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					                      STATE OF CONNECTICUT


               DEPARTMENT OF PUBLIC UTILITY CONTROL
                      TEN FRANKLIN SQUARE
                      NEW BRITAIN, CT 06051



DOCKET NO. 02-06-12   DPUC IMPLEMENTATION            OF   A   STATE-WIDE   311
                      NUMBER




                             December 16, 2002

                       By the following Commissioners:


                             Jack R. Goldberg
                             John W. Betkoski, III
                             Linda J. Kelly




                            DRAFT DECISION
                                             TABLE OF CONTENTS

I.   INTRODUCTION ...................................................................................................... 1
     A. SPECIAL ACT NO. 02-16 ....................................................................................... 1
     B. FEDERAL COMMUNICATIONS COMMISSION .............................................................. 1

II. OTHER CITIES AND STATES ................................................................................. 2

III. CONNECTICUT 311 SERVICE DIALING PLAN ...................................................... 3
     A. CONNECTICUT 311 SERVICE .................................................................................. 3
     B. CONNECTICUT 311 SERVICE DEMAND .................................................................... 5
     C. CONNECTICUT 311 SERVICE NETWORK DESIGN ...................................................... 5
     D. ESTIMATED COST OF CONNECTICUT 311 SERVICE .................................................. 6
     E. CONNECTICUT 311 SERVICE FUNDING.................................................................... 9
     F. CONNECTICUT 311 SERVICE IMPLEMENTATION........................................................ 9
        1. Wireline ........................................................................................................ 9
        2. Wireless ..................................................................................................... 10
     G. ACCESS TO CONNECTICUT 311 SERVICE .............................................................. 12
     H. EDUCATION PLAN ............................................................................................... 12

IV. CONCLUSION ........................................................................................................ 12
I.      INTRODUCTION

A.      SPECIAL ACT NO. 02-16

        On June 13, 2002, Special Act No. 02-16, An Act Concerning a State-Wide 311
Number and a Reverse 911 Number (Act), was signed into law by Governor Rowland.
SA 02-16 required the Department of Public Utility Control (Department), within
available appropriations, in conjunction with the Department of Public Safety (DPS) and
Infoline of Connecticut (Infoline), to develop a plan (Plan) for the implementation of a
state-wide non-emergency governmental telecommunications service to be known as
311 service. The Department was required to submit its plan to the Legislature’s
Energy and Technology Committee no later than January 1, 2003. A copy of SA 02-16
is appended hereto as Attachment 1.

B.      FEDERAL COMMUNICATIONS COMMISSION

      By its February 19, 1997 order in CC Docket No. 92-105, In the Matter of The
Use of N11 Codes and Other Abbreviated Dialing Arrangements (N11 Order), First
Report and Order and Further Notice of Proposed Rulemaking, the Federal
Communications Commission (FCC) adopted an abbreviated dialing arrangement to
reach non-emergency police services by assigning 3111 on a nationwide basis for this
purpose.2 N11 Order, ¶ 2. A copy of the N11 Order is appended hereto as Attachment
2.

        In the N11 Order, the FCC determined that the assignment of a national number
through which the public could gain access quickly to non-emergency police and other
government services was in the public interest.3 Id., ¶35. The FCC required that when
a provider of telecommunications services receives a request from an entity (e.g., a
local police chief or local fire chief) to use 311 for access to non-emergency police and
other government services in a particular jurisdiction, it must ensure that, within six
months of the request: (1) entities that were assigned 311 at the local level prior to the
effective date of the N11 Order relinquish non-compliant uses; and (2) it takes any steps
necessary (e.g., reprogramming switch software) to complete 311 calls from its
subscribers to a requesting 311 entity in its service area. Id.



1 311 Service was originally envisioned as a means for the public to contact law enforcement agencies in
   non-emergency circumstances. However, in many jurisdictions, the public can gain access to both law
   enforcement and other government agencies by dialing an all-purpose 7-digit non-emergency
   telephone number. DGS Report to the Governor and Legislature: Non-Emergency Number Pilot
   Programs, City of San Diego, City of San Jose (DGS Report), November 2000, p. 6.
2 Assignment means that a numbering plan administrator announces to the industry that a particular
   number will be used for certain, defined services.
3 The FCC left to local jurisdictions the discretion to determine whether 311 should be used locally to
   reach other government services. According to the FCC, local jurisdictions could better determine
   whether this code could or should be used for access to services in addition to non-emergency police
   services. The FCC also found that state public utilities commissions, in conjunction with state and
   local governments, could address any conflicting requests for use of 311 (e.g., situations in which city
   and county law enforcement agencies both request 311 implementation in the same geographic area)
   better than the FCC. N11 Order, ¶37.
Docket No. 02-06-12                                                                  Page 2

        The FCC also determined that use of an N11 code for access to non-emergency
police services could alleviate congestion on 911 circuits, which would permit more
effective operation of 911 emergency services. In the opinion of the FCC, by promoting
the safety of life and property and ensuring the public prompt access to emergency
services was consistent with the purpose of the Telecommunications Act of 1996
(Telcom Act). The FCC stated that in determining not to alter 911’s designation as a
national code for emergency services, serves the public interest because end users
would know that they can dial 911 from virtually any exchange in the country in order to
obtain emergency assistance. The FCC concluded that ensuring that 911 circuits are
not overburdened with non-emergency calls would let callers know that they can dial
911 from any exchange (to obtain necessary governmental services) without hampering
others’ access to 911 for emergencies. Id., ¶ 36.

       The FCC states that 311 is being used in several jurisdictions. Id., ¶38. A
greater discussion of the use of 311 in other cities and states is presented below in
Section II. The FCC also permitted the states and local governments to deploy 311
through their 911 centers or devise alternative procedures for routing and answering
311 calls. The FCC acknowledges that a provider of telecommunications services may
incur certain costs (e.g., in reprogramming switch software) to enable implementation of
311. Since 311 calls, like 911 calls, are typically intrastate in nature, states would
regulate cost recovery in most instances. Funding of 311 service would also be a local
issue. Id., ¶42.

       The wireless industry also expressed concern about costs and other
implementation issues in the FCC proceeding.4 In recognition of the issues and
problems associated with the wireless industry’s provision of 311, the FCC refrained
from imposing the same types of obligations on wireless providers with regard to 311
service as it did for 911 service. Id., ¶43.

II.    OTHER CITIES AND STATES

       The FCC has provided the states/local authorities with the ability to implement
311 dialing in their respective jurisdictions. While 311 dialing is not implemented on a
state-wide basis any where in the country, it is currently offered in 14 cities in the United
States. In particular, 311 non-emergency telephone service is provided in the cities of
Austin, Texas; Baltimore, Maryland; Bethel, Alaska; Chicago, Illinois; Columbia, South
Carolina; Dallas, Texas; Detroit, Michigan; Hampton, Virginia; Houston, Texas; Las
Vegas, Nevada; Rochester, New York; San Antonio, Texas; San Jose, California; and
Washington, DC.5 Additionally, although 311 has been designated as a non-emergency
service by the FCC, some of those cities have employed 311 dialing for other purposes.

