments against the August 27th Petition.
On November 2nd of 1999, Mike Drummond published his "Cracking the (area) code" story in the Union Tribune.
On December 7th of 1999, Administrative Law Judge (ALJ) Pulsifer filed a draft ruling(1) denying the August 27th petition.
On December 24th of 1999, Kuczewski filed a one page response to both Pacific Bell and ALJ Pulsifer's filings.
On January 6th of 2000, the CPUC voted against the August 27th petition by the slimmest of margins (3 to 2).
On January 13th of 2000, Kuczewski filed a second Petition requesting an indefinite extension of the "Permissive Dialing" period to allow all 619/858 customers to retain both area codes.
On January 26th of 2000, Dave Nichols (president of Pacific Bell for the San Diego region) published an editorial in the Union Tribune denying Pacific Bell's responsibility for the split.
On February 7th of 2000, the San Diego City Council held an open meeting on the split.
- Kuczewski and other citizens spoke in opposition to the split.
- Kuczewski advocated a reversion to "Permissive Dialing" to reverse the effects of the split. He also advocated using the 935 area code as a 7-digit overlay to provide more numbers for the region without disturbing any existing numbers or dialing patterns.
- Pacific Bell's representatives supported the split and opposed Kuczewski's plan as they did in their CPUC filing of September 27th.
- When questioned by Mayor Golding, Pacific Bell also refused to divulge their number utilization claiming that such information was "proprietary".
On February 7th of 2000, the San Diego City Council voted to take the following actions:
- Oppose Area Code 935
- Advocate the Completion of the Number Audit
- Contact the CPUC Administrator regarding Number Administration
- Support the Permissive Dialing Petition
- Whatever action is taken to prevent area code 935, the same action shall be taken against area code 858.
On February 8th of 2000, both Kuczewski and Pacific Bell addressed the San Diego County Board of Supervisors.
On February 11th of 2000, ALJ Pulsifer solicited all participants for comments concerning deferral of the 935 area code split.
On February 24th of 2000, the City of San Diego filed 4 documents with the CPUC:
1. Petition to Intervene in CPUC Proceeding
2. Indefinite Permissive Dialing Petition for 858 with 7-Digit Overlay
3. Emergency Motion to Revert to Permissive Dialing in 858
4. Comments on Phase 2 of the 3-way Split (619/935 split)

Outcome (as written in 2000)

On January 6th of 2000, the California Public Utilities Commission (CPUC) voted to accept ALJ Pulsifer's draft ruling against the petition ("Yes" votes endorsed the split). The vote was as follows:

Name	Vote	Appointment	Contact
Henry M. Duque	No	Wilson, April 1995	hmd@cpuc.ca.gov Website 1-800-848-5580
Josiah Neeper	No	Wilson, September 1995	jln@cpuc.ca.gov Website 1-800-848-5580
Richard A. Bilas	Yes	Wilson, January 1997	rb1@cpuc.ca.gov Website 1-800-848-5580
Carl W. Wood	Yes	Davis, June 1999	cxw@cpuc.ca.gov Website 1-800-848-5580
Loretta Lynch	Yes	Davis, December 1999	lyn@cpuc.ca.gov 1-800-848-5580

During the proceeding, both Commissioners Neeper and Duque spoke out strongly against the majority position.

It is unclear whether the Commission will revisit the matter in response to mounting public discontent with these splits. Interestingly, both of Governor Davis's new appointees endorsed the split.

Summary (as written in 2000)

Unfortunately, the citizens of California do not elect these Commissioners. However, they are appointed by the Governor of California who must ultimately answer to the citizens on election day. If you look carefully at this table, you may notice that 2 of the 3 votes to split San Diego were cast by Governor Gray Davis's very recent appointees. Fortunately, these votes and appointments were made in public, so we have some degree of accountability in this matter. But accountability is only as good as our collective memories. So let me propose a memory aid for this particular split. Rather than calling it the 619/858 split of 1999, I suggest that we name it after the very people who allowed it to happen. My preference would be "The Bilas, Lynch, Wood, Davis Split of 99". I've tried to make an acronym of that, but it's tough with no vowels. So since the people at the top always like to take credit for things like a good economy and low inflation, I suggest that we name this split after the Governor who appointed the deciding Commissioners and the President who's FCC has limited our choices to either splits or 11-digit overlays. In other words, I propose that all San Diegan's remember this as the Davis-Clinton Split of 1999.

Epilog (added in December 2022)

Subsequent to these events, California Governor Gray Davis faced a recall election and was removed from office on November 17th, 2003.

In 2018, the geographic boundaries of the split were removed which converted the split into an overlay where both area codes (619 and 858) are available throughout the region of the former 619 area code. This was the configuration that Kuczewski had advocated in 1999.

by **Bob Kuczewski** » Fri Dec 09, 2022 9:21 pm

As described above, this first image shows the 3-way split that was proposed to be implemented back in 1999 and 2000:

: SPLITC.JPG (85.18 KiB) Viewed 1000 times

The 858 Area Code was listed as "Phase 1", and the 935 Area Code was listed as "Phase 2". Only the small downtown region and Point Loma were being spared from having their numbers changed. In effect, all of the 619 phone numbers that were being taken from the 858 and 935 regions would end up being "redistributed" to homes and businesses in this small 619 area.

I tried to explain it to people using the "buckets of phone numbers" analogy:

The Area Code "Bucket"

POUR10.JPG (57.36 KiB) Viewed 1000 times

Each area code is an imaginary grouping of about 8 million possible phone numbers. You can picture each area code as if it were a bucket that can hold up to 8 million drops of water. In this example, each drop of water would be the same as one person's phone number. To tell the buckets apart, each one is labeled with a three digit number which we call the "area code" for that bucket. For example, our San Diego "bucket" would be labeled with "619" so we could find it among all the other buckets in the country. And once we can find the right bucket, we can use the rest of the phone number to find the right drop!

