**Before the**

**Federal Communications Commission**

**Washington, D.C. 20554**

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| In the Matter of                 | *  | CC Docket No. 99-200         |
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| Petition of the Connecticut      | ** |                              |
| Department of                    |    |                              |
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| Public Utility Control for       | *) |                              |
| Delegated Authority to Implement | ** |                              |
| Specialized Transitional         |    |                              |
| Overlays                         | *  |                              |
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+----------------------------------+----+------------------------------+

**MEMORANDUM OPINION AND ORDER**

**Adopted: May 16, 2003 Released: May 23, 2003**

By the Commission: Commissioners Copps and Martin issuing separate
statements.

# INtroduction

1.  In this order, we conditionally grant the Connecticut Department of
    Public Utility Control's (Connecticut Department) petition to
    implement specialized overlays (SOs) for the 203 and 860 numbering
    plan areas (NPAs or area codes). [^1] Specifically, we delegate
    authority to the Connecticut Department to implement a single
    transitional SO for both the 203 and 860 area codes. Prior to
    implementation of the SO, however, the Connecticut Department must
    determine the specific non-geographic sensitive services that will
    be included in the SO and submit its implementation plan for review
    and approval by the Wireline Competition Bureau (Bureau). Further,
    we limit the duration of the SO to three years, after which the
    Connecticut Department shall transition the SO to an all-services
    overlay (i.e., an area code that will include all service types,
    regardless of use or technology). We find that implementation of a
    single SO in Connecticut, subject to the modifications stated
    herein, is consistent with our numbering resource optimization
    policies because it avoids the use of an additional area code and
    extends the lifespans of the existing Connecticut area codes.
    Moreover, the transitional nature of the SO will minimize the cost
    and inconvenience of frequent area code changes because, eventually,
    all carriers will be allowed to receive numbers from the SO area
    code. Accordingly, we find that the benefits of making more
    numbering resources available with a single SO outweigh any
    potential discriminatory effect.

# BACKGROUND

## The 1996 Act and Commission Rules

2.  Section 251(e) of the Communications Act of 1934, as amended (the
    Act), gives the Commission plenary jurisdiction over the North
    American Numbering Plan (NANP) and related telephone numbering
    issues in the United States.[^2] The Commission initially prohibited
    the use of SOs after determining that they were unreasonably
    discriminatory and unjust in violation of sections 201(b) and 202(a)
    of the Act.[^3] In the *Numbering Resource Optimization Third Report
    and Order,* the Commission lifted the ban on SOs due, among other
    things, to the urgency presented by the increasing demand for the
    finite supply of telephone numbers.[^4] In that order, the
    Commission stated that it would consider requests for authority to
    implement SOs on a case-by-case basis to minimize any adverse impact
    on customers and service providers. The Commission directed state
    commissions seeking authority to implement SOs to discuss why
    implementation of an SO would be superior to the implementation of
    an all-services overlay. The Commission also set forth eight
    criteria for state commissions to address in SO petitions: (1) the
    technologies or services to be included in the SO; (2) the
    geographic area to be covered; (3) whether the SO will be
    transitional; (4) when the SO will be implemented, and, if a
    transitional SO is proposed, when the SO will become an all-services
    overlay; (5) whether the SO will include take-backs of telephone
    numbers from existing customers; (6) whether there will be ten-digit
    dialing in the SO and the underlying area code(s); (7) whether the
    SO and the underlying area code(s) will be subject to rationing;
    and (8) whether the SO will cover an area in which pooling takes
    place.[^5]

## The Petition

3.  The Connecticut Department requests delegated authority to implement
    two transitional SOs: one over each of the existing geographic area
    codes in Connecticut (the 203 and 860 NPAs).[^6] The 203 NPA is
    projected to exhaust in the third quarter of 2004, and the 860 NPA
    is projected to exhaust in the second quarter of 2005.[^7] The
    Connecticut Department seeks to implement an SO in each NPA that
    will transition into an all-services overlay once the underlying
    NPAs exhaust.[^8] It asserts that an SO is superior to an
    all-services overlay in Connecticut because exhaust of the
    underlying area codes will be delayed as telephone numbers for
    wireless and non-geographic sensitive services are assigned from the
    SO area code rather than the 203 or 860 area codes.[^9] In response
    to the criteria established by the Commission, the Connecticut
    Department proposes to: (1) prospectively include wireless and
    non-geographic sensitive services in the SO; (2) implement an SO
    over each of the existing geographic area codes separately; (3) have
    transitional SOs; (4) transition the SOs to all-services overlays
    when the underlying NPAs exhaust; (5) take back unopened blocks of
    numbers from wireless providers, but not numbers that have been
    assigned to wireless customers; (6) require ten-digit-dialing six
    months after implementation; (7) not impose rationing; and (8)
    require carriers in the SO to participate in pooling.[^10]