4 The Department, in preparing this report, solicited comments from Verizon Wireless (VW) concerning
  the deployment of 311 in Connecticut. A discussion of VW’s comments is presented in Section III.F.2.
5 Other cities and counties planning 311 Systems include:        New York, New York; Philadelphia,
  Pennsylvania; Calgary and Halifax, Canada; Suffolk County, New York; Los Angeles County,
  California; Miami-Dade County, Florida; Howard County, Maryland; Lane County, Oregon; and
  Broward County, Florida. Motorola Presentation, Overview of 311 and Customer Service Request
  Systems for Government, Canadian Community Information & Referral Conference, Ottawa, Ontario,
  November 14, 2002.
Docket No. 02-06-12                                                                       Page 3

For example, of the 14 cities where 311 dialing is available, seven cities6 have
employed the abbreviated dialing function for city service calls. 7 The remaining cities
have established 311 calling for non-emergency police incidents.8 Moreover, 311 calls
within these cities are answered either by police call takers, 311 call takers or in Dallas,
by fire department call takers.

       In preparing the Plan, the Department contacted a number of cities where 311
dialing is currently offered.9 The Department notes that the population served by 311 in
these cities ranges from a low of 117,000 (Columbia, SC) to 3 million (Las Vegas, NV).
The annual number of 311 calls ranged from 237,000 (Hampton, VA) to 16 million
(Houston, TX). A copy of a table summarizing this information together with the number
of 311 support personnel and cost of providing 311 service by city is appended hereto
at Attachment 3.

III.    CONNECTICUT 311 SERVICE DIALING PLAN

      Connecticut 311 Service is a service that would be made available to local
governmental entities to provide its citizens with an easy to remember telephone
number for access to non-emergency government services. Connecticut 311 Service
would utilize the intelligent routing functionality of the public switched network to
complete 311 dialed calls to the appropriate 311 call center. The 311 call completion
would be based on the calling party’s geographic location within the subscribing
governmental entities’ geographic boundary. Call routing would be based on the
development of a database of citizen information related to their geographic location
and the telephone number that they are calling from.

A.      CONNECTICUT 311 SERVICE

       SA 02-16 requires the Department in conjunction with DPS and Infoline to
develop a plan for the implementation of a state-wide non-emergency governmental
telecommunications service to be known as 311 Service. As a preliminary step to the
Plan, the Department recommends that a determination be made to identify the non-
emergency services that would be accessed when 311 is dialed. For example, although


6    Chicago,        Columbia,     Dallas,    Detroit,  Hampton,     Houston      and      San     Antonio.
   www.911dispatch.com/information/311map.html.
7 City service calls include, but are not limited to water, power, sanitation services, library books, and
   recreation services. City of Los Angeles 311E Government Service Project, Project Overview, Price
   Waterhouse Coopers, p. 17.
8 Non-emergency police incident calls include property crimes that are no longer in progress and the
   offender is not on the scene. Non-emergency police incidents also include crimes such as vandalism,
   thefts, graffiti, stolen automobiles and garage burglaries. Additionally, non-emergency police calls
   include animal control problems; illegally parked vehicles; minor vehicle accidents where there are no
   injuries and traffic is not blocked; and the phone numbers, addresses hours of operation, etc. of local
   police units or programs.             Washington DC Metropolitan Police Department Website,
   http://mpdc.dc.gov/info/phone/311.shtm.
9 Between September 9, 2002 and October 14, 2002, the Department staff contacted 311 support
   personnel querying them about the date 311 calling was first implemented, population served, cost
   information, number of 311 support personnel, annual number of 311 calls received and the type of
   311 center management.
Docket No. 02-06-12                                                                 Page 4

311 is currently offered in 14 cities throughout the United States, the types of services
offered in these jurisdictions is evenly mixed (i.e., abbreviated dialing access to city
services vs. non-emergency police calls). As an aid in making this determination, the
Department recommends that the DPS 911 calling statistics and Infoline calling volumes
be reviewed to determine the most appropriate use for the 311 Service.

       During this proceeding, DPS provided 911 calling statistics measuring the
number of calls received at the state’s Public Safety Answering Points (PSAP) for the
period January through October 2002. A copy of those statistics are appended hereto
as Attachment 4.

        Infoline also provided calling volumes for the health and human services
information and referrals that it offers in Connecticut for the years 2000 and 2001. A
copy of those statistics are appended hereto as Attachment 5. The Department notes
that in testimony proffered during public hearings concerning then Raised Bill 308,
Infoline indicated that it:

       Already fields thousands of calls from residents looking for a myriad of
       municipal government services including senior centers, youth activities,
       public health inspections, tax assistance, assessors libraries, schools,
       town administrative entities, etc. In addition, there are many more
       thousands of requests for services provided by state agencies including
       the department of Social Services, Children and Families, Mental Health
       and Addiction Services, Public Health, Insurance, Consumer Protection,
       Motor Vehicles, etc.10

       Infoline also testified:

       Infoline is able to refer callers to the appropriate agency and site where
       service is located because of its extensive, constantly updated database
       of resources and trained, professional staff who are skilled in assessment
       techniques and knowledgeable about health and human service systems
       in the state. The database contains information about 403 state and
       municipal agencies with over 8000 sites where services are delivered.11

        As the record of Raised Bill No. 308 indicates, Connecticut 911 PSAPs are not
being overburdened with non-emergency calls. In addition, based on the testimony of
Infoline official Melanie Loewenstein, a 311 non-emergency governmental
telecommunications system has the potential of duplicating the existing services offered
through Infoline 211. Id., pp. 1 and 2.




10 Testimony of Melanie Loewenstein, Senior Vice President of United Way of Connecticut, Raised Bill
    No. 308; LCO No. 1469, dated February 26, 2002, p. 2.
11 Id.
Docket No. 02-06-12                                                                    Page 5

B.     CONNECTICUT 311 SERVICE DEMAND

        Before proceeding with the implementation of Connecticut 311, the Department
also recommends that a determination be made as to the types of services that would
be offered end users when dialing 311. For example, do Connecticut cities and towns
want 311 dialing as a means of responding to non-emergency calls that would normally
be transported to city/town PSAPs or municipal offices for local information? Would
cities/towns prefer Connecticut 311 Service to offer both non-emergency and city town
information? Based on the responses from those questions as well as an analysis of
the DPS 911 and Infoline 211 calling statistics, a better idea of how Connecticut 311
Service should be offered could be determined.

       In addition, a demand/opinion survey of users (i.e., city/state residents,
businesses, etc.) should also be considered to determine the services that could be
delivered by Connecticut 311 Service. At that time, the public could also be queried
concerning their knowledge of 911 service, Infoline and the types of information
provided by dialing 211.