When the area code is brand new, it is empty (with no drops in it). But as people begin ordering phone service, the bucket starts to fill up with phone numbers. You can think of this as a faucet that is slowly dripping more and more water into the bucket. Each additional phone service adds one more drop to the bucket.

Unfortunately, this "slowly dripping" faucet has become a stream of water as more and more people order new phone services. This is where things get a little tricky. It turns out that the faucet doesn't always run at the same rate. Sometimes it's fairly slow for many years, and then all of a sudden everyone wants a second phone for their computer or their cell phone. These sudden spurts of phone orders make it difficult to predict when the bucket will be full. This is complicated by the long process that must be used to add new buckets. An area code change may take years to implement. So since you can't tell when the water might really start gushing, it's a good idea to start adding a new bucket before the old one gets too full.

So how do you add a new "bucket" when you think you might run out of phone numbers? Well there are two approaches depending on where you want the drops to end up. The first approach is called an area code "split" and it has been the traditional method of adding a new area code for many years. The second approach is called an area code "overlay" and it's beginning to gain popularity for many reasons. We'll look at both approaches and compare them in the following sections.

Splitting an Area Code

POUR20.JPG (53.69 KiB) Viewed 1000 times

When an area code begins to get so full that it might spill over, it can be "split" into two (or more) area codes. Traditionally, this means that some people will stay in the old area code and some people will be given a new area code. How do you decide who stays and who goes? There are probably many considerations including everything from expected growth patterns to political clout. In many cases, this means that people closer to the "heart" of a city will get to keep their old area code while people further from this political "heart" will have to suffer with the new area code. This kind of geographic split is also consistent with the traditional use of the three "area code" digits of your 10 digit phone number. In other words all the people in the same 3-digit bucket should also live in the same geographic area.

So how does the actual split take place? Well the first thing that everyone notices about an area code split is that some people have to get a new area code. This is like "dumping" their numbers out of the old area code and dumping them into the new area code. This means that some people's old phone numbers will be given out to new people! So your good old phone number may be given out for someone else to use for any purpose. Your old phone number might be used for a FAX machine or an escort service. It might even be given to a business competitor. After all, that's exactly why you were "dumped" out of your old bucket in the first place - to make room for new "people" to take your spot! If this doesn't seem "fair", you are absolutely right. It's not fair, but it's what's happening throughout this country on a regular basis.

So after you (or someone else) has been "dumped" into the new bucket they are both much less full than they were before the dumping. Now there's plenty of room for the new drops to flow into the buckets without ending up on the floor. But there is a bit of a gamble here. Remember that we don't really know in advance how much water is going to flow out of either faucet. When we dumped the water, we tried to guess how many people would be moving into each area and how many phone numbers they might need. We tried to leave enough space in each bucket to handle that number of people. But what if we guessed wrong? What happens if we find that the bucket on the left is filling up much faster than the bucket on the right? What can we do? The answer is to add another bucket! This means that we have to dump some of those people again because someone has to go into the new bucket. As mentioned before, this typically means that the people closest to the "heart" of the city can keep their old area code, and people further out have to suffer the time and expense of changing their area code yet again.

POUR30.JPG (51.7 KiB) Viewed 1000 times

Overlay

When an area code begins to get so full that it might spill over there is a simple solution - let it spill over!!

POUR40.JPG (54.4 KiB) Viewed 1000 times

In some ways, the overlay is the simplest and most obvious solution. Anyone who's ever used an "overflow pan" knows that it's much easier to catch the overflow than to wrestle with multiple buckets of liquid (and wrestling with "buckets" of angry phone customers is no easier).

The overlay rule is very simple. Just keep giving out 619 numbers until there are absolutely none left. Then the next person who asks for a number gets the first 858 number. There's no prediction or judgement required. "Just give 'em out til there ain't no more left to give." No one has to change anything! It's remarkable. The people who get the new numbers are the very same people who are ordering the new numbers!

If this is so simple, why hasn't it always been done this way? The answer is that overlays are only practical because of our growing computer technology. In the "old" days, phone switching was done with real switches. Those "real" switches would route calls from area to area based on their leading digits. This made it very difficult to route numbers with the same leading digits (area codes) to different physical locations (areas). That's why area codes and (local prefixes) were traditionally linked to physical locations.

But now those "real" switches have been replaced with computer switches. And as most people should know, computers can be programmed to do almost anything. So the computer switches don't have to rely on the "area" digits to route their calls. In fact, computer switching doesn't even have to use digits at all. The internet, for example, uses a routing system based on actual names instead of numbers. These internet names are called "domain names" (like "edugateway.com"). The great thing about internet domain names is that they can be moved from one part of the country to another without any interruption in service. And now that the phone system is using more computer switches, the same should become true for our phone numbers. In other words, our full 10 digit phone numbers should eventually be "portable" to any location within the United States phone system (and possibly beyond). The common use of overlays gets us one step closer to national phone number portability.

But why haven't you mentioned dialing 11 digits (1+10) for every call in an overlay? Isn't that why many people don't like overlays?

Those are very good questions! It turns out that FCC order 96-333 (Section I, Subsection C, Paragraph 20) states:

"In this Order, we also prohibit the use of service-specific or technology-specific area code overlay plans. States may employ all-services overlays only if they also mandate 10-digit dialing for all local calls within the area affected by the area code change and ensure the availability of at least one central office code in the existing area code to every entity authorized to provide local exchange service in that area, including CMRS providers."