# Discussion

## Introduction

4.  We conditionally grant the Connecticut Department's petition.
    Although we find that, when viewed as a whole, the Connecticut
    Department substantially addresses the criteria established by the
    Commission in the *Numbering Resource Optimization Third Report and
    Order*, we require additional details with respect to the specific
    non-geographic sensitive services to be included in the SO. [^11]
    Without these details, we are unable to fully assess whether this
    aspect of the Connecticut Department's proposal furthers our
    numbering resource optimization goals. Therefore, prior to
    implementation of the SO, the Connecticut Department must submit to
    the Bureau its implementation plan detailing the specific
    non-geographic sensitive services that it intends to include in the
    SO. We delegate authority to the Bureau to review and approve the
    Connecticut Department's implementation plan before the SO can be
    implemented.

5.  We further find that two aspects of the Connecticut Department's
    proposal should be modified. Specifically, we find that the
    introduction of a single SO in Connecticut is preferable to a
    separate SO over each NPA, as proposed by the Connecticut
    Department, because the Connecticut Department has not demonstrated
    that the demand for numbering resources in the state justifies two
    SOs at this time. Furthermore, expanding the geographic scope of one
    area code to overlay the entire state will preserve one area code
    for future use, thereby helping extend the life of the NANP. We also
    find that that the SO should transition to an all-services overlay
    three years after implementation of the SO, rather than
    transitioning when the underlying NPAs exhaust, as proposed by the
    Connecticut Department. Requiring the SO to transition three years
    after its implementation balances the need to minimize the potential
    discriminatory impact of an SO with the need to increase the
    numbering use efficiencies in the underlying NPAs and the SO. In
    addition, we believe that allowing the state to preserve the numbers
    in the underlying NPAs for geographic-specific uses for a period of
    three years accommodates the state's goals, while at the same time
    minimizing any anti-competitive effects associated with an
    indefinite transition period.

6.  Assuming the Connecticut Department is able to adequately detail and
    explain the rationale for the non-geographic sensitive services to
    be included in the SO, we find the SO, as modified, offers similar
    benefits as an all-services overlay for the 203 and 860 area codes.
    A single transitional SO will promote number optimization efforts in
    Connecticut by making more numbering resources available to all
    carriers. In addition, because all service providers will eventually
    be able to receive numbering resources from the SO code after it has
    transitioned to an all-services overlay, the plan does not have the
    potential discriminatory impact of a permanent SO. Implementation of
    the SO also will delay exhaust of the underlying area codes as
    telephone numbers for wireless and non-geographic sensitive services
    are assigned from the SO rather than from the underlying area code.
    An SO also will help preserve the geographic identity of the
    underlying NPAs prior to transition to an all-services overlay, a
    benefit which states and consumers have determined to be important.
    Finally, the SO will minimize the cost and inconvenience of frequent
    area code changes.

## Specialized Overlay Criteria

7.  In the *Numbering Resource Optimization Third Report and Order*, the
    Commission stated that state commissions seeking delegated authority
    to implement SOs should specifically address eight criteria
    described in that order.[^12] Below we address the information
    provided by the Connecticut Department in response to each of those
    criteria.

8.  *Geographic Area*. We delegate to the Connecticut Department
    authority to implement a single transitional SO covering both the
    203 and 860 NPAs. Although the Connecticut Department seeks to
    implement an SO in each NPA, we agree with commenters that two SOs
    would be inefficient here and could actually help accelerate the
    exhaust of the NANP. [^13] In support of its petition, the
    Connecticut Department states that because the 203 and 860 area
    codes are projected to exhaust, new area codes already are planned
    for each of them.[^14] We note, however, that the Connecticut
    Department failed to provide data demonstrating that the demand for
    numbers justifies two SOs. In addition, the expanded SO is ideal
    from a numbering resource optimization perspective because it will
    reduce the demand for numbers in multiple area codes. Further, the
    increased number of subscribers included in the SO will lead to
    better utilization of numbering resources.[^15] Thus, we find that
    the implementation of two SOs is not necessary and a single SO is
    preferable.[^16]

9.  *Transitional SOs*. We find the Connecticut Department's proposal to
    implement a transitional SO, as modified herein, is consistent with
    our numbering resource optimization goals.[^17] We agree with the
    Connecticut Department, AT&T Wireless, CTIA, and SBC that a
    transitional SO is reasonable because it will eventually include all
    providers, and thus decrease the likelihood that numbers will become
    stranded.[^18] Decreasing the likelihood that the numbers in the SO
    will be underutilized, in turn, promotes our numbering resource
    optimization goals.[^19] A transitional SO will also limit the
    potentially discriminatory effects of creating a permanent SO.

