No Area Code 442 Split for San Diego County!

"I have voted against this decision because... overlays are the technology-friendly, cost-efficient and least disruptive solution for area code relief."

--PUC Commissioner Timothy Alan Simon, April 24, 2008,
the only one of five PUC commissioners who
opposed the 442 split. He felt strongly enough
about the issue to file his own dissenting opinion:

Dissent of Commissioner Timothy Alan Simon

Item 25:  Relief of the 760 Numbering Plan Area 

I. Introduction

The question of how to accommodate the ever-growing number of California telephone users continues to confront this Commission. Fervent arguments have been advanced by the supporters of both split and overlay solutions, but on balance, I am convinced, with modern technologies and human behavioral trends, that overlays best serve the needs of the residents and businesses. 

As I represented in the 818 Area Code Relief decision that, with my fellow commissioners’ support we adopted on consent[1]— I philosophically support overlays as the correct solution for area code relief in California based on the factual records that have been developed.

As such, I cannot support the Alternative I adopted by the majority, which opts instead for a geographically-based area code split for the 760 area code.

II. Overlays Allow Existing Consumers To Retain Their Telephone Numbers.

Numbering relief in the 760 area is imperative — being driven by the economic and population growth along the coast. In this regard, it would be an understatement to claim that the public has been passionate about the outcome of this proceeding.  The adopted decision reports that the Commission staff received more than 1,300 comments—601 in favor of the geographic split Alternative I; 163 in favor of geographic split Alternative IV; and 261 in favor of the overlay Alternative III.[2] By these numbers, the vast majority would appear to favor a split of some type, as opposed to an overlay.  But when I met with parties on both sides of the debate, the singularly resonant message that I heard was: “Whatever you do, just let me keep my 760 area code!”  Accordingly, I consider Split Alternative I pandering to the misguided belief of residents that they will retain the incumbent 760 area code.  

This decision fails to heed that consumer concern for constancy and, instead, adopts a geographic area code split that, much as the colonial powers did at the Treaty of Versailles, places the Commissioners in the unenviable position of picking consequential boundaries of winners and losers.  The majority’s decision bequeaths 760 to the vast northeast and relegates the new 442 code to the denser population of consumers in the southwestern area, near San Diego.  In contrast, the overlay alternative would have assigned the new area code to new customers after exhausting the inventory of 760 area codes and would have allowed existing customers to retain their existing telephone numbers.  The cost that will be incurred by business and residents is regrettable.  

III. Splits Place Enormous Avoidable Costs On Small Business Owners.

Rising costs threaten the survival of small businesses as they face greater economic challenges to stay competitive and cost effective.  Small business innovation and job creation is what makes America great.  As such, I favor exploring and, when appropriate, advocating alternatives that lower the costs to small businesses.

I am concerned that splits place enormous burdens on small businesses and the customers of small businesses, to the extent that those costs must be passed on through higher prices.  At a minimum, these avoidable costs include reprinting telephone numbers on stationery, business cards, advertising materials, fleets, and other business-promotional signage.  Further, the potential that businesses could lose their connection to former customers is significant. 

In addition to allocating the least amount of costs on consumers and businesses in the affected area, overlays are the least disruptive option and most technology friendly. 

IV. Area Code Splits Are a Short-Term Solution in Light of New Technology Advances.

Area code splits—no matter how implemented—are short term fixes.  Ten and even fifteen digit phone numbers will be the norm—it’s only a matter of time.[3]  In the interim, split solutions cater to a segment of the population that would be better served by accepting the inevitable and embracing technologies that adopt ten-digit local dialing.

The truth is, the future is here.  We regularly connect to ten-digit numbers and think nothing of it because there is no inconvenience.  We store the full ten-digit phone numbers of our contacts in our autobooks, cellular phones, fax machines, computers and voice recognition devises.  “Any-number” digit dialing is relatively painless with broadly available modern technologies.

V. Geographic Constraints

Opponents of the overlay solution point to the vast geographic reach of the 760 area code as support for a split solution.  I disagree.  Most of the area is desert and mountains, meaning that the areas are sparsely populated, if at all. Moreover, overlays have been implemented in other large, rural geographic areas—for example, but limited to the Province of Alberta, Canada.[4]

VI. Conclusion

I have voted against this decision because the record developed in this proceeding confirms my informed conviction that overlays are the technology-friendly, cost-efficient and least disruptive solution for area code relief. 

Dated April 24, 2008 San Francisco, California

Timothy Alan Simon
Commissioner

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We think NANPA's original recommendation of an area code overlay makes the most sense and inconveniences the fewest people. In an overlay, those of us who already have 760 phone numbers would keep them and only new customers in the 760 area would be assigned the 442 area code.

We won!
Thanks for sending your "Keep 760" email message to the CPUC!

No Area Code 442 Split for San Diego County!

(Map adapted from the San Diego Union-Tribune, April 24, 2008)

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