This is often called the "mandatory 1+10-digit dialing" requirement which is currently imposed on all overlays. This is also the most unpopular feature of overlays, and there are movements under way to repeal this mandatory 1+10-digit dialing. In fact, recent decisions by the California Public Utilities Commission have stated:

"With the availability of 1,000-block number pooling technology on the horizon, however, the previous assumptions supporting the rationale for mandatory 1+10-digit dialing must be seriously reexamined."

and

"In conjunction with consideration of amending our own policies on this issue, we plan to consider filing a petition with the FCC to eliminate the 1+10-digit dialing requirement that it places on any area in which an overlay is in use."

If these changes are adopted by the FCC, the result will be a new kind of overlay that allows 7-digit dialing for all calls made within the same area code. The best feature of these "7-digit overlays" is that no changes are required by anyone inside or outside of the overlay. Here are some features of 7-digit overlays:

+ Everyone gets to keep their same 10-digit phone number.
+ No changes are required by anyone inside the 7-digit overlay.
+ No changes are required by anyone outside the 7-digit overlay.
+ There are no wasted numbers (as with splits).
+ There are no advance notices required because nothing changes!
+ Area codes can be completely exhausted before adding any new area codes.
+ / - Eventually the new overlay numbers will be given for new phone services.

These features make 7-digit overlays the best choice for the people who manage the phone numbers and most importantly for the people who rely on them. The August 27th Petition before the CPUC requests a 6 month delay of the final split of 619/858/935 to evaluate the possibility of granting the nation's first 7-digit overlay to the people of San Diego. Please support that petition by contacting the CPUC, the FCC, and the media about this issue.

by **Bob Kuczewski** » Fri Dec 09, 2022 9:22 pm

Bob Kuczewski's June 5th 1999 Email Message to CPUC, San Diego Union Tribune and others