10. *Timing of Transition*. We find that the proposed SO should
    transition to an all-services overlay three years after its
    implementation, rather than upon exhaust of the underlying NPAs as
    proposed by the Connecticut Department.[^20] We agree with
    commenters that delaying the transition until the underlying area
    codes exhaust could result in the SO being in place indefinitely,
    and possibly permanently.[^21] The Connecticut Department
    anticipates that as telephone number assignment practices become
    more efficient, the lives of the underlying NPAs could be extended
    indefinitely.[^22] Because it cannot be determined with certainty
    when the underlying NPAs will exhaust, we agree with commenters that
    the exhaust trigger proposed by the Connecticut Department is too
    ambiguous.[^23] We find that the transition period should be fixed
    to minimize any potential anti-competitive results from the
    differential assignment of numbers to targeted industry segments and
    groups of consumers for an indefinite period. We agree with Nextel
    that a three-year period for the SO is reasonable, because it will
    establish a predictable limit on the duration of the SO.[^24] It
    will also provide an opportunity for all of the NPAs to realize the
    benefits of wireless pooling and porting.[^25]

11. In the *Numbering Resource Optimization Third Report and Order*, the
    Commission discussed the possibility of using participation in
    pooling as a transition trigger.[^26] According to the Connecticut
    Department, because wireless carriers were scheduled to begin
    participating in pooling in the 203 and 860 area codes by November
    24, 2002, a transition trigger based on the pooling requirement
    would not provide enough time to realize the benefits of the
    SO.[^27] We agree with the Connecticut Department that a pooling
    trigger is not appropriate. A pooling trigger would diminish the
    benefits of the SO by limiting the state's ability to preserve the
    underlying area codes to a short period of time.[^28] Moreover,
    since wireless carriers are now participating in pooling, a pooling
    trigger is not viable.

12. *Take-Backs.*[^29] We find the Connecticut Department's proposal to
    limit use of take-backs is reasonable. The Connecticut Department
    proposes to require wireless carriers to return all uncontaminated
    blocks (i.e. thousands-blocks and central office codes or NXXs) from
    existing area codes to the North American Numbering Plan
    Administrator (NANPA) or Pooling Administrator (PA) in order to
    further optimize the use of numbering resources in the existing
    NPAs.[^30] The Connecticut Department explains that the public
    interest is not served if consumers are required to "turn back"
    their existing telephone numbers and undergo the unnecessary expense
    and inconvenience often associated with changing telephone
    numbers.[^31] We agree with commenters that limiting take-backs to
    unopened blocks is reasonable.[^32] We find that the Connecticut
    Department's proposal to limit take-back to blocks that are not in
    use will ensure that consumers will not have to relinquish their
    numbers, carriers will not incur reprogramming costs, and returning
    completely unused blocks can be done at minimal cost to the
    carriers.

13. *Ten-Digit Dialing*.[^33] We find that the Connecticut Department's
    request for a six-month waiver of the ten-digit-dialing requirement
    for overlays is reasonable.[^34] The Connecticut Department
    requested a six-month waiver of the ten-digit dialing rule to
    provide it with an opportunity to develop and implement a consumer
    education program.[^35] This waiver will allow consumer education to
    occur prior to the implementation of ten-digit dialing, help
    minimize consumer confusion, and facilitate a smooth transition from
    seven-digit to ten-digit dialing. Because ten-digit dialing is
    currently in effect in almost half of the state,[^36] the
    Connecticut Department presumably can use this six-month waiver to
    build upon the knowledge it has gained from its earlier
    implementation of ten-digit dialing and ensure a smooth transition
    to ten-digit dialing throughout the state.

14. *Rationing*.[^37] We agree with the Connecticut Department and
    commenters, and find that rationing is not necessary in the SO or
    the underlying NPAs.[^38] The Commission has previously stated that
    any SO that achieves the purposes for which it is implemented
    (increasing the availability of numbering resources for all
    carriers) should not be subject to rationing.[^39] Because the
    proposed SO will allow reasonable access to numbers by all carriers
    and promote our numbering resource optimization efforts, we find
    that rationing is not necessary in the SO or the underlying NPAs.