C.     CONNECTICUT 311 SERVICE NETWORK DESIGN

      After identifying the services that could be accessed by 311, the next step in
deploying Connecticut 311 Service is to identify and develop the appropriate network
design that 311 service would utilize. The Department believes that there are four
possible network design scenarios that Connecticut 311 Service could employ.12

         For example, Connecticut 311 Service could adopt a scenario that mirrors the
state’s current 911 Public Safety Answering Point network wherein non-emergency calls
would be directed to the state’s PSAPs. Possible issues with this scenario however,
could result in non-emergency calls being directed to PSAPs placing a burden on
emergency dispatchers. It should be noted that if 311 calls are directed to a 911 PSAP,
the 311 call may not be answered quickly because 911 calls have priority. Another
issue that could occur would be in those cases where the calls would terminate in
regional centers, such calls could not directly connect the caller to municipal entity. 13
Nevertheless, if this scenario were adopted, one benefit would be that calling centers
(i.e., the PSAPs) are operational on a seven-day, 24 hour (7X24) basis.

       A second scenario consists of a county-wide answering point. Under this
scenario, there would be no central governing body and/or support agencies. There
would most likely also be a limited community of interest in county-wide call centers.
Additionally, the calling center could operate as a regional non-emergency answering
point, but like the PSAP scenario, county-wide call centers could not directly connect

12 On September 18, 2002, members of the Department’s staff met with representatives of the Southern
    New England Telephone Company (Telco) to discuss the 311 non-emergency service requirements
    and the public switched network. By teleconference call on October 7, 2002, the Department also
    discussed the implications of 311 non-emergency service with representatives of Cox Connecticut
    Telcom, L.L.C.
13 It has been argued that the real problem is not an overload of non-emergency calls to the 911 system,
    but rather, a shortage in 911 call takers and dispatchers. DGS Report, p. 10.
Docket No. 02-06-12                                                                        Page 6

callers to municipal entities. Lastly, county-wide call centers would not be able to
control multiple municipal out of hour messages.

       Mirroring the current 211 answering point scenario is another possible network
design. This network design could provide a central answering point for statewide non-
emergency calls. However, similar to the previous scenarios, the call center would only
be able to connect the caller to a municipal entity at a significant additional cost. Finally,
if the 211 answering point scenario were adopted, it could follow the same hours of
operation as Infoline (i.e., 7X24).

       Finally, Connecticut 311 Service could be deployed on a municipal answering
point basis. Under this scenario, the municipality would provide services directly to its
citizens. The municipal call center would also be in a position to connect callers to the
appropriate service entity. The municipality would also manage the hours of operations
as well as control its out of hours messages.

          Telco 311 Service Outline, pp. 1 and 2.

D.        ESTIMATED COST OF CONNECTICUT 311 SERVICE

           Quantification of the cost of Connecticut 311 Service will depend on several
factors including the number of agencies participating; level of services provided by
those agencies; equipment, staffing and public relations costs; and the actual cost to
administer the Connecticut 311 Service. Additionally, an investigation and quantification
of the cost associated with 311 equipment must be undertaken. Based on the 311
network model that is eventually deployed, specific 311 call answering and call
management equipment must be identified and the underlying cost calculated to
correspond to that network design. Finally, the cost of public education and (both
announcing the deployment of Connecticut 311 Service as well as ongoing public
education) must be factored into the start-up and annual cost of offering the service in
the state.

       Motorola indicates that the cost of a 311 service operation is made up of several
cost elements. Each element has many dimensions that must be defined before a clear
estimate of the total can be made. The following table illustrates the elements that need
to be considered by Connecticut in the evaluation of the 311 service project.14

                Cost Category                      Cost Items                     Questions?
                                                                             - Statewide or regional
                                                                             - How many call
            Architecture                 - Operational Concept               centers
                                         - System Design                     -       How       many
                                         - Interfaces                        databases
                                                                             -    Any    mandatory
                                                                             interfaces
            311                                                              - State needs to
                                         - Transaction Service Fee           negotiate a favorable
            Telecommunication

14   Motorola State of Connecticut 3-1-1 Initiative, December 5, 2002, pp. 2-4.
Docket No. 02-06-12                                                           Page 7

          Cost Category             Cost Items                     Questions?
       s Service Charges                                       rate per 311 call with
                                                               telecommunications
                                                               provider
                           - Facilities & equipment (Build-    - # of call centers
                           out,   Maintenance,    Utilities,   - # of call takers
       Call Center(s)      Lease, desks, computers)
                           -      Salaries     (Managers,
                           Supervisors, Customer Service
                           Representatives)
                                                               -     Use       existing
       Communications      - WAN’s & LAN’s, T1 charges, infrastructure
                           Citizen web intake                  - What else needs to
                                                               be purchased
                                                               -      Use       existing
                                                               hardware
       CSR Hardware        - Servers, Routers
                                                               - What else needs to
                                                               be purchased
                                                               - # CSR concurrent
                                                               users
                                                               - How many mapping
                                                               licenses
       CSR Software        - Licenses, Maintenance
                                                               - How many mobile
                                                               laptop licenses
                                                               - How many mobile
                                                               handheld licenses
                                                               - How many service
                                                               request types to be
                                                               configured
                                                               -       How        many
                                                               configuration
                                                               managers        to     be
                           - Configuration                     trained
       CSR Deployment      - Training                          - How many CSR
                           - Dataloads                         trainers to be trained
                           - Interfaces                        - How many geodata
                                                               loads required
                                                               - How many different
                                                               GIS data sources to
                                                               be used
                                                               - What interfaces to
                                                               CSR        must        be
                                                               developed
                                                               - How does CT plan to
                           - Citizen Awareness Campaign        educate the public on
       Operations          - Return on Investment Analysis     use of 311
                                                               - How does CT plan to
                                                               measure ROI
Docket No. 02-06-12                                                                Page 8


   Motorola also states that its experience indicates that the major costs for a large
deployment as envisioned by Connecticut may lie in the following bands:15

        Telecommunications – $0.05 - $0.10 per 311 call (~$200,000/yr for 2 million
         calls)
        75-person Call Center – $1 million to $3 million
        Customer Service Request (CSR) Hardware - $500,000
        CSR Licenses - $750,000
        CSR Deployment Services - $1 million
        Infrastructure upgrades (if needed) – TBD
        Software interfaces between CSR and legacy systems (if required) – TBD
        Recurring employee costs - TBD

        In addition, Motorola16 indicates that its CSR System would offer participating
cities and towns the tools that managers need to communicate with citizens and the
departments that need to deliver services. Motorola’s claims that its CSR product is the
software utilized by many 311 service call center call takers to handle and respond to
the calls because it has been developed specifically for state and local government
service delivery needs. According to Motorola, the CSR product provides a knowledge
based where call takers can search using topics, keywords, or location information to
determine how to refer a call and forward it to the agency responsible for the call, if the
call center cannot resolve the call.17 Services that could be provided include: work
order management; links service requests, ability to link multiple requests to each other;
efficient alignment of manpower by supporting the dispatching of crews at the
designated time in the workflow process; correspondence management; on-line
information directory; and controls over the amount of information collected and used for
each service request by key staff.18

       Moreover, the Telco suggests that Connecticut 311 Service components would
include the following:

        Local service required from the municipality central office for call completion.
         This provides the called Route to Number (RTN). Municipality defined function
         regarding call completion and non-emergency services would be covered.