Date: 6/5/99 12:29AM Subject: 619 Area Code Split To: cab@cpuc.ca.gov From: Bob Kuczewski Subject: 619 Area Code Split Cc: letters@uniontrib.com, knsd13@cerf.net, news8@kfmb.com, roger@rogerhedgecock.com (Also sent to "bpr@cpuc.gov" on 6/5/99 12:48AM) (Also sent to "telcofiling@cpuc.ca.gov" on 6/5/99 12:53AM) (Also sent to "webmaster@cpuc.ca.gov" on 6/7/99 9:34AM) (Also sent to "fccinfo@fcc.gov" on 6/11/99 10:42AM) (Also sent to "consumer-affairs@cpuc.ca.gov" on 6/11/99 3:26PM) (Also sent to "BBB@cpuc.ca.gov" Betty Brandel on 6/25/99 10:56AM)0][b]Attachment A - Early E-Mail Petition Concerning 619 Area Code Split ============================================================== Dear California Public Utilities Commission (cc Local Press), I am a resident of San Diego, and I just learned of the proposed area code split affecting my phone service. In an effort to ascertain public opinion on this matter, I went with a friend to 2 local markets to conduct an informal poll of affected consumers. My poll shows that 85% of the people polled are unsatisfied with the proposed split. An even greater number (87.5%) would be in favor of a plan that would allow them to maintain their existing area code. Such a plan could be easily implemented using an "overlay" area code as has already been done in other areas. This use of an overlay has the following advantages: 1. Allows full utilization of numbers within former 619 area code 2. Saves phone numbers which would be used for "forwarding" 3. Provides economic savings to businesses who advertise 4. Enhances customer convenience and stability of access 5. Moves in the direction of portable area codes (the future) Let me expand briefly on each of these points: 1. Allows full utilization of numbers within former 619 area code This means that all 10,000,000 numbers would be usable for each area code. Each and every 619 number could be given out before any of the other numbers. This is in contrast to the fixed geographic allocation which must estimate future demand, allocate an unused buffer of reserved numbers, and then suffer from any errors in that estimate. If, for example, the north county continues to grow at an accelerated pace, then a fixed allocation may require yet another split even though there may be plenty of numbers available in the former 619 area code and the new 935 area code. An overlay, however, would allow those unused neighboring codes to be given out in the north county area. This would eliminate "wasted" phone numbers in those area codes whose growth was overestimated. 2. Saves phone numbers which would be used for "forwarding" A change in area code may be disastrous (and certainly costly) to our national and international businesses. Many of them may attempt to retain their existing number in the 619 area code and duplicate it in their new area code. This, of course, makes money for the phone company, but further reduces the available phone number pool - exactly what we don't want to happen. This is precisely the kind of conflict of interest that the CPUC is intended to oversee and eliminate. 3. Provides economic savings to businesses who advertise This is an obvious benefit to anyone using their phone number for business. The costs of new business cards, advertisements, trade listings, and many more can be significant in a competitive environment. These are costs not borne by competitors who do business in a numerically stable environment. Our local officials should be protecting our competitive position by eliminating these unnecessary changes wherever possible. Implementing an overlay would provide just such protection for our phone numbers which are an important economic asset (much like company names and trademarks). 4. Enhances customer convenience and stability of access Since San Diego is largely inhabited by non-native people, most of the 619 customers have relatives who live outside the 619 area code (and this will only increase as area codes continue to shrink). So these changes in area code require a significant effort to ensure that all the distant relatives and old friends get the updated information. Many address books will be strained and many contacts may be lost forever. There is no reason for this to occur since we have the capability to maintain our own area codes by using an area code overlay. 5. Moves in the direction of portable area codes (the future) Finally, the notion of portable area codes is already very close at hand. The increasing use of computer technology in the telecommunication industry is leading us to the availability of permanent portable phone numbers (we already have permanent portable email addresses which can be routed to us literally anywhere in the world). Since the phone number space contains 10 billion numbers, it is unlikely that the U.S. will exhaust that many numbers before we are consumed by the other problems of such a large population. In fact, we have 10 times the number of phone numbers as we have social security numbers! But we can only use these phone numbers efficiently if we can break the geographic limits that we have placed on them. In a sense, this may be the "Y2K" problem of the next century. The solution is here if we take the steps to make phone numbers portable now. Remember that you heard it from me in 1999. I certainly will. Given these benefits and the overwhelming support for an alternative solution (over 85% in my small poll), I cannot understand why the proposed split hasn't been stopped by the CPUC or any of our local politicians. Maybe there has been a misunderstanding on the part of the public concerning this problem. If that's the case, let me point out some of the flaws in the arguments for the split (and against overlays). 1. "Everyone will have to use area codes for all numbers." This is not true. Each phone may still use short numbers for local calls with local prefixes that are not in conflict. 2. "I might have to pay 'long distance' to call my neighbor." Again, this is not true. You may have to use an area code for NEW local listings, but these need not incur long distance charges or even "zone" calling charges. 3. "I wouldn't know when to use an area code when dialing." Not true. All of your existing numbers would continue to be 7-digit calls as always. The area code question would only come into play when dialing a NEW number (one that you hadn't known before the split). And how would you get such a new number? Most likely through the phone book or through information, or through an advertisement. And each of those sources would list the area code as part of the phone number. 4. "I would lose the convenience of 7-digit dialing for more and more phone numbers." This may be true, but it is going to happen anyway. The new proposed split carves up San Diego into some pretty small slices. Since we are a highly mobile society, there are many personal and business transactions that will cross these boundaries on a regular basis. It is apparent from the map that any additional splits will make 7-digit dialing a difficult proposition in any event. That is the price we pay for our growing population. There's no way around that other than restricting growth. Finally, I do want to make an observation about the proposed split. It appears to me that the areas retaining the 619 area code also appear to be the seats of power. I suspect that this is much more than a coincidence. To be honest, I was not unduly concerned about the split until I learned that it was going to affect my own personal and business phone numbers. I suspect that this is also true of those making these decisions. Therefore, as a safety check, I suggest that this split be redefined such that those making (and influencing) these decisions are the ones to be most affected. Or to ensure fairness, let's drop the 619 area code altogether and assign three new area codes to all regions. This would ensure that every one feels the same pain. In that case, we might see a little more creative effort being applied to the problem. Sincerely, Bob Kuczewski < bobk@edugateway.com > =-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=- Informal Poll of 619 Customers =-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=- Method: This poll was conducted by asking people the following two questions: 1. How do you feel about getting a new area code next week (June 12th)? 2. Would you be in favor of a plan that would allow you to keep your current area code? The poll was conducted in the parking lot of Henry's market on Governor Drive from 7:50-8:15pm and in the University Town Center Mall from around 8:30-9:00pm. Both polls were taken on June 4th 1999, and the questions were asked by two adults in their 40's (one male and one female). Participants were selected (unscientifically) as those who appeared not to be burdened by time pressure or other circumstances which might make them unwilling to participate. Results: ================================================== Raw Results: ----------------------------------------- First Site (Henry's parking lot) 1. How do you feel about getting a new area code next week (June 12th)? Male questioner: 2 Favorable 0 Don't Care 15 Unfavorable 2. Would you be in favor of a plan that would allow you to keep your current area code? Male questioner: 17 Favorable 0 Don't Care 2 Unfavorable ----------------------------------------- Second Site (UTC Mall) 1. How do you feel about getting a new area code next week (June 12th)? Male questioner: 0 Favorable 2 Don't Care 7 Unfavorable 2. Would you be in favor of a plan that would allow you to keep your current area code? Male questioner: 8 Favorable 3 Don't Care 0 Unfavorable ================================================== Results from both sites combined: ----------------------------------------- Combined Sites (Note: Female interviewer did not tally sites separately) 1. How do you feel about getting a new area code next week (June 12th)? Male questioner: 2 Favorable 2 Don't Care 22 Unfavorable Female questioner: 0 Favorable 3 Don't Care 10 Unfavorable 2. Would you be in favor of a plan that would allow you to keep your current area code? Male questioner: 25 Favorable 3 Don't Care 2 Unfavorable Female questioner: 10 Favorable 0 Don't Care 0 Unfavorable ================================================== Results from both sites and questioners combined: ----------------------------------------- Combined Male and Female Questioners 1. How do you feel about getting a new area code next week (June 12th)? 2 Favorable 5 Don't Care 32 Unfavorable 2. Would you be in favor of a plan that would allow you to keep your current area code? 35 Favorable 3 Don't Care 2 Unfavorable ================================================== Results from both sites and questioners and questions combined: ----------------------------------------- Combined Questions (assumes they are consistent negatives) 4 Satisfied with new area code 8 Don't Care 67 Unsatisfied with new area code ----------------------------------------- Percentages of Combined Questions: 5% Satisfied with new area code (4 / 79) 10% Don't Care (8 / 79) 85% Unsatisfied with new area code (67 / 79)

by **Bob Kuczewski** » Fri Dec 09, 2022 10:53 pm

Bob Kuczewski's August 27th 1999 Petition to Delay the Split by 6 Months

BEFORE THE PUBLIC UTILITIES COMMISSION
OF THE STATE OF CALIFORNIA

Order Instituting Rulemaking on the Commission's ) Own Motion Into Competition for Local Exchange ) R.95-04-043 Service ) ________________________________________________________) Order Instituting Investigation on the Commission's ) Own Motion Into Competition for Local Exchange ) I.95-04-044 Service ) ________________________________________________________)

PETITION FOR MODIFICATION AND
REQUEST FOR SIX MONTH STAY OF D.98-06-018
IN ORDER TO COMPLETE INVESTIGATION AND
CONSIDERATION OF A SEVEN DIGIT OVERLAY
BY ROBERT M. KUCZEWSKI AND OTHERS

INTRODUCTION

Pursuant to Rule 47 of the Commission's Rules of Practice and Procedure, Robert M. Kuczewski and Others (Petitioners) hereby petition for modification of D.98-06-018, issued June 4, 1998, and mailed June 5, 1998.

