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City of DBQ Position on Area Code 319 Changes ~ \.~ CITY OF DUBUQUE, IOWA MEMORANDUM June 1, 2000 TO: The Honorable Mayor and City Council Members FROM: Michael C. Van Milligen, City Manager SUBJECT: City of Dubuque Position on Area Code 319 Changes The Iowa Utilities Board is responding to the predicted exhaustion of unassigned telephone prefixes and individual phone numbers under Area Code 319, which serves roughly the eastern one-third of Iowa. The Iowa Utilities Board has held a number of town meetings around the affected area to explain the problem and viable solutions, and to invite public comment. The Board has announced its intent to receive written comments until June 26, to hold a formal hearing in late August, and to adopt a plan in late October for implementation in the third quarter of 2001. Cable TV Administrator Merrill Crawford is recommending that the City submit written comments to the Iowa Utilities Board advocating a "geographic split" relief plan, with the 319 Area Code designation being retained by the area which borders the largest number of other area codes, or the "Iowa East Coast", that includes Dubuque. I concur with the recommendation and respectfully request Mayor and City Council approval. I'l"i!~ /l;1~ Michael C. Van Milligen MCVM/dd Attachment cc: Barry Lindahl, Corporation Counsel Tim Moerman, Assistant City Manager Merrill Crawford, Cable TV Administrator \'1 '~r' -f ':},Jj e8L~J-C\ ~:, nl."I"'O . ',I. /'18 o I :~ lid 1-- f.,in;" 00 O::Ji\L::()jtJ ~ .)>.~ CITY OF DUBUQUE, IOWA MEMORANDUM May 26, 2000 MEMO TO: Michael C. Van Milligen, City Manager ~ FROM: Merrill Crawford, Cable Franchise Administrator SUBJECT: City of Dubuque Position on Area Code 319 Changes INTRODUCTION: The purpose of this memorandum is to recommend that the City of Dubuque submit written comments to the Iowa Utilities Board advocating a "geographic split" relief plan, with the 319 Area Code designation being retained by the area which borders the largest number of other area codes. BACKGROUND: My April 28 report provides greater historical detail and comparative information regarding the need for the Iowa Utilities Board to respond to the predicted exhaustion of unassigned telephone prefixes and individual phone numbers under Area Code 319, which serves roughly the eastern one-third of the state of Iowa. The Iowa Utilities Board has held a number of town meetings around the affected area to explain the problem and viable solutions, and to invite public comment. The Board has announced its intent to receive written comments until June 26, to hold a formal hearing in late August, and to adopt a plan in late October for implementation in the third quarter of 200 I. Area Code Relief Options Under Consideration By The Iowa Utilities Board There are typically two alternatives given serious consideration for area code relief. These are the "Overlay" and the "Geographic Split". As in their earlier process regarding Central Iowa's Area Code 515, the Iowa Utilities Board's Area Code 319 relief consideration began with a petition on behalf of the "Iowa telecommunications industry" asking for relief and recommending the Overlay procedure. We can assume that "Iowa telecommunications industry" in this case probably means the larger phone companies and cell phone companies. The petition does not necessarily represent the positions of the many small independent telephone companies in Iowa. In fact, at the Dubuque meeting, the owner of the Andrew Telephone Company rose to speak against the "industry" recommendation. The Overlay Option If the Overlay option is adopted, a second, new area code number is assigned to the same geographic area as the existing one. All existing exchanges and telephone numbers remain assigned to the existing area code (319 in this case). After the remaining supply of prefixes and number blocks has been exhausted, new prefixes would be assigned from the new area code, and eventually there will be a substantial mix of phone numbers with each of the two area codes in the same neighborhood, even in the same business or household. Therefor, a basic requirement of implementing an Area Code Overlay is that all customers in the area must include the area code when dialing illLlocal calls (10 digits instead of 7). Long-Distance calling is not affected, in that dialing the other area code within your area does not result in long distance toll fees. The Overlay option seems to be favored most often by the larger telephone companies and the cellular companies (notably US Cellular, who already requires their customers to dial the area code for a local call). It appears to be generally less-favored by individual consumers and small businesses, due primarily to the inconvenience and memorization challenges associated with 10- digit dialing. The one-time reprogramming of many computers, fax machines, automated alarm dialing systems, etc. would be required as a part of the implementation of an area code overlay, and some printed advertising, phone books, letterheads, etc. which currently do not include the area code in phone number listings would need to be updated. Also, the expense of new switching hardware and/or software to handle the overlay could prove a significant and disproportionate burden upon the smallest local telephone companies. The Geographic Split Option If the Geographic Split option is adopted by the ruB, the existing area served by Area Code 319 would be arbitrarily split into two smaller geographic areas, one of which would retain Area Code 319 while the other is assigned a new 3-digit area code. This would permit continuation of the current practice of placing local calls via 7-digit dialing, while calling to the other newly- created area would require the area code, for a total of I a-digits. Of course, on