15. *Thousands-Block Number Pooling.* We find that thousands-block
    number pooling should be implemented in the proposed SO as in the
    underlying NPAs.[^40] As with all-service overlays, pooling should
    be implemented in SOs that cover an area in which pooling is taking
    place, among other things, to ensure that carriers operating within
    the area are subject to the same requirements. The Connecticut
    Department and commenters recognize that because pooling has been
    implemented in the 203 and 860 area codes, pooling will also be
    required in the SO.[^41] Doing so will increase the efficient
    allocation of numbering resources throughout the state.

16. *Technologies and Services*. We tentatively agree to allow the
    Connecticut Department to limit the technologies and services to be
    included in the SO. However, before final approval is granted, the
    Connecticut Department must submit additional information detailing
    the technologies and services to be included in the proposed SO. The
    Connecticut Department proposes to include wireless and
    non-geographic sensitive services in the SO.[^42] The Connecticut
    Department specifically proposes to include non-geographic sensitive
    services that use high-speed transport lines, such as those
    connected to automatic teller machines (ATMs) or point of sale (POS)
    terminals, and unified messaging (UM) services.[^43] Although we
    share commenters' concerns about the lack of specificity in the
    Connecticut Department's discussion of the technologies and services
    to be included in the SO,[^44] we find that it is reasonable to
    conditionally grant the petition.

17. Because Connecticut is the first state to request delegated
    authority to implement SOs, we believe it is important to give the
    Connecticut Department assurance that the proposal substantially
    complies with the criteria enumerated in the *Numbering Resource
    Optimization Third Report and Order*.[^45] We trust that this
    assurance will allow the Connecticut Department to develop
    expeditiously its implementation plan and provide the Commission
    with the information it needs to approve the grant. Furthermore,
    this conditional grant will provide the Connecticut Department with
    a framework to develop its implementation plan, which in turn will
    enable the Connecticut Department to provide the Commission with the
    information it needs to approve the grant of delegated authority to
    implement the SO. Once the Commission approves this information, the
    Connecticut Department should be able to quickly implement its SO
    plan.

18. The Connecticut Department must provide greater specificity
    regarding the non-geographic sensitive services, not merely examples
    of services that may be included. Any proposal that refers to the
    purpose for which the numbering resources are used (e.g., high-speed
    transport for ATMs and POS transactions) must indicate how it
    proposes to identify the services for inclusion in the SO. For
    example, the Connecticut Department must identify the specific
    services that are associated with telephone numbers if it proposes
    to include high-speed transport services in the SO.[^46] With
    respect to UM services, we agree with j2 Global Communications that
    UM can refer to different services such as email facsimile services
    and vehicle response services.[^47] Because these service providers
    will need adequate notice if their services are going to be included
    in the SO, any ambiguity regarding what services will be in the SO
    must be eliminated prior to implementation of the SO. We, therefore,
    require the Connecticut Department to provide a complete list of the
    services it proposes to include in the SO and specify how each
    service will be identified.

19. The Connecticut Department proposes to conduct public workshops to
    help identify which services should be included in the SO and
    formulate the terms and conditions under which non-geographic
    sensitive services would be included in the SO.[^48] We support the
    Connecticut Department's plan to conduct such workshops and find
    that these workshops could be a valuable tool for determining which
    non-geographic sensitive services would be included in the SO. These
    workshops can help the Connecticut Department address consumer and
    industry concerns as well. These workshops could also help the
    Connecticut Department obtain the additional information we have
    requested. We, therefore, encourage the Connecticut Department to
    conduct workshops prior to filing its implementation plan with the
    Bureau. Once the Connecticut Department files its implementation
    plan and the Bureau reviews and approves the technologies or
    services to be included in the SO, the Connecticut Department may
    implement a single transitional SO as herein described.

# ORDERing ClauseS

20. Accordingly, IT IS ORDERED that pursuant to the authority contained
    in Sections 1, 3, 4, 201-205, 251 of the Communications Act of 1934,
    as amended, 47 U.S.C. §§ 151, 153, 154, 201-205, and 251, this ORDER
    is hereby adopted.

21. IT IS FURTHER ORDERED that pursuant to the authority contained in
    Sections 1, 3, 4, 201-205, 251 of the Communications Act of 1934, as
    amended, 47 U.S.C. §§ 151, 153, 154, 201-205, and 251, and section
    52.19(c) of the Commission's Rules, 47 C.F.R. § 52.19(c) the
    petition filed by the Connecticut Department of Public Utility
    Control, is CONDITIONALLY GRANTED AS MODIFIED HEREIN upon the
    submission of additional information by the Connecticut Department
    and the approval of such information by the Wireline Competition
    Bureau, as discussed herein.