Petitioners seek to modify the decision with respect to the dates for "Start of Mandatory Dialing" and "End of Mandatory Dialing" for Phase 1 as shown on page 24 of D.98-06-018. Petitioner requests that these dates be extended 6 months to allow for evaluation of a seven digit overlay option which was not considered in earlier decisions. This is a timely request given the recent indications by both the FCC and the CPUC that aggressive measures are needed to reduce the explosive proliferation of area codes and the resulting disruption to customers.

The call for such "aggressive measures" suggests the possibility of implementing the nation's first seven digit overlay to minimize customer impact and maximize number conservation. The requested time extension provides for an evaluation of this possibility. While a 6 month extension might seem insufficient for such a project, this unusually short period is justified by the particularly non-disruptive nature of 7-digit overlays. In fact, it is possible to implement a 7-digit overlay without impacting a single customer. This feature obviates the need for both "practice dialing" periods and "permissive dialing" periods. This feature also greatly reduces the response time needed to relieve an endangered NPA making the 7-digit overlay a very effective and painless cure for the explosive growth in numbering demands.

COMMENTARY ON TIMELINESS OF PETITIONERS' FILING

At this late date the Petitioners must also explain why the petition could not have been presented within one year of the effective date of D.98-06-018. Petitioners respectfully submit several such explanations for this unfortunate delay.

First and foremost, the Petitioners are common citizens of San Diego who have received most of their information on this issue through the popular media. Unfortunately, the nature of popular media leads to sensationalist distortions of many important public matters. So rather than educating San Diegans about their choices, many "news" organizations sought shock appeal from the story by simply proclaiming that citizens must get ready for the new area code whether they like it or not. The underlying message of these stories was (and still is) that there's nothing to be done about the impending area code split. This misrepresentation has lead to a strong sense of alienation and frustration among San Diegans who might otherwise have taken earlier action. Fortunately, the educational efforts of the Utility Consumers' Action Network (UCAN) and the Commission's own San Diego Outreach Office have been enough to overcome this sense of helplessness for the current Petitioners.

Second, it should be noted that Robert M. Kuczewski did (coincidentally) send several e-mail messages to the CPUC and other organizations on June 5th 1999. This is exactly one year after the mailing date for D.98-06-018 which is stamped as 6/5/98. These email messages are listed here (the full text of these messages is included in Attachment A).

Date Subject of Message Recipient Carbon Copy to
6/5/99 12:29AM 619 Area Code Split cab@cpuc.ca.gov letters@uniontrib.com knsd13@cerf.net news8@kfmb.com roger@rogerhedgecock.com
6/5/99 12:48AM None bpr@cpuc.ca.gov
6/5/99 12:53AM CPUC Consumer Comments Address? telcofiling@cpuc.ca.gov

While the content and delivery mode (e-mail) of these messages may not meet the CPUC's requirements, they do indicate the Petitioners' sincere concern over the area code split. Furthermore, the technical content of these early messages is almost completely consistent with the current Petition before you.

Third, as noted in the Commissions draft report of August 3rd, 1999:

"We consider the Petitioners' stated rationale for waiting beyond one year to file the Petition to be sufficient under Rule 47(d) to warrant further consideration of the Petition on its merits. While we recognize that a number of the concerns raised in the Petition could have been raised earlier, the extent of those concerns has continued to grow as the extent of the numbering crisis becomes more apparent. Given the gravity of the problem raised by Petitioners and the growing public awareness of the problem over time, we shall consider the Petition on its merits."

The preceding observation was made regarding the mandatory 1+10-digit dialing of the 310 / 424 overlay. In this case, the public outcry did not reach its peak until the pain of mandatory 1+10-digit dialing was upon them. We expect this same effect to occur when the currently scheduled 3-way split of the 619 NPA goes into full effect. Only then will phone customers fully realize the negative consequences of this split. Petitioners assert that area code splits become even worse than area code overlays when the radius of the split regions becomes smaller than the typical drive distance between home and work. At or below that radius, customers will suddenly find a significant increase in their number of 1+10-digit calls. Petitioners state that this is worse than the overlay situation because in addition to significant 10-digit dialing, customers must also know the precise boundaries of these regions and many will have suffered the additional insult of losing their long-standing area code.

Finally (and hopefully most convincingly) the option of a 7-digit overlay was not seriously considered at the time of D.98-06-018 due to FCC order 96-333 Section I, Subsection C, Paragraph 20 which states:

20. In this Order, we also prohibit the use of service-specific or technology-specific area code overlay plans. States may employ all-services overlays only if they also mandate 10-digit dialing for all local calls within the area affected by the area code change and ensure the availability of at least one central office code in the existing area code to every entity authorized to provide local exchange service in that area, including CMRS providers.

However, as stated in the August 3, 1999 Commission Draft:

"With the availability of 1,000-block number pooling technology on the horizon, however, the previous assumptions supporting the rationale for mandatory 1+10-digit dialing must be seriously reexamined."

and

"In conjunction with consideration of amending our own policies on this issue, we plan to consider filing a petition with the FCC to eliminate the 1+10-digit dialing requirement that it places on any area in which an overlay is in use."

If the requested stay of D.98-06-018 is granted, then the timing of these policy changes could save the 619 NPA from a very unpopular split. Additionally, the largely in-tact 619 NPA would make an ideal candidate for the nation's first 7-digit overlay.