the heels of a decision to implement a geographic area code split must come the decision as to which of the newly-defined areas keeps Area Code 319 and which must adapt to the new area code. "Adaptation" includes, among other changes, the widespread necessity to print new telephone books, catalogs, business cards, letterhead, billboards, radio & TV advertising, websites, etc. to show the changed area code. The shorter the implementation deadline for the new area code, the greater the disruption and associated costs to customers within the area assigned the new code. Disruption to the area retaining the old area code would be minor by comparison. Most state regulators, including the Iowa Utilities Board, require the telephone industry to conduct an extensive public education effort when a geographic split is implemented, and if possible to provide for a transitional period during which calls placed using either the new or the old area code will still be completed (called "permissive" dialing). In a Geographic Split, Who Keeps Area Code 319? There is perceived to be some advantage, at least in the short run, to those communities and businesses in the newly-defined area which retains the old area code, and history has seen some rather nasty politicking toward this end in other states. The IUB hopes to avoid or at least minimize the political approach to the extent possible. It has been rumored that in the event the geographic split option is selected for Area Code 319, the Board may consider a random method, such as a coin toss, to decide which area keeps the existing area code. Board Representatives have asked for input from the public not only as to whether the Overlay or Geographic Split option should be selected, but in the event of the latter, what criteria or process should be used to decided who retains the old area code. The most persuasive argument I have heard in favor of the "Iowa East Coast" (including Dubuque) retaining Area Code 319 in a geographic split arises from the fact that a newly-defined eastern half (in most patterns) contacts the borders of four other states, each with its own pending area code problems, while the western half (depicted as an island in some patterns) contacts the borders of only one, if any, other states. The cities of Dubuque and Keokuk, particularly, function in a tri-state marketing mode. The logic follows that since businesses and residents of these communities (and to a lesser degree any market along a state border) face the effects of potential changes to as many as 6 area codes from these other states as well as Iowa, it would be most helpful and fair to leave the Iowa East Coast with Area Code 319. A similar logic would apply for the eventual plan to relieve Area Code 712 along Iowa's western boundary. Determining the Exact Borders in a Geographic Split The Board has been considering approximately 15 different versions of the Geographic Split, prepared and displayed on maps by the national agency which assigns numbers. Nearly all of these patterns are variations of an East/West splitting of the existing 319 geographic area. That is, most patterns would place Cedar Rapids, Iowa City & Waterloo together and Dubuque and Davenport together. A few patterns show Waterloo with Dubuque & Davenport, and one pattern attempts a north/south split along Interstate 80, veering northerly at the Quad Cities, to place Iowa City and Davenport together and Cedar Rapids, Waterloo & Dubuque together. It is apparent that a broad range of geographic alternatives is being reviewed although the Board seems focused upon a half-dozen or so leading candidates, all of the East/West variety. The arbitrary border between the two areas must follow the existing borders of a myriad of local telephone exchanges, and is not likely to split any towns or cities, although one or more rural school districts may be unavoidably affected. An important specific measure to use in establishing the border between the two areas will be the resulting balance in the projected longevity of the "fix". Most likely, a pattern which should serve both areas for eight or nine years will be preferred by the Board to a pattern which would keep one area wallowing in available numbers for twelve years while the other area faces a shortage again in three years. The Board seems open at this time for recommendations as to additional criteria. Between May 9 and 19, I solicited input from the members of the City's Management Team regarding impact of the "Overlay" and "Geographic Split" alternatives on City operations, and whether we should advocate one option over another. I have also sought the opinions of our telephone consultant, Elert & Associates, and of our Washington, D.C. communications law firm, Miller & VanEaton, regarding any factors that might favor a particular option for the area encompassing Dubuque. Dan McDonald reports that the Dubuque Area Chamber of Commerce has polled local businesses and, based upon their strong response, is prepared to recommend the Geographic Split option to the Iowa Utilities Board. The advice from members of the City's Management Team is that City operations are not likely to be impacted dramatically by the Iowa Utility Board's decision over the long term. Some form of change to Area Code 319 is inevitable, and any option will involve some period of confusion and adaptation expense. Expressed preference for the Overlay or the Geographic Split has been mixed among department and division managers, as it is among businesses and the general population, but appears to favor the Geographic Split option approximately three-to-one.. The regions of the country with the most practical experience implementing and living with Area Code relief plans are large, dense metropolitan areas. While both Overlay and Geographic Split solutions have each been initially