        Single RTN within the municipal geographic boundary.

        Non-emergency 311 service database required to identify eligible callers and to
         provide appropriate call routing information to the RTN. The 311 database will
         require that all non-subscribing citizen end users be excluded.

15 Id., p. 4.
16  On November 8, 2002, the Department staff discussed with representatives of Motorola, its CSR
    System. According to Motorola, the CSR system is a tool used by public enterprises to help them
    maintain a high level of service delivery to their citizens. CSR System Brochure, p. 3.
17 Motorola State of Connecticut 3-1-1 Initiative, December 5, 2002, p. 1.
18 Motorola CSR Brochure, p. 3.
Docket No. 02-06-12                                                                    Page 9


         Multiple non-emergency 311 service databases are required when a central
          office serves multiple municipalities. For example, one subscribing municipality
          and one or more non-subscribing municipalities. The intelligent routing network
          needs to be deployed in any additional central offices to cover subscribing citizen
          end users.

         Coordinated implementation between the Telco and the municipality.

     The Telco also suggests that the following non-emergency 311 service tariff
components would be incurred:

          Recurring charges: Per System, Per Central Office, Per Call, or Budget Usage
          Billing and an optional Call Summary Report;

          Non-recurring charges: Per System Establishment, Per Central Office Equipped,
          Per System Table Changes and Table Updates and optional Budget Billing Set
          Up.

      Therefore, a complete cost analysis of Connecticut 311 Service will have to be
conducted that identifies all components of the service and the associated cost.

E.        CONNECTICUT 311 SERVICE FUNDING

       While SA 02-16 has required the Department, DPS and Infoline to develop a plan
to implement state-wide 311 calling, the Act is silent as to how service implementation
will be funded. The Department will seek guidance from the Legislature as to how
Connecticut 311 Service should be funded.

F.        CONNECTICUT 311 SERVICE IMPLEMENTATION

          1.      Wireline

       SBC Communications, Inc. (SBC) currently provides 311 Non-Emergency
Service in Chicago, IL; San Jose, CA; Dallas, Houston and San Antonio Texas.
According to the Telco, SBC’s experience for a typical 311 system implementation has
ranged from 9 to 15 months. The Telco states that each interval is established based
on negotiations with each customer as to how they intend to operate the service and the
non-emergency agencies that would be covered by the service. The Telco also states
that the implementation interval has been affected by database vendor selection
processes and the level of deployment of intelligent network technology in each specific
area.19 The systems currently deployed by SBC equally serves police non-emergency
calls and both police and governmental agencies non-emergency calls. The Telco
claims that there is also a 50/50 split on stand alone 311 call centers vs. the 311 call
center function being integrated into existing 911 call centers in those cities.

19   The Telco indicates that the Chicago 311 system has 44 central offices (CO), the Los Angeles system
     has 55 COs and the Houston system has 65. This compares to 130 COs that would most likely have
     to be equipped for the offering of 311 service in Connecticut.
Docket No. 02-06-12                                                                          Page 10

Additionally, the Telco indicates that SBC’s experience has been that all sites handling
311 non-emergency calls are being manned 7X24.

          2.       Wireless

       The wireless industry puts forward different issues that are not typically present
with those of the wireline community. By their very nature, wireless mobile services are
not associated with any particular community or political subdivision. From the
customer’s perspective, access to services such as those which might be available
through the assignment of a N11 code (in this case 311 service) to a community service
provider, is different in the mobile setting than it would be through landline access from
their homes or offices. Wireless operators have customers whose geographic locations
vary constantly. The customer’s mobile phone number is not an indicator of what
“community” the customer is located in at any given time, and often does not reflect the
“community” where the customer lives or works. There may be little correlation between
the phone number and any of the customer’s communities of interest. 20 Likewise, the
phone number may not reflect the local telephone company exchange boundary or
governmental jurisdiction where a customer is located, lives, or works. For example, a
CMRS provider in the Fairfield County area may serve a customer who uses his or her
phone in the customer’s home town, in Danbury, across the boarder in Westchester
County, New York or even while on vacation away from the area throughout New
England and all of these locations may be served by the same system as part of its
home calling area. Because mobile phone service is not associated with specific
geographic communities, the use of abbreviated dialing codes to permit wireless mobile
customers to access community services, such as those offered under or 311 codes,
must necessarily be designed and deployed differently than a comparable landline
offering.

       The operational issues associated with the implementation of abbreviated N11
codes also constrain the potential benefits of N11 codes for wireless customers.
Wireless networks are unable to easily conform to defined political or geographic
boundaries. Wireless calls are established over a radio air link between the customer’s
mobile phone and a network cell site containing radio transmission equipment. Cell site
coverage areas never adhere to political boundaries and almost always span multiple
communities and frequently serve multiple counties or states. Cell site coverage areas
overlap each other as they serve portions of the communities within the network. In
many instances, wireless carriers’ FCC-licensed areas also differ from each other.
Therefore, the manner in which network call routing is designed and decided is not only
complex but is also unique to each wireless carrier’s network. In Connecticut, many VW
cell towers also serve the bordering states of New York and Massachusetts. Similarly,


20   Unlike wireline carriers, Commercial Mobile Radio Service (CMRS) carriers do not draw numbers from
     every wireline rate center. Instead, they typically draw numbers from only a few rate centers and give
     their customers “local” outbound calling over an extended area, regardless of the rate center
     associated with the customer’s number. In Connecticut, for instance, VW draws numbers from a
     minimal number of rate centers. By selecting from a limited number of rate centers in their calling
     areas, and associating them with their large wireless network, CMRS carriers provide customers with
     a very large local calling area. The end result is that the rate center of the mobile numbers has little to
     do with the “local” calling area of the customers’ pricing plans or their community of interest.
Docket No. 02-06-12                                                                       Page 11

cell towers located in these bordering states also handle calls from wireless customers
physically located in Connecticut. These unique operational characteristics make the
imposition of N11 service rules on wireless providers unworkable. For instance, VW
questioned in its written comments which community’s services should the customer
access via the 311 code when the customer travels along and across various borders.21

       VW asserts that wireless customers will likely use N11 services differently than
landline customers. Wireless networks operate differently from other wireless networks
and are operationally different than more predictable fixed landline networks. These
factors require full flexibility for CMRS carriers to work with N11 service providers to
deploy service in ways that best accommodate their wireless customers. 22

       Based on its experience with the deployment of 211 dialing in Connecticut, the
Department concurs with the VW comments. Therefore, the Department recommends
that as the 311 deployment plan is developed, that special attention be afforded all
CMRS carriers taking into consideration the technical differences and difficulties that will
be placed on these service providers as they provide for 311 dialing.23