FACTS SUPPORTING SAN DIEGO AS NATION'S FIRST 7-DIGIT OVERLAY

The Petitioners assert the following facts:

The San Diego metropolitan area is about to be fractured in an irreparable manner costing the long-standing phone numbers of nearly two thirds of its citizens.
The 619 area code is estimated to be at 30% to 50% of it's capacity. This puts the 619 area code at low to moderate risk of near-term exhaustion giving ample time for considering creative alternatives to the 3-way split.
This three-way split is particularly premature in light of emerging approaches to area code management that are just around the corner (including number management techniques like pooling and creative overlay techniques like 7-digit dialing).

The Petitioners therefore request a bold course of action for the people of San Diego. Petitioners propose that the San Diego area should receive CPUC and FCC permission for the nation's first 7-digit overlay. San Diego is an ideal candidate for a 7-digit overlay for several reasons:

The 619 area code is largely in tact and has not already been fractured. This fact increases the value of maintaining 7-digit dialing without splits.
San Diego is largely a migration destination city which means that most residents have significant out-of-area contacts which must be notified of area code changes. This makes San Diegans particularly susceptible to the ill effects of the 3-way split which redefines the external phone numbers for two thirds of its citizens.
The people of San Diego are outraged at the current three-way split which forces a new phone number on nearly two-thirds of the population.
The current implementation of the 858 split has been fraught with problems and has not met the requirements for completion of the split by Dec. 12, 1999.
Current publicly available estimates indicate that the 619 area code is only at 30% to 50% utilization which allows ample time for public review of other alternatives.
The somewhat unique three-way split combined with the imminent split of the adjoining 760 NPA (also formerly part of 619) provides a rich source of 7 and 10 digit overlay options.
Prior attempts at educating San Diegans have been very poor with many customers still unaware of the impending change. In addition, all prior education has ignored the 7-digit option which is expected to be the most favored approach (based on preliminary surveys).
All of these problems with the current split have made the people of San Diego particularly receptive to alternatives that would spare them the considerable time and expense of completing the area code split. This unusual receptivity to alternatives greatly increases the impact of even the most modest educational efforts.

In addition to these reasons which make San Diego a desirable candidate, there are also additional advantages that could be transferred to most other area code relief situations. These include:

- Number Conservation - Overlays (both 10 and 7 digit) are best for number conservation because there are no numbers "locked away" in areas which experience less than predicted growth. However, 7-digit overlays have the additional advantage that they can be implemented without any advanced public notice or "practice periods". This allows the original (non-overlaid) area codes to be fully exhausted before the first overlay number is assigned.

- Number Stability - The use of 7-digit overlays provides a painless method for ensuring the stability of people's phone numbers without requiring the very unpopular 10-digit dialing of traditional overlays. It is anticipated that this number stability (and eventually portability) will be one of the historically recognized breakthroughs in our telecommunications infrastructure.

- Flexibility - A key advantage to the 7-digit overlay is that it requires NO public preparation because there is absolutely NO CHANGE to all existing services both locally and globally. This creates a "No Notification" flexibility similar to the deployment of new prefixes within an area code. This allows rapid response to unexpected demand by "stretching" neighboring overlays to cover regions of unexpected growth. In fact, the flexibility of 7-digit overlays will most likely give rise to many creative arrangements to maximize conservation and convenience for phone customers.

- Popular Acceptance - All studies have shown that mandatory 10-digit dialing is by far the most unpopular aspect of overlays. The numerics behind the growth in telecommunication services will eventually lead to more 10-digit dialing under any plan (splits, 10-digit overlays, and 7-digit overlays). However, only 7-digit overlays provide a gradual transition to this ultimate reality. And if the demand should subside (due to competing telecom options), the 7-digit overlays will have bridged the crisis with the least disruption to customers (who presumably are the most important component of this issue).

- Breaking the Area Bounds - The widespread implementation and acceptance of overlays is one more step toward breaking the bounds that tie numbers to physical areas. The internet "domain name" system has demonstrated the tremendous flexibility available when public addresses are not permanently tied to the physical addresses of the underlying medium or provider. This separation of public and physical addresses gives rise to global domain name portability. The use of multiple "area" codes within a single area opens the conceptual door to this same portability for our phone numbers. The coincidental migration from physical phone switching to computer controlled phone switching promises to provide a physical mechanism to support the conceptual notion of national phone number portability (if desired). And this portability will eventually give consumers a controlling interest in their phone numbers in a manner consistent with true "provider" competition.

Petitioners assert that all of these potential benefits more than compensate for the few objections to 7-digit overlays. In fact, the principal objections appear to arise more from attempts to be fair to carriers than to customers. And while these objections must be considered, we feel that the enormous benefits to the people of San Diego should overcome these transient "unfairnesses" to competing carriers. Additionally, efforts in number pooling and other new allocation procedures should quickly eliminate even those unfairnesses.

OVERALL PLAN

In order to provide for a favorable outcome for the people of San Diego Petitioners request extending the 619/858 permissive dialing period until San Diegans have been educated to the benefits of a 7-digit overlay. At that time either the 858 or the 935 area codes could be overlaid on top of the entire 619 area or a smaller subregion as decided by popular opinion. Note that this approach extends the life of the 619 area code considerably because it allows for complete exhaustion of the 619 numbers before any of the alternates are given out. This approach also provides for the possible re-integration of the 619/858/935 NPA with the 760/442 NPA by spanning all regions with all 5 area codes while not disturbing any existing phone service. Statistically, this provides for optimal usage of San Diego's numbering resources since all 5 area codes may be used to handle unexpected growth in all parts of the region.

POSSIBLE OUTCOMES

The outcomes are somewhat unlimited as San Diegans begin to think beyond the limitations of traditional area codes. These are just a few that might arise:

All 7-digit Overlays - Again, after extensive education, the preferred solution might be a single overlay covering the existing 619/760 areas. This pooling of area codes alone may delay the necessary deployment of the 858, 935, and 442 area codes for years to come. This combined 619/760 overlay might eventually re-homogenize the recently fractured 619 area code.