implemented in these dense areas, the pace of continued growth is such that regulators have had to address further relief in just a few years. Where Geographic Split solutions have been used several times in the same large city, the geographic areas become small enough that most daily "local" business is conducted via IO-digit dialing, much as if the Overlay option had been implemented in the first place. Clearly, a decision to implement a Geographic Split should not be based upon an assumption that lO-digit dialing would be permanently avoided. Neither should our most compelling argument for retaining the 319 designation along the "Iowa East Coast" prevent us from considering the short-term hassle and expense if we are the ones ending up having to change. Anything is possible. In a largely rural area such as Eastern Iowa, however, a well-crafted Geographic Split, applied in conjunction with other number-conservation techniques, could be expected to service dialing needs for a number of years. Further area code changes are not as likely to follow in rapid succession as they have in the largest metropolitan settings, particularly as we watch the birth and testing of telecommunication technologies such as "voice over IP", which may offer interconnection methods not dependent upon the traditional "dial-up" numbering system. Conclusion Confident that we can adapt without great long-term difficulty to whichever option the Iowa Utilities Board selects, I suggest that the City of Dubuque advocate an option that could prove the least disruptive in the immediate future to older citizens and smaller businesses and communities, buying them a bit more time to catch up to the rapid changes in telecommunications. That option would be the Geographic Overlay. Further, I suggest that the City strongly advocate retention of the Area Code 319 designation by that newly-created area which borders the greatest number of other area codes, acknowledging that communities along these "Iowa East Coast" borders can expect to suffer additional market disruption from relief plans implemented in these other area codes and states. RECOMMENDED ACTION: The Recommended Action is that the City of Dubuque adopt the attached Resolution and send written comments to the Iowa Utilities Board recommending the adoption of a Geographic Split solution, with the Area Code 319 designation retained by that newly-created area which borders the greatest number of other area codes. cc: Pauline Joyce, Administrative Services Manager RESOLUTION NO. - 00 A RESOLUTION OF THE CITY OF DUBUQUE RECOMMENDING THAT THE IOWA UTILITIES BOARD ADOPT A PLAN FOR AREA CODE 319 RELIEF WHICH SPLITS THE CURRENT GEOGRAPHIC AREA INTO TWO COMPARABLE SMALLER ZONES, AND THAT THE 319 DESIGNATION BE RETAINED BY THAT ZONE WHICH BORDERS THE LARGEST NUMBER OF OTHER AREA CODES. WHEREAS, the City Council of the City of Dubuque. Iowa aCknowledges the pending exhaustion of telephone dialing prefixes within Area Code 319 by late 2002. due to the expansi on of tel ecommuni cat ions servi ce provi ders . new technologies and services. and consumer demand, and WHEREAS, the City Council is grateful to the Iowa Utilities Board for its insightful and methodical approach to crafting a relief plan. for its clear and extensive publ ic information effort and for its careful attention to the concerns and advice of businesses. institutions, and citizens in the affected area. and WHEREAS, neither a perfect solution nor an insurmountable obstacle is seen in the "Overlay" or "Geographic Split" alternatives as methods to forestall the exhaustion of available dialing prefixes, as both desirable and objectionable elements are unavoidably inherent in each approach. and WHEREAS, citizens and communities along Iowa's East Coast together conduct daily business in local markets which cross borders into four other states, and have faced or may soon face the disruptive impact of similar relief plans for up to seven other area codes. IOWA: NOW THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF DUBUQUE, Section 1. That the Iowa Utilities Board is commended and thanked for its meticulous and responsive review and hearing process regarding this complicated and difficult task. and its sensitivity to the concerns and comments of Iowans throughout the affected area. Section 2. That the City of Dubuque recommends to the Iowa Utilities Board a "Geographic Split" option. with the Area Code 319 designation retained by that newly-created area whi ch borders the 1 argest number of other area codes. Section 3. That the City of Dubuque offers its support and assistance in implementing the solution chosen by the Iowa Utilities Board as smoothly as possible so as to minimize the burden and expense to Dubuque businesses, institutions, and families. PASSED, APPROVED, and ADOPTED this day of June, 2000. Terrance M. Duggan, Mayor Attest: Jeanne Schneider, City Clerk CITY OF DUBUQUE, IOWA MEMORANDUM June 1,2000 MEMO TO: Michael C. Van Milligen, City Manager FROM: Merrill Crawford, Cable Franchise Administrator ~. SUBJECT: Area Code 319 Update INTRODUCTION: The purpose of this memorandum is to report the predicted exhaustion of available numbers in the 319 Area Code earlier than previously announced. BACKGROUND: The news media this morning are reporting an announcement from the North American Numbering Plan Administrator (NANP A) that Area Code 319 may be exhausted of available telephone numbers as much as nine months earlier than the late 2002 deadline previously reported. This news does not change the recommendation in my May 26 memo, and apparently has not affected the Iowa Utilities Board comment and decision deadlines on this problem. We can expect, however, that either the length of advance notice or the length of the permissive dialing period for the chosen solution, or both, will be shortened.