September 26, 1997 Hand Delivered



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September 26, 1997


Hand Delivered
Mr. Daniel P. Gahagan

Executive Secretary

Public Service Commission of Maryland

William Donald Schaefer Tower

6 St. Paul Street

Baltimore, Maryland 21202-6806


Re: Case No. 8582
Dear Mr. Gahagan:
This letter is in response to Order No. 73692, issued by the Commission on September 11, 1997, which directs BA-MD “to confirm or deny the contentions that seven-digit 555 dialing is technically feasible, and to explain any encumbrances with implementing seven-digit dialing for 555 services.” Order at 6. The Commission adds that it hopes BA-MD can implement a reasonable strategy for providing seven-digit dialing for 555 services.
The order suggests that the Commission has been misled about some crucial facts at issue in this matter. Initially, therefore, BA-MD would like to set the record straight.
First, the Commission may believe that BA-MD’s sister companies in Pennsylvania and West Virginia have offered 555 service for over 6 months. Order at 5. That is incorrect. The facts are that although 555 service is tariffed in those jurisdictions, the service is not being offered to any customers because of the same technical issues facing BA-MD. In fact, based on discussions with Bellcore, it is BA-MD’s understanding that, although a number of 555 telephone numbers have been assigned, 555 service is not now being offered anywhere in the country. (The one exception is 555-1212, which is directory assistance offered by a number of different entities.)
Second, the Commission may believe that it has complete authority to grant the relief requested. That is unclear. The Federal Communications Commission has issued an order which requires “mandatory 10-digit dialing for all local calls in areas served by overlays ....”1 At least one of the parties in this proceeding, moreover, has suggested that this order precludes the implementation of 7-digit dialing for 555 calls. The Washington Post Company has filed a petition with the FCC seeking clarification of the FCC’s “apparent requirement that 10 digits be dialed to complete calls to national 555 numbers in areas served by overlay area codes.”2 The FCC has not ruled on this petition, but until it does, it is at least premature for this Commission to consider implementing 7-digit dialing for 555 numbers.
Third, the Commission may believe that 555 numbers are assigned to the same entity in all, or almost all, of the area codes in the country. That is not true. 555 numbers can be assigned on a national or non-national geographical area. Of those numbers which have been assigned, 2193 numbers are national numbers, but 376 (15% of the total assigned) are not.
The assignment of 555 numbers is done by Bellcore pursuant to 555 NXX Assignment Guidelines established by the Industry Carriers Compatibility Forum (ICCF). Under those guidelines, non-national 555 numbers are assigned on a NPA (Area Code) basis.3 They also specify, regarding overlay situations, that “an entity holding a non-national 555 number in an existing geographic NPA will be given the opportunity to request assignment of the same 555 number in the new NPA. If this opportunity is declined, the 555 number in the new NPA will be available for assignment to another entity.”4 The current guidelines, therefore, anticipate that a 555 number could be assigned to two different entities in an overlay area. If that is the case, BA-MD cannot implement 7-digit dialing for 555 numbers. If two different entities are assigned the same 555 number in the 410 and 443 area codes, for example, no switches would be able to route calls to those numbers correctly if only 7 digits were dialed.
The Commission’s order suggests that BA-MD should be able to implement 7-digit dialing only for national 555 numbers, and 10-digit dialing for non-national numbers. While BA-MD will need more time to study this question, it does not seem to be a practical solution. At this point, BA-MD believes it would be required to modify the translations in every BA-MD switch to translate each and every 555 number individually to determine its specific routing, i.e., 7 digits or 10 digits. This process would be extremely labor intensive, and continuous. Every time a new 555 number was assigned, additional translation work would have to be done in all switches. While BA-MD has not had sufficient time to fully assess the feasibility or impact of this approach, it is possible that this work would cost so much that 555 service could not be offered at a price customers would be willing to pay.
A different approach would be to modify the assignment guidelines for 555 numbers adopted by the Industry Numbering Committee. Those guidelines could be amended to mandate that different entities could not be assigned the same 555 number in the existing NPA and the corresponding overlay NPA. Until those national guidelines are changed, however, the Commission should not require 7-digit dialing for 555 numbers.
Moreover, the Commission should not necessarily advocate such a change in the guidelines. Considerations which suggest that such a change would not be in the public interest include:
1. Discrimination Claims by Other Information Service Providers
555 codes are similar to 976, 936 and 915 codes. Granting an exception for 555 numbers could afford CVS, the Washington Post and future holders of 555 codes a competitive advantage over other information service providers. This would open the door for all other information services companies to petition the Commission for additional exceptions to the 10-digit dialing requirement.
2. Customer Confusion
The education campaign associated with 10-digit dialing has been very successful in Maryland. Mandatory 10-digit dialing was implemented on May 1, 1997. Since then Marylanders have become accustomed to thinking in terms of 10-digit dialing. If an exception for 555 numbers were introduced now, there clearly would be confusion. This confusion would be exacerbated if not all 555 numbers were exempt, resulting in a hit or miss dialing strategy for customers calling 555 numbers.
For the reasons set forth above, BA-MD cannot, under the current national assignment guidelines, recommend “a reasonable strategy for providing seven-digit dialing for 555 numbers held by the same entity in all (or most) area codes.” Order at 6. There is no legitimate reason, however, for the Commission to refer this matter to the Hearing Examiner Division at this time. At the very least, the Commission should defer any action until the FCC rules on the Washington Post’s petition.

Respectfully submitted,



cc: All Parties of Record, Case No. 8582

1 In the Matters of Implementation of the Local Competition Provisions of the Telecommunications Act of 1996; Interconnection Between Local Exchange Carriers and Commercial Mobile Radio Service Providers; Area Code Relief Plan for Dallas and Houston, Ordered by the Public Utility Commission of Texas; Administration of the North American Numbering Plan; and Proposed 708 Relief Plan and 630 Numbering Plan Area Code by Ameritech-Illinois, CC Docket No. 96-98 et al., Second Report and Order and Memorandum Opinion and Order, ¶ 287 (released August 8, 1996) (emphasis added).


2 In the Matter of Implementation of Local Competition Provision of the Telecommunications Act of 1996, CC Docket No. 96-98, Petition for Clarification of the Washington Post Company, dated October 7, 1996 at 1.


3 ICCF 555 NXX Assignment Guidelines, p.4, ¶ 3.1.2.


4 Id. p.6, ¶ 3.11.




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