Overlapping 7-digit Overlays. The northern 760 area code could be overlaid by the 858 area code in its southern regions. The 858 overlay could then overlap both the southern end of the 760 area and the northern end of the 619 area (as currently scheduled). The 442 area code could be used to overlay the southern portion of 619, and the 935 could overlay the eastern portion of 619. This provides all regions with only 2 layers (the original 619 or 760 and one other taken from 858, 442, or 935). There are two fantastically strong benefits to this arrangement. First, it can be implemented as 7-digit overlays so that NO CHANGES are required to any existing phone service or calling habits. This alone would be a welcome advantage to the people of San Diego. The second benefit to this approach is that it pools all 5 available area codes in a flexible arrangement that can easily handle changing growth patterns. Maybe the north end experiences more growth than expected. The solution is to simply "stretch" the overlays northward to accommodate the load. This "area code" pooling is not possible with area code splits. And in fact, the ultimate imposition of overlays on top of splits for this purpose would be met with a huge outcry as customers who gave up their area codes for tiny splits will be forced into a 10 digit dialing scenario to accommodate the overlay after all.

SPECIFIC SHORT TERM REQUEST

The previous paragraphs have discussed possible approaches and final outcomes for San Diego's numbering plan. However, the only requirement at this time is time itself. Petitioners would like to take advantage of the public's heightened interest in the area code issue to properly educate them regarding their area code options. Petitioners expect commitments from local news organizations to run public service announcements which graphically depict all available options. Furthermore, any and all "Intervenor Funding" from this Petition shall be directed toward this educational campaign. Petitioners assert that this education will result in the best informed decision and the greatest customer satisfaction with the final result. After all, one of the greatest sources of dissatisfaction has been the feeling of helplessness by the people of San Diego. While this feeling may be unjustified given the previous opportunities for expression, it is a reality that can be easily corrected by a chance to evaluate all possible options.

CONCLUSION

Numerous FCC and CPUC publications and decisions have expressed the desire to pursue "aggressive measures" to extend the life of the current area code system while maintaining a high degree of customer satisfaction and comfort with the required changes. We feel that a cooperative agreement to allow additional time for the full consideration of 7-digit overlays will produce a better outcome for the people of San Diego and a valuable tool for the preservation of area codes and phone numbers on a national basis. Furthermore, the proposed 7-digit overlay would be fully contained within the existing 619 and/or 760 boundaries. We therefore feel that the people living within those boundaries should be able to make their own choice in this important matter. Please give them that choice.