21 These same issues were experienced by the Department and Infoline when statewide 211 dialing was
   implemented in Connecticut. Although the 211 dialing code to access Infoline was to begin no later
   than January 1, 1999 for wireline service providers, it was not until 2002 before wireless carriers were
   able to permit their end user subscribers to access Infoline by dialing 211.
22 VW Comments, p. 3.
23 Wireless providers typically deploy their abbreviated dialing codes on a market-wide or switch-wide
   basis to accommodate the needs of their customers while working within the practical limitations of
   their technology. This is usually accomplished through switch translation commands, entered into the
   mobile switch, directing that switch to translate and route calls made via the abbreviated dialing code
   to a single number. The translation command applies on a per-switch basis to every cell site served
   by that switch, without exception. In larger markets that employ multiple switches, the same
   translation command is loaded into each switch, effectively providing abbreviated dialing to the entire
   market.
   Based a Petition for Reconsideration filed by VW at the FCC in CC Docket No. 92-105, The Use of
   N11 Codes and Other Abbreviated Dialing Arrangements (VW Petition), dated March 12, 2001, the
   Department believes that wireless carriers may be required to engineer a more complex and extremely
   labor-intensive technical fix in order to accommodate the individual requests of each community or
   agency. By enabling each community to request calls to be routed to their unique information and
   referral service number, wireless carriers would be required to engineer a per-cell routing requirement
   instead of a system-wide or per-switch solution. Per-cell routing would be burdensome, time
   consuming and complex to establish and maintain:
-- Working first from cell site coverage maps and maps of the communities served, engineers would need
   to determine which cell sites or portions of cell sites served that particular community information and
   referral service. VW suggests that care be taken to ensure that calls originated from the community
   are routed to the community, but because radio propagation is imperfect there would be instances
   where customer calls will not be routed to the community information service in which their call
   originated.
-- Per-cell routing for those cells identified would require building translation tables for each cell or cell
   face. This involves sitting down at a terminal and typing in tables of how dialing patterns should be
   processed for that cell. A switch translator that some carriers use in their networks would change the
   abbreviated digits dialed by the customer from that cell site/face to the number for the local community
   information and referral service.
-- Once the highly detailed tables have been created for each cell they must be maintained for all system
   changes that would affect these dialing plans. A number of everyday systems engineering changes
   may trigger translation table changes such as adding cell sites, sectoring cell sites, or re-homing cell
   sites. For instance, when new cells are added within the community, a new table would need to be
Docket No. 02-06-12                                                                       Page 12


G.       ACCESS TO CONNECTICUT 311 SERVICE

       Additional factors that must be addressed once the 311 non-emergency network
design has been agreed upon, include whether deployment of Connecticut 311 Service
would be phased-in or placed into service via a flash cut. A determination as to the
hours of operation and availability for call answering centers should also be made. Will
the state oversee Connecticut 311 Service or will oversight be delegated to the cities
and municipalities? Finally, a decision should be made as to how access to
Connecticut 311 Service would be made. That is, in addition to wireline and wireless
service access, will Connecticut 311 Service be accessed via an Internet web site, e-
mail communications or both?

H.       EDUCATION PLAN

       Prior to implementation of Connecticut 311 Service, a public education program
should be developed and executed. The State of Connecticut, local cities and
municipalities, DPS 911 and Infoline 211 (if appropriate) and telecommunications
service providers should develop a communications strategy, develop promotional
materials and produce various events designed to raise the public’s awareness of the
availability of Connecticut 311 Service, the appropriate uses of 311 service and when
911 should be dialed. A 311-web site could also be developed (similar to that used by
the Washington DC Metropolitan Police Department) that explains 311 service, when it
should be called, etc. Local municipal and law enforcement officials can also make
presentations at community and Neighborhood Watch Meetings to inform their
constituents of the service. Lastly, local telecommunications service providers should
be contacted concerning the possibility of including information in monthly customer
service bills and/or assisting in the production of public service announcements and
communications for newspapers, radio and television.

IV.      CONCLUSION

      Special Act 02-16 has required the Department to submit its Plan for 311 service
to the Legislature. In light of the above, the Department submits the proposed
Connecticut 311 Service Plan:

1.       Determine the types of services (i.e., city services or non-emergency police calls)
         that would be provided to callers dialing 311.

2.       Conduct a comprehensive review of the DPS 911 and Infoline callings statistics.



     created that accepts and translates the abbreviated dialing code. New cells are usually added along
     with a decrease in the coverage of existing cells. The same process that took place initially to map out
     cell coverage would need to be undertaken again for all modified cells to reverify that the cells
     continue to serve the community and if not the tables would be amended. These reviews and
     changes would also be required for other changes in radio propagation when converting cells from
     omni to directional, down tilting or changing radios and changing radio power level settings. VW
     Petition, pp. 13-15.
Docket No. 02-06-12                                                      Page 13

3.    Survey Connecticut cities and towns to measure local demand for the service(s)
      as well as assess the type of municipal services that could be accessed through
      dialing 311.

4.    Conduct a demand/opinion survey of prospective users of Connecticut 311
      Service.

5.    Identify and develop the appropriate network design that Connecticut 311
      Service will utilize.

6.    Investigate and quantify the start-up and ongoing equipment and network costs
      associated with the provision of Connecticut 311 Service.

7.    Develop a Connecticut 311 Service funding program.

8.    Meet with the 311 service software vendors, the wireline and CMRS industries to
      identify technical issues and develop a network deployment schedule that
      addresses those issues and permits end users to timely access Connecticut 311
      in a timely manner. Particular attention should be paid to the technical issues
      plaguing the wireless industry.

9.    Develop a Connecticut 311 Service time line identifying all project milestones.

10.   Determine how Connecticut 311 Service will be implemented (i.e., phased-in or
      on a flash cut basis). Determine the oversight that would be afforded
      Connecticut 311 Service and 311 call center hours of operation.

11.   Develop and execute a public awareness program informing the public of the
      availability of Connecticut 311 Service.
DOCKET NO. 02-06-12      DPUC IMPLEMENTATION            OF      A STATE-WIDE   311
                         NUMBER

This Decision is adopted by the following Commissioners:




                   Jack R. Goldberg


                   John W. Betkoski, III


                   Linda J. Kelly




                            CERTIFICATE OF SERVICE

        The foregoing is a true and correct copy of the Decision issued by the
Department of Public Utility Control, State of Connecticut, and was forwarded by
Certified Mail to all parties of record in this proceeding on the date indicated.