22. IT IS FURTHER ORDERED that pursuant to the authority contained in
    Sections 1.3 and 52.19(c) of the Commission's Rules, 47 C.F.R. §§
    1.3, 52.19(c), and the delegated authority in sections 0.91 and
    0.291, of the Commission's Rules, 47 C.F.R. §§ 0.91, 0.291 that the
    Connecticut Department of Public Utility Control's Request for
    Temporary Waiver of 47 C.F.R. Section 52.19(c)(3)(ii) is GRANTED for
    a period of six months from the date of implementation of the SO
    code.

    FEDERAL COMMUNICATIONS COMMISSION

> Marlene H. Dortch
>
> Secretary

![](media/image1.wmf){width="6.944444444444445e-4in"
height="6.944444444444445e-4in"}

**SEPARATE STATEMENT OF**

**COMMISSIONER MICHAEL J. COPPS**

Re: *Petition of the Connecticut Department of Public Utility Control
for Delegated*

*Authority to Implement Specialized Transitional Overlays*

All of us share the frustration consumers are experiencing with the
proliferation of new telephone numbers and area codes. But number
conservation is not an issue that the federal government can---or
should---undertake on its own. We need to work closely with state public
utility commissions on numbering issues. States have an integral role to
play in number conservation efforts. That is why I am pleased that we
address the petition from the Connecticut Department of Public Utility
Control today. At the same time, I sincerely hope that other states that
follow the path Connecticut blazes here receive a speedier and less
conditional response from the Commission. I also hope that the
Commission redoubles its efforts to address expeditiously other
petitions concerning numbering, including the petition filed last year
by the California Public Utilities Commission concerning our
contamination threshold requirement.

**SEPARATE STATEMENT OF**

**COMMISSIONER KEVIN J. MARTIN**

Re: *Petition of the Connecticut Department of Public Utility Control
for Delegated*

*Authority to Implement Specialized Transitional Overlays*

While I am pleased that we are taking action on the Connecticut
Department of Public Utility Control's petition to implement specialized
overlays, I would have granted the State of Connecticut greater
flexibility by not imposing the conditions set forth in today's
decision.

Nearly two years ago, I supported the Commission's effort to grant the
requests of several States to lift the prohibition on technology
specific and service specific overlays. As I have said before, giving
States additional flexibility in how to address numbering issues is
crucial, because it is the State Commissions, not this Commission, that
feel the outcry from consumers when numbering conservation measures are
adopted.[^49]

I expect this Commission to continue to work with the States to
facilitate their number conservation plans and look forward to quick
Commission action on other pending numbering petitions.

[^1]: Service-specific and technology specific overlays are collectively
    referred to as specialized overlays (SOs). In a service-specific
    overlay, numbering resources are assigned to carriers that provide a
    particular type of service or services, such as unified messaging
    and/or vehicle response (e.g., OnStar) services. In contrast,
    numbering resources in a technology-specific overlay are assigned to
    carriers that use a particular type of technology or technologies,
    such as wireless. *See* *Numbering Resource Optimization*, Third
    Report and Order and Second Order on Reconsideration, CC Docket No.
    96-98 and CC Docket No. 99-200, 17 FCC Rcd 252, 282 n.173 (2001)
    (*Numbering Resource Optimization Third Report and Order*).

[^2]: Pub. L. No. 104-104, 110 Stat. 56 (1996 Act). The 1996 Act amended
    the Communications Act of 1934, 47 U.S.C. §§ 151-174. Section
    251(e)(1) states:

    > The Commission shall designate one or more impartial entities to
    > administer telecommunications numbering and to make such numbers
    > available on an equitable basis. The Commission shall have
    > exclusive jurisdiction over those portions of the North American
    > Numbering Plan that pertain to the United States. Nothing in this
    > paragraph shall preclude the Commission from delegating to State
    > commissions or other entities all or any portion of such
    > jurisdiction.