Respectfully Submitted,

By: _________________________________
Robert M. Kuczewski
Date: 6/5/99 12:29AM Subject: 619 Area Code Split To: cab@cpuc.ca.gov From: Bob Kuczewski Subject: 619 Area Code Split Cc: letters@uniontrib.com, knsd13@cerf.net, news8@kfmb.com, roger@rogerhedgecock.com (Also sent to "bpr@cpuc.gov" on 6/5/99 12:48AM) (Also sent to "telcofiling@cpuc.ca.gov" on 6/5/99 12:53AM) (Also sent to "webmaster@cpuc.ca.gov" on 6/7/99 9:34AM) (Also sent to "fccinfo@fcc.gov" on 6/11/99 10:42AM) (Also sent to "consumer-affairs@cpuc.ca.gov" on 6/11/99 3:26PM) (Also sent to "BBB@cpuc.ca.gov" Betty Brandel on 6/25/99 10:56AM)0][b]Attachment A - Early E-Mail Petition Concerning 619 Area Code Split ============================================================== Dear California Public Utilities Commission (cc Local Press), I am a resident of San Diego, and I just learned of the proposed area code split affecting my phone service. In an effort to ascertain public opinion on this matter, I went with a friend to 2 local markets to conduct an informal poll of affected consumers. My poll shows that 85% of the people polled are unsatisfied with the proposed split. An even greater number (87.5%) would be in favor of a plan that would allow them to maintain their existing area code. Such a plan could be easily implemented using an "overlay" area code as has already been done in other areas. This use of an overlay has the following advantages: 1. Allows full utilization of numbers within former 619 area code 2. Saves phone numbers which would be used for "forwarding" 3. Provides economic savings to businesses who advertise 4. Enhances customer convenience and stability of access 5. Moves in the direction of portable area codes (the future) Let me expand briefly on each of these points: 1. Allows full utilization of numbers within former 619 area code This means that all 10,000,000 numbers would be usable for each area code. Each and every 619 number could be given out before any of the other numbers. This is in contrast to the fixed geographic allocation which must estimate future demand, allocate an unused buffer of reserved numbers, and then suffer from any errors in that estimate. If, for example, the north county continues to grow at an accelerated pace, then a fixed allocation may require yet another split even though there may be plenty of numbers available in the former 619 area code and the new 935 area code. An overlay, however, would allow those unused neighboring codes to be given out in the north county area. This would eliminate "wasted" phone numbers in those area codes whose growth was overestimated. 2. Saves phone numbers which would be used for "forwarding" A change in area code may be disastrous (and certainly costly) to our national and international businesses. Many of them may attempt to retain their existing number in the 619 area code and duplicate it in their new area code. This, of course, makes money for the phone company, but further reduces the available phone number pool - exactly what we don't want to happen. This is precisely the kind of conflict of interest that the CPUC is intended to oversee and eliminate. 3. Provides economic savings to businesses who advertise This is an obvious benefit to anyone using their phone number for business. The costs of new business cards, advertisements, trade listings, and many more can be significant in a competitive environment. These are costs not borne by competitors who do business in a numerically stable environment. Our local officials should be protecting our competitive position by eliminating these unnecessary changes wherever possible. Implementing an overlay would provide just such protection for our phone numbers which are an important economic asset (much like company names and trademarks). 4. Enhances customer convenience and stability of access Since San Diego is largely inhabited by non-native people, most of the 619 customers have relatives who live outside the 619 area code (and this will only increase as area codes continue to shrink). So these changes in area code require a significant effort to ensure that all the distant relatives and old friends get the updated information. Many address books will be strained and many contacts may be lost forever. There is no reason for this to occur since we have the capability to maintain our own area codes by using an area code overlay. 5. Moves in the direction of portable area codes (the future) Finally, the notion of portable area codes is already very close at hand. The increasing use of computer technology in the telecommunication industry is leading us to the availability of permanent portable phone numbers (we already have permanent portable email addresses which can be routed to us literally anywhere in the world). Since the phone number space contains 10 billion numbers, it is unlikely that the U.S. will exhaust that many numbers before we are consumed by the other problems of such a large population. In fact, we have 10 times the number of phone numbers as we have social security numbers! But we can only use these phone numbers efficiently if we can break the geographic limits that we have placed on them. In a sense, this may be the "Y2K" problem of the next century. The solution is here if we take the steps to make phone numbers portable now. Remember that you heard it from me in 1999. I certainly will. Given these benefits and the overwhelming support for an alternative solution (over 85% in my small poll), I cannot understand why the proposed split hasn't been stopped by the CPUC or any of our local politicians. Maybe there has been a misunderstanding on the part of the public concerning this problem. If that's the case, let me point out some of the flaws in the arguments for the split (and against overlays). 1. "Everyone will have to use area codes for all numbers." This is not true. Each phone may still use short numbers for local calls with local prefixes that are not in conflict. 2. "I might have to pay 'long distance' to call my neighbor." Again, this is not true. You may have to use an area code for NEW local listings, but these need not incur long distance charges or even "zone" calling charges. 3. "I wouldn't know when to use an area code when dialing." Not true. All of your existing numbers would continue to be 7-digit calls as always. The area code question would only come into play when dialing a NEW number (one that you hadn't known before the split). And how would you get such a new number? Most likely through the phone book or through information, or through an advertisement. And each of those sources would list the area code as part of the phone number. 4. "I would lose the convenience of 7-digit dialing for more and more phone numbers." This may be true, but it is going to happen anyway. The new proposed split carves up San Diego into some pretty small slices. Since we are a highly mobile society, there are many personal and business transactions that will cross these boundaries on a regular basis. It is apparent from the map that any additional splits will make 7-digit dialing a difficult proposition in any event. That is the price we pay for our growing population. There's no way around that other than restricting growth. Finally, I do want to make an observation about the proposed split. It appears to me that the areas retaining the 619 area code also appear to be the seats of power. I suspect that this is much more than a coincidence. To be honest, I was not unduly concerned about the split until I learned that it was going to affect my own personal and business phone numbers. I suspect that this is also true of those making these decisions. Therefore, as a safety check, I suggest that this split be redefined such that those making (and influencing) these decisions are the ones to be most affected. Or to ensure fairness, let's drop the 619 area code altogether and assign three new area codes to all regions. This would ensure that every one feels the same pain. In that case, we might see a little more creative effort being applied to the problem. Sincerely, Bob Kuczewski < bobk@edugateway.com > =-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=- Informal Poll of 619 Customers =-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=- Method: This poll was conducted by asking people the following two questions: 1. How do you feel about getting a new area code next week (June 12th)? 2. Would you be in favor of a plan that would allow you to keep your current area code? The poll was conducted in the parking lot of Henry's market on Governor Drive from 7:50-8:15pm and in the University Town Center Mall from around 8:30-9:00pm. Both polls were taken on June 4th 1999, and the questions were asked by two adults in their 40's (one male and one female). Participants were selected (unscientifically) as those who appeared not to be burdened by time pressure or other circumstances which might make them unwilling to participate. Results: ================================================== Raw Results: ----------------------------------------- First Site (Henry's parking lot) 1. How do you feel about getting a new area code next week (June 12th)? Male questioner: 2 Favorable 0 Don't Care 15 Unfavorable 2. Would you be in favor of a plan that would allow you to keep your current area code? Male questioner: 17 Favorable 0 Don't Care 2 Unfavorable ----------------------------------------- Second Site (UTC Mall) 1. How do you feel about getting a new area code next week (June 12th)? Male questioner: 0 Favorable 2 Don't Care 7 Unfavorable 2. Would you be in favor of a plan that would allow you to keep your current area code? Male questioner: 8 Favorable 3 Don't Care 0 Unfavorable ================================================== Results from both sites combined: ----------------------------------------- Combined Sites (Note: Female interviewer did not tally sites separately) 1. How do you feel about getting a new area code next week (June 12th)? Male questioner: 2 Favorable 2 Don't Care 22 Unfavorable Female questioner: 0 Favorable 3 Don't Care 10 Unfavorable 2. Would you be in favor of a plan that would allow you to keep your current area code? Male questioner: 25 Favorable 3 Don't Care 2 Unfavorable Female questioner: 10 Favorable 0 Don't Care 0 Unfavorable ================================================== Results from both sites and questioners combined: ----------------------------------------- Combined Male and Female Questioners 1. How do you feel about getting a new area code next week (June 12th)? 2 Favorable 5 Don't Care 32 Unfavorable 2. Would you be in favor of a plan that would allow you to keep your current area code? 35 Favorable 3 Don't Care 2 Unfavorable ================================================== Results from both sites and questioners and questions combined: ----------------------------------------- Combined Questions (assumes they are consistent negatives) 4 Satisfied with new area code 8 Don't Care 67 Unsatisfied with new area code ----------------------------------------- Percentages of Combined Questions: 5% Satisfied with new area code (4 / 79) 10% Don't Care (8 / 79) 85% Unsatisfied with new area code (67 / 79)

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