                         Louise E. Rickard                         Date
                         Acting Executive Secretary
                         Department of Public Utility Control
ATTACHMENT 1
                             Substitute Senate Bill No. 308
                               Special Act No. 02-16
AN ACT CONCERNING A STATE-WIDE 311 NUMBER AND A REVERSE 911
NUMBER.
Be it enacted by the Senate and House of Representatives in General Assembly
convened:
Section 1. (Effective July 1, 2002) The Department of Public Utility Control shall, within
available appropriations, in conjunction with the Department of Public Safety and
Infoline of Connecticut, develop a plan for the implementation of a state-wide
nonemergency governmental telecommunications service to be known as 311 service.
Not later than January 1, 2003, the Department of Public Utility Control shall submit
such plan to the joint standing committee of the General Assembly having cognizance
of matters relating to energy and technology in accordance with the provisions of
section 11-4a of the general statutes.
Sec. 2. (Effective July 1, 2002) The Department of Public Safety shall, within available
appropriations, develop a plan for the implementation of a state-wide reverse 9-1-1
system. Not later than January 1, 2003, the department shall submit such plan to the
joint standing committee of the General Assembly having cognizance of matters
relating to public safety in accordance with the provisions of section 11-4a of the general
statutes.
Approved June 13, 2002
ATTACHMENT 2
                                     Before the
                         Federal Communications Commission
                                Washington, D.C. 20554

                                             )
                                             )                           FCC 97-51
                                             )
                                             )
In the Matter of                             )
The Use of N11 Codes and Other               )   CC Docket No. 92-105
Abbreviated Dialing Arrangements             )
                                             )
                                             )
                                             )
                                             )
                                             )

                          FIRST REPORT AND ORDER
                 AND FURTHER NOTICE OF PROPOSED RULEMAKING


     Adopted: February 18, 1997                        Released: February 19, 1997


By the Commission:

Comment Date:               March 31, 1997
Reply Comment Date:         April 30, 1997


                                   TABLE OF CONTENTS


                                                                        Paragraph No.


I.       Introduction                                                          1

II.      Background                                                            4

III.     First Report and Order                                                13
         A.     Analysis                                                       13
                1.     Jurisdiction/Numbering Authority                        13
                2.     Mandatory Assignment of N11 Codes                       14
                       for Provision of Information Services
                3.     National Assignment of Specific N11 Codes               22
                       a.     Background                                       22
                    b.     Emergency Services (911)                     23
                    c.     Access to Government Services                24
                    d.     Access to Repair Services (611)
                           and Business Office Uses (811)               45
                    e.     Directory Assistance (411)                   47
                    f.     Access to Telecommunications Relay
                           Services                                     49
              4.    Statutory Preemption
      57
              5.    Other Issues                                        59
                    a.     Alternate Abbreviated Dialing Arrangements   59
                    b.     Recall Procedures                            63
              6.    Regulatory Flexibility Act                          65

IV.   Further Notice of Proposed Rulemaking                             66
      A.    Introduction                                                66
      B.    Access to Telecommunications Relay Services                 67
      C.    Sale or Transfer of N11 Codes                               69
      D.    Administration of N11 Codes                                 72
      E.    Procedural Matters                                          76
            1.     Ex Parte Presentations                               76
            2.     Regulatory Flexibility Act                           77
      F.    Comment Filing Procedures
      78

V.    ORDERING CLAUSES                                                  81

Appendix A:   Comments Filed on N11 NPRM
Appendix B:   Comments Filed on TRS Petition
Appendix C:   Comments Filed on GSA Petition
Appendix D:   Comments Filed on Department of Justice Request
Appendix E:   Final Regulatory Flexibility Analysis
Appendix F:   Initial Regulatory Flexibility Analysis




                                          2
                                 I.      INTRODUCTION

       1.     In 1992, the Commission adopted a Notice of Proposed Rulemaking
proposing that incumbent local exchange carriers (incumbent LECs) be required to
provide abbreviated dialing arrangements.24 "Abbreviated dialing arrangements" are
telephone numbers of less than the standard 7 or 10 digits. Among abbreviated dialing
arrangements, "N11 codes" are 3-digit telephone numbers of which the first digit may be
any digit other than 0 or 1, and the last two digits are both 1.25 Since the N11 NPRM
was released, various parties have asked that the Commission designate N11 codes for
a variety of applications,26 including, for example, to facilitate network access: (1) for
individuals with hearing or speech disabilities; (2) to information services; (3) to federal
and state government agencies; and (4) to non-emergency police services.

       2.      Under the amendments to the Communications Act of 1934 (the Act) in
the Telecommunications Act of 1996,27 the Commission has exclusive jurisdiction over
"those portions of the North American Numbering Plan that pertain to the United
States."28 The Commission also has authority to delegate to "State commissions or
other entities all or any portion of such jurisdiction."29 In this First Report and Order, we
allow the incumbent LECs, in addition to the states and Bell Communications Research
(Bellcore), to continue to perform the N11 code administration functions that they
performed at the time of enactment of the 1996 Act amendments to the 1934 Act, until
further Commission action. We also adopt several other important measures regarding
abbreviated dialing arrangements. Specifically, we respond to a request for an N11
code that could be dialed to reach non-emergency police services by assigning 311 on



 24  See The Use of N11 Codes and Other Abbreviated Dialing Arrangements, CC Docket No. 92-105, 7
  FCC Rcd 3004 (1992) (N11 NPRM). Appendix A lists those parties filing comments and reply comments
  in response to the N11 NPRM.

 25  Under the North American Numbering Plan (NANP), N11 codes are known as service codes. The
  NANP is the basic numbering scheme for the telecommunications networks located in Anguilla, Antigua,
  Bahamas, Barbados, Bermuda, British Virgin Islands, Canada, Cayman Islands, Dominica, Dominican
  Republic, Grenada, Jamaica, Montserrat, St. Kitts & Nevis, St. Lucia, St. Vincent, Turks & Caicos
  Islands, Trinidad & Tobago, and the United States (including Puerto Rico, the U.S. Virgin Islands, Guam
  and the Commonwealth of the Northern Mariana Islands).

 26   National Center for Law and Deafness and Telecommunications for the Deaf, Inc. (NCLD Petition),
  filed October 1, 1993. Appendix B lists the parties filing comments and replies in response to the NCLD
  Petition. GSA, Petition for Declaratory Ruling (GSA Petition), filed March 11, 1994. Appendix C lists the
  parties filing comments and replies in response to the GSA Petition and the National Association of State
  Telecommunications Directors, ex parte Presentation in CC Docket No. 92-105, September 22, 1993.

 27   Telecommunications Act of 1996, Pub. L. No. 104-104, 110 Stat. 56 (1996).

 28   47 U.S.C. § 251(e)(1).

 29   Id.




                                                    3
a nationwide basis for this purpose.30 Wherever 311 is currently in use for other
purposes, however, we would allow that use to continue until the local government in
that area was prepared to activate a non-emergency 311 service. In this First Report
and Order we also conclude that, as the incumbent LECs can do currently, all providers
of telephone exchange service must be able to have their customers call 611 and 811 to
reach their repair and business service offices. We also conclude that a LEC may not
itself offer enhanced services31 using a 411 code, or any other N11 code, unless that
LEC offers access to the code on a reasonable, nondiscriminatory basis to competing
enhanced service providers in the local service area for which it is using the code to
facilitate distribution of their enhanced services. Finally we respond to a request for an
N11 code that could be used throughout the nation to reach telecommunications relay
services (TRS) by directing Bellcore to assign 711 on a nationwide basis for this use.
We decline, however, to: (1) mandate that N11 numbers be made available for access
to information services;
(2) mandate that an N11 code be designated for access to government agencies; or (3)
disturb the current allocation of various N11 codes for access to emergency services, 32
directory assistance, and LEC repair and business offices.