[^3]: *See Numbering Resource Optimization Third Report and Order*, 17
    FCC Rcd at 283, *citing Proposed 708 Relief Plan and 630 Numbering
    Plan Area Code by Ameritech -- Illinois*, Declaratory Ruling and
    Order, 10 FCC Rcd 4596, 4607-12 (1996) (*Ameritech Order*); *see
    also* 47 U.S.C. §§ 201(b), 202(a). Specifically, the Commission
    initially stated that SOs hinder entry into the telecommunications
    marketplace by: (1) failing to make numbering resources available on
    an efficient, timely basis to telecommunications services providers;
    and (2) providing particular industry segments and groups of
    consumers an unfair advantage. *See Implementation of the Local
    Competition Provisions of the Telecommunications Act of 1996,*
    Second Report and Order and Memorandum Opinion and Order, 11 FCC Rcd
    19392, 19527-28 (1996) (*Local Competition Second Report and
    Order*), *vacated in part*, California v. FCC, 124 F.3d 934 (8^th^
    Cir. 1997), *rev'd* AT&T v. Iowa Utils. Bd., 199 S. Ct. 721 (1999).

[^4]: *See Numbering Resource Optimization Third Report and Order*, 17
    FCC Rcd at 285.

[^5]: *Id*. at 288.

[^6]: On March 12, 2001, the Connecticut Department filed a petition for
    authority to conduct a transitional SO trial. *See Petition of the
    Connecticut Department of Public Utility Control for Authority to
    Conduct a Transitional Service/Technology-Specific Overlay Trial*
    (filed Mar. 12, 2001) (Connecticut Department Initial Petition). On
    January 18, 2002, the Connecticut Department supplemented its
    earlier filing. *See Petition of the Connecticut Department of
    Public Utility Control for Authority to Implement a Transitional
    Service/Technology-Specific Overlay in Connecticut* (filed Jan. 18,
    2002) (Connecticut Department Supplemental Petition). *See also
    Common Carrier Bureau Seeks Comment on the Petition of the
    Connecticut Department of Public Utility Control for Delegated
    Authority to Implement Transitional Service-Specific and
    Technology-Specific Overlays*, Public Notice, 17 FCC Rcd 2168
    (2002). Comments and reply comments in response to this public
    notice will be referred to as Supplemental Petition Comments and
    Supplemental Petition Reply Comments, respectively. On May 9, 2002,
    the Connecticut Department filed information further supplementing
    its petition. *See Petition of the Connecticut Department of Public
    Utility Control for Authority to Conduct a Transitional Service
    Technology Specific Service Overlay Trail -- Supplemental
    Information* (filed May 9, 2002) (Connecticut Department
    Supplemental Information Filing). *See also Wireline Competition
    Bureau Seeks Comment on the Supplemental Information to the
    Supplemental Petition of the Connecticut Department of Public
    Utility Control for Authority to Conduct A Transitional Service
    Technology-Specific Overlay*, Public Notice, 17 FCC Rcd 10513
    (2002). Comments and reply comments filed in response to this public
    notice will be referred to as Supplemental Information Comments and
    Supplemental Information Reply Comments, respectively. Collectively,
    the Connecticut Department's filings will be referred to as the
    Connecticut Department Petition.

[^7]: North American Numbering Plan Administrator 2002 NRUF and NPA
    Exhaust Analysis, June 5, 2002 available at
    <http://www.nanpa.com/pdf/NRUF/nruf061501results.pdf> (NANPA June
    2002 Exhaust Data). *See also* Changes as of May 9, 2003, available
    at <http://www.nanpa.com/pdf/NRUF/05_09_03_delta_nruf.pdf> (NANPA
    May 2003 Updated Exhaust Data). Jeopardy was declared for both the
    203 and 860 NPAs in 1998. *See* North American Numbering Plan
    Administrator Jeopardy Declaration Table, available at
    <http://www.nanpa.com/news/jeopardy_declaration_table.html>.
    Jeopardy is defined as a situation where the forecasted and/or
    actual demand for NXX resources will exceed the known supply during
    the planning/implementation interval for relief. *See Numbering
    Resource Optimization*, First Report and Order and Further Notice of
    Proposed Rulemaking, CC Docket No. 99-200, 15 FCC Rcd 7574, 7511
    n.164 (2000), *citing* CO Code Assignment Guidelines at §§ 9.3,
    13.0.

[^8]: Connecticut Department Supplemental Petition at 6-7.

[^9]: *See* Connecticut Department Supplemental Information Filing at
    1-2.

[^10]: Connecticut Department Supplemental Petition at 4-8; Connecticut
    Department Supplemental Information Filing at 3-6; Connecticut
    Department Supplemental Information Reply Comments at 2-6.

[^11]: *Numbering Resource Optimization Third Report and Order*, 17 FCC
    Rcd at 288.

[^12]: *Id*.

[^13]: *See* AT&T Wireless Supplemental Petition Comments at 7; Nextel
    Supplemental Petition Comments at 4; SBC Supplemental Petition
    Comments at 3; Sprint PCS Supplemental Petition Comments at 25-26;
    Verizon Supplemental Petition Comments at 2; AT&T Wireless
    Supplemental Information Comments at 2.

[^14]: Connecticut Department Supplemental Petition at 6. *See* *also*
    AT&T Wireless Supplemental Petition Comments at 7; Nextel
    Supplemental Petition Comments at 4; Sprint PCS Supplemental
    Petition Comments at 25-26; Verizon Supplemental Petition Comments
    at 2; AT&T Wireless Supplemental Information Comments at 2.

[^15]: *See* *Numbering Resource Optimization Third Report and Order*,
    17 FCC Rcd at 289.

[^16]: We note that by expanding the geographic area of the SO we do not
    intend to change the routing and rate of local calls. *See* Sprint
    PCS Supplemental Petition Comments at 21-23.

[^17]: Connecticut Department Supplemental Petition at 7; Connecticut
    Department Supplemental Information Filing at 4-5.

[^18]: *See* AT&T Wireless Supplemental Petition Comments at 4; CTIA
    Supplemental Petition Comments at 3-4; SBC Supplemental Petition
    Comments at 3.

[^19]: *See* *Numbering Resource Optimization Third Report and Order*,
    17 FCC Rcd at 289.

[^20]: Connecticut Department Supplemental Petition at 7; Connecticut
    Department Supplemental Information Filing at 4-5.

[^21]: *See* AT&T Wireless Supplemental Petition Comments at 4-6; CTIA
    Supplemental Petition Comments at 4-5; Cingular Supplemental
    Petition Comments at 6-9; Nextel Supplemental Petition Comments at
    4; Verizon Supplemental Petition Comments at 2; Verizon Wireless
    Supplemental Petition Comments at 6-7; VoiceStream Supplemental
    Petition Comments at 3-4; WorldCom Supplemental Petition Comments at
    3; AT&T Wireless Supplemental Petition Reply Comments at 5-6;
    Cingular Supplemental Information Comments at 6-9; Verizon Wireless
    Supplemental Information Comments at 6.

[^22]: Connecticut Department Supplemental Petition at 7.

[^23]: *See* AT&T Wireless Supplemental Petition Comments at 4-6; CTIA
    Supplemental Petition Comments at 4-5; Cingular Supplemental
    Petition Comments at 6-9; Nextel Supplemental Petition Comments at
    4; Verizon Supplemental Petition Comments at 2; VoiceStream
    Supplemental Petition Comments at 3-4; AT&T Wireless Supplemental
    Petition Reply Comments at 5-6; Verizon Wireless Supplemental
    Information Comments at 6.

[^24]: When Nextel filed its comments in February 2002, it suggested
    that the transition occur on the earlier of the exhaust of an
    underlying NPA or on a date to be selected by the industry in 2005.
    *See* Nextel Supplemental Petition Comments at 4.

[^25]: Wireless carriers are required to provide local number
    portability by November 24, 2003, in switches for which another
    carrier has made a request for local number portability. *See
    Verizon Wireless Petition for Partial Forbearance from the
    Commercial Mobile Radio Services Number Portability Obligation,* WT
    Docket No. 01-184*,* and *Telephone Number Portability,* CC Docket
    No. 95-116, Memorandum Opinion and Order, 17 FCC Rcd 14972, appeal
    pending (2002) (*Verizon Wireless LNP Forbearance Order*).

[^26]: *See* *Numbering Resource Optimization Third Report and Order*,
    17 FCC Rcd at 290-91.

[^27]: Connecticut Department Supplemental Information Filing at 4.

[^28]: *See Numbering Resource Optimization Third Report and Order*,17
    FCC Rcd at 390.

[^29]: Take-backs occur when carriers surrender their numbers in the
    underlying area code and obtain numbers from the new area code.
    *See* *Numbering Resource Optimization Third Report and Order*, 17
    FCC Rcd at 287.

[^30]: Connecticut Department Supplemental Petition at 7; Connecticut
    Department Supplemental Information Filing at 5.

[^31]: Connecticut Department Supplemental Petition at 7-8.