       3.     In the Further Notice of Proposed Rulemaking (FNPRM) we ask for
comment on the technical feasibility of implementing 711 for TRS access. We also ask
parties: (1) if it would be possible to develop within a reasonable time an N11
"gateway" offering access to multiple TRS providers; (2) whether, with such gateway
access, TRS calls would still be answered within our mandatory minimum standards for
TRS answer times; (3) whether such a gateway would be consistent with Section 255 of
the Act; and (4) whether any other important disability services could be accessed
through the same gateway. Regarding TRS, the FNPRM also requests comment from
interested parties, particularly TRS providers, about the possibility of providing both
voice and text TRS services through the same abbreviated N11 code. Finally, we ask
for comment on the proprietary nature of N11 codes and on our proposal to transfer the
administration of N11 codes at the local level from the incumbent LECs to the NANP
administrator.


 30  Assignment means that a numbering plan administrator announces to the industry that a particular
  number will be used for certain, defined services. This warns current users of that number that they will
  need to relinquish their use of the number when the new assignment is implemented. Implementation
  involves, among other things: relinquishing current local uses for the number; preparing switches for the
  new, assigned use; modifying switches to route calls; and installing additional switching or other
  equipment required to provided the services contemplated.

 31  The term "enhanced services" refers to services, offered over common carrier transmission facilities
  used in interstate communications, which employ computer processing applications that act on the
  format, content, code, protocol or similar aspects of the subscriber's transmitted information; provide the
  subscriber additional, different, or restructured information; or involve subscriber interaction with stored
  information. See Section 64.702 (a) of the Commission's Rules, 47 C.F.R. §64.702(a). For purposes of
  this proceeding, information and enhanced services are used interchangeably.

 32   As discussed within, 911 has been designated as a national code for emergency services.




                                                     4
                                          II. BACKGROUND

        4.     Prior to enactment of the 1996 Act amendments to the 1934 Act, Bellcore,
the states, the incumbent LECs, and the Commission each performed functions relating
to the administration of N11 codes. Since the AT&T divestiture, Bellcore has served as
the administrator of the NANP. Bellcore has assigned N11 codes for national use. In
addition, the Commission may direct Bellcore to assign an N11 code for national use if
the Commission determines that such a national assignment is appropriate. 33 Bellcore,
in its role as NANP administrator, has issued specific guidelines addressing the use of
N11 codes.34 Bellcore has stated that it has made no additional national assignments in
the last few years, pending resolution of the instant proceeding. Bellcore guidelines
recognize four N11 codes as assigned for national use: 411 (local directory
assistance); 611 (repair service); 811 (business office); and 911 (emergency
services).35 Bellcore also has stated that the remaining N11 codes, listed as
"unassigned," along with any assigned codes that are not used locally (611 and 811 in
some areas), would be kept available for future assignment by the NANP
administrator.36

       5.     Bellcore guidelines permit local use of N11 codes provided that such
assignments and use can be discontinued on short notice.37 In states where N11 codes
have been used locally, state public utilities commissions have directed the LECs to
assign and administer these codes. The specific procedures for assignment of N11
codes for local use vary from state to state. Three local N11 codes have been assigned
for particular uses in at least some LEC service areas (411 for local directory
assistance; 611 for LEC repair service; and 811 for LEC business office use).


 33  711 is currently used in Canada for relay service for the hearing disabled. In a letter dated September
  8, 1993, the Canadian Steering Committee on Numbering (CSCN) confirmed "the assignment of 711 as
  the access code for relay service for the deaf . . . and [stated that it had] negotiated the assignment of 1-
  800-855-0511 as the national 800# for access to MRS [message relay service]." See September 8,
  1993 letter from B.M. Stevens, Secretary CSCN, Canadian Numbering Administrator, to its "distribution
  list" advising the Canadian industry of changes. CSCN was established under the authority of Industry
  Canada (the Canadian agency that regulates telecommunications services and their providers in
  Canada) to advise it on an ad hoc basis. It has been confirmed with Industry Canada that in February
  1994, both 711 and 1-800-855-0511 were implemented for relay service in Canada. The 711 number is
  used by the hearing disabled to access the relay service, while the 1-800-855-0511 number is used by
  the hearing to access the relay service.

 34 See Bell Communications Research, BOC Notes on the LEC Networks -- 1994 (Issue 2), April 1994
  (Network Notes), "Numbering Plan and Dialing Procedures."

 35   See id. at 3.4. Thirty years ago, AT&T designated 911 for access to emergency services.

 36   Id. at 3.4.1.

 37   Id.




                                                     5
        6.      The Commission, in the NANP Order,38 adopted a new model for
administration of the NANP by announcing its intent to establish the North American
Numbering Council (NANC) under the Federal Advisory Committee Act.39 (The NANC
held its first meeting on October 1, 1996). The NANP Order did not specifically consider
the issue of service code allocation. In addition to holding that the NANP administrator's
existing functions will be transferred to an entity to be recommended by the NANC, the
Commission in the NANP Order also held that central office (CO) code administration
functions will be transferred from the LECs to the new NANP administrator to be
recommended by the NANC within 18 months after completion of the transfer of the
existing NANP administrative functions from the current NANP administrator.40 The
NANC will advise the Commission on numbering issues and also is charged with
recommending and guiding a neutral NANP administrator. Within the United States,
prior to enactment of the 1996 Act amendments to the 1934 Act, twelve regional CO
code administrators handled CO code assignments.41 Many LECs serving as CO code
administrators administered N11 codes for local use.42

       7.     On March 6, 1992, BellSouth petitioned the Commission to declare that
mandatory assignment of N11 codes for access to information services would be
consistent with the Communications Act and Commission policies.43 The petition was
prompted by a request from Cox Enterprises, Inc. (Cox), which had asked BellSouth to
assign it an N11 code in Atlanta for the purpose of offering information services. On
May 4, 1992, the Commission informed BellSouth that "there appears to be no
regulatory or legal impediment prohibiting BellSouth from currently assigning N11 codes
in a reasonable, non-discriminatory manner," which may include, for example, assigning
N11 codes on a first-come, first-service basis.44

    8.     On the same day that the Commission issued its letter to BellSouth, the
Commission adopted the N11 NPRM tentatively concluding that: (1) service codes 211,

 38 Administration of the North American Numbering Plan, CC Docket No. 92-237, Report and Order, 11
  FCC Rcd 2588 (1995).

 39   5 U.S.C., App. 2 (1988).

 40   NANP Order at para. 115.

 41 The current telephone number format within the NANP is given by: NXX-NXX-XXXX, with the second
  three digits representing CO code. The CO code administrators within the United States were:
  Alascom; Ameritech; Bell Atlantic; BellSouth Corporation (BellSouth); Cincinnati Bell; GTE (for 813 area
  code); GTE (for 808 area code); NYNEX; Pacific Bell; Southern New England Telephone; SBC; and U S
  WEST.