[^32]: *See* Cingular Supplemental Petition Comments at 6; Nextel
    Supplemental Petition Comments at 5; SBC Supplemental Petition
    Comments at 3-4; Sprint PCS Supplemental Petition Comments at 18;
    AT&T Wireless Supplemental Petition Reply Comments at 4-5; Nextel
    Supplemental Information Comments at 5. Nextel seeks assurances that
    new replacement NXXs are immediately available. *See* Nextel
    Supplemental Petition Comments at 5; Nextel Supplemental Information
    Comments at 3.

[^33]: Ten-digit dialing requires a caller to dial the area code
    followed by the seven-digit phone number for calls within the same
    NPA. The ten-digit dialing rule states that no area code overlay may
    be implemented unless there is mandatory ten-digit dialing for all
    calls in the geographic area covered by the overlay. *See* 47 C.F.R.
    § 52.19(c)(3)(ii).

[^34]: Nextel concurs. *See* Nextel Supplemental Information Comments at
    3-4. Other commenters also support a short waiver. *See* AT&T
    Wireless Supplemental Information Comments at 2; CTIA Supplemental
    Information Comments at 6-7. Sprint PCS recommends a four-month
    permissive dialing period. *See* Sprint PCS Supplemental Information
    Comments, Attachment at 6.

[^35]: Connecticut Department Supplemental Information Reply Comments at
    4-5. The Connecticut Department initially did not believe that
    ten-digit dialing would be necessary and deferred to the Commission
    for direction. *See* Connecticut Department Supplemental Petition at
    8. The Connecticut Department then requested a 12-month waiver of
    the ten-digit dialing rules. *See* Connecticut Supplemental
    Information Filing at 6-7. This request was later reduced to a
    six-month waiver of the ten-digit dialing rules. Connecticut
    Department Supplemental Information Reply Comments at 4-5.

[^36]: Connecticut Department Supplemental Petition at 8.

[^37]: Rationing is a number conservation measure that limits the amount
    of numbering resources made available for allocation to carriers in
    a given area, in accordance with an industry-implemented or
    state-implemented rationing plan. *See, e.g.*, *Petition for
    Declaratory Ruling and Request for Expedited Action on July 15, 1997
    Order of the Pennsylvania Public Utility Commission Regarding Area
    Codes 412, 610, 215, and 717*, Memorandum Opinion and Order and
    Order on Reconsideration, 13 FCC Rcd 19009, 19025-27 (1998).

[^38]: *See* Connecticut Department Supplemental Petition at 8; Nextel
    Supplemental Petition Comments at 7; SBC Supplemental Petition
    Comments at 4.

[^39]: *See Numbering Resource Optimization* *Third Report and Order*,
    17 FCC Rcd at 294.

[^40]: Connecticut Department Supplemental Petition at 6; *see also* SBC
    Supplemental Petition Comments at 3.

[^41]: *Id*.

[^42]: Connecticut Department Supplemental Petition at 5-6.

[^43]: *See* Connecticut Department Supplemental Information Filing at
    3-4; Connecticut Department Supplemental Information Reply Comments
    at 2-4.

[^44]: *See* Cingular Supplemental Petition Comments at 2-4; Nextel
    Supplemental Petition Comments at 3-4; OnStar Supplemental Petition
    Comments at 5; SBC Supplemental Petition Comments at 2; Sprint PCS
    Supplemental Petition Comments at 8-10; Verizon Wireless
    Supplemental Petition Comments at 4-5; WorldCom Supplemental
    Petition Comments at 2-3; VoiceStream Supplemental Petition Comments
    at 3; AT&T Wireless Supplemental Information Comments at 4-6;
    Cingular Supplemental Information Comments at 5-6; CTIA Supplemental
    Information Comments at 5-6; CTIA Supplemental Information Reply
    Comments at 3; Nextel Supplemental Information Comments at 2-3; SBC
    Supplemental Information Comments at 2; Sprint Supplemental
    Information Comments, Attachment at 3-5; Verizon Wireless
    Supplemental Information Comments at 5-6.

[^45]: *See Numbering Resource Optimization* *Third Report and Order*,
    17 FCC Rcd at 288.

[^46]: For example, some high-speed transport lines may be packet
    switched and may not be associated with a telephone number.

[^47]: *See* j2 Global Communications Supplemental Information Comments
    at 2 n.4. j2 Global Communications further contends that UM services
    are not geographically sensitive and should not be included in the
    SO.

[^48]: *See* Connecticut Department Supplemental Information Filing at
    4.

[^49]: See Remarks by Kevin J. Martin, Commissioner, Federal
    Communications Commission, to the Southeastern Association of
    Regulatory Utility Commissioners (SEARUC) Conference 2002 (June 3,
    2002).