 42   See paras. 72-75, infra, for further discussion of administration of N11 codes.

 43   BellSouth, Petition for Declaratory Ruling (BellSouth Petition), March 6, 1992.

 44 Letter from Robert L. Pettit, FCC General Counsel, to David J. Markey, Vice President, BellSouth,
  dated May 4, 1992 (May 4 1992 FCC General Counsel Letter to BellSouth).




                                                       6
311, 411, 511, 611, 711 and 811 should be available for abbreviated dialing 45 (2) N11
codes should be made available for abbreviated dialing until it is necessary to use the
codes as area codes;46 (3) LECs should not be subject to any additional restrictions on
how they allocate N11 codes;47 and (4) use of N11 service codes for information
services would not result in customer confusion.48

        9.     In light of these tentative conclusions, the Commission solicited comment
on the following broad issues: (1) whether LECs should be able to use 411 for delivery
of enhanced services; (2) whether continued LEC use of 611 and 811 represented an
efficient use of limited numbering resources that served the public interest; (3) whether
procedures for recalling N11 codes should be developed; (4) whether three digit dialing
should be available for purposes other than calling enhanced services; (5) whether sale
or transfer of N11 codes should be permitted; (6) whether restrictions should be placed
on the manner in which LECs allocate N11 codes if demand exceeds supply; (7)
whether LECs should be permitted to grant a preference to parties that "propose
innovative ways of using the company's network;"49
(8) what role state regulators should play in allocating N11 codes if demand exceeds
supply; (9) whether the use of N11 codes for information services results in customer
confusion; and (10) whether it is feasible to require other abbreviated dialing
arrangements to be made quickly available by LECs in lieu of or in addition to requiring
them to make N11 codes available.

       10.   In October 1993, the National Center for Law & Deafness and
Telecommunications for the Deaf, Inc. (NCLD) petitioned the Commission to direct the
assignment or reservation50 of two uniform N11 numbers. It requested 711 for access
to TRS by persons with speech and/or hearing disabilities and a second unspecified
service code for TRS access by voice and telephone users. On October 14, 1993, the
Commission released a public notice describing the petition and requested comments.51



 45   See N11 NPRM at para. 12.

 46   See id. at para. 13.

 47   See id. at para. 16.

 48   See id. at para. 18.

 49   Id. at para. 16.

 50  Parties refer both to assignment and to reservation. Throughout our discussion we will refer to
  assignment. For a definition of "assignment," see footnote 7, supra.

 51  Commission Requests Comment on Petition for Assignment of N11 Codes to Facilitate Access to
  Telecommunications Relay Services, Public Notice, 8 FCC Rcd 7587 (1993) (TRS N11 Notice). See
  also Commission Clarifies Pleading Cycle for Comments on Petition for Assignment of N11 Codes to
  Facilitate Access to Telecommunications Relay Services, Public Notice, 8 FCC Rcd 8391 (1993).




                                                7
      11.    In March 1994, the General Services Administration (GSA) filed a petition
requesting that an N11 code be reserved to facilitate nationwide public telephone
access to federal executive agencies.52 In a similar request, the National Association of
State Telecommunications Directors (NASTD), in an ex parte letter filed in this docket,
requested that a single N11 code be reserved to facilitate public access to state
agencies.53

       12.     In a letter dated August 26, 1996, the United States Department of
Justice's Office of Community Oriented Policing Services (Department of Justice) asked
that an N11 code, specifically 311, be reserved on a national basis for use by
communities for non-emergency police telephone calls. The Department of Justice also
suggested that the N11 code could be used to give access to other government
services, at the discretion of each jurisdiction. In a Public Notice dated September 10,
1996, the Commission sought comment on the Department of Justice's request.

                                III. FIRST REPORT AND ORDER54

A.       Analysis

         1.      Jurisdiction/Numbering Authority

       13.     The Act states that, "[t]he Commission shall have exclusive jurisdiction
over those portions of the North American Numbering Plan that pertain to the United
States."55 Although the Act gives the Commission exclusive jurisdiction over those
portions of the NANP that pertain to the United States, the Act also allows the
Commission to delegate "to State commissions or other entities all or any portion of
such jurisdiction."56 As stated above, prior to enactment of the 1996 Act amendments
to the 1934 Act, Bellcore, the states, and the incumbent LECs each performed functions
relating to the administration of N11 codes. In Implementation of the Local Competition
Provisions of the Telecommunications Act of 1996, CC Docket No. 96-98, Second
Report and Order and Memorandum Opinion and Order, FCC 96-333 (rel. Aug 8, 1996).
(Local Competition Second Report and Order), the Commission stated:

 52   GSA Petition at 3.

 53    National Association of State Telecommunications Directors (NASTD), Ex Parte Presentation in CC
     Docket No. 92-105, September 22, 1993.

 54      Although this First Report and Order adopts several measures regarding abbreviated dialing
     arrangements, it does not specifically adopt the rules proposed in the N11 NPRM. See N11 NPRM at
     Appendix A.

 55    See 47 U.S.C. § 251(e)(1). For this reason, the discussion of jurisdiction appearing in the N11 NPRM
     and comments filed in response to that discussion are moot. The Act states that, "the term 'United
     States' means the several states and Territories, the District of Columbia, and the possessions of the
     United States, but does not include the Canal Zone." 47 U.S.C. § 153(50).

 56   See id.




                                                     8
         [w]e authorize Bellcore to continue to perform its functions as the North
         American Numbering Plan Administrator in the same manner it did at the
         time of enactment of the 1996 Act. We also allow the incumbent LECs to
         continue to perform the CO code administration functions that they
         performed at the time of enactment of the 1996 Act. Finally, we allow the
         states, if they performed any number administration functions prior to
         enactment of the 1996 Act, to continue to do so until such functions are
         transferred to the new NANP administrator.57

As noted above, prior to enactment of the 1996 Act amendments to the 1934 Act, many
LECs serving as CO code administrators managed N11 codes for local use. In this First
Report and Order, we also allow the incumbent LECs, therefore, to continue to perform
the N11 code administration functions that they performed at the time of enactment of
the 1996 Act amendments to the 1934 Act. This is consistent with the Commission's
statement in the Local Competition Second Report and Order that the "transfer of
numbering administration functions will be a complex task, one that cannot be
accomplished immediately even on a transitional basis."58

                  2.      Mandatory Assignment of N11 Codes for
                          the Provision of Information Services

      14.    Background. The N11 NPRM proposed to require LECs to
assign N11 codes to parties requesting them for information services unless and until it
is necessary to use the N11 numbers as area codes.59 The Commission tentatively
concluded that LECs should be permitted to select any reasonable method to allocate
N11 codes that would ensure fair and efficient number allocation.60

       15.    Comments. Commenters are divided on whether LECs should be
required to assign N11 codes for access to information services. Those supporting the
proposal contend that it would compel LECs to provide the public with convenient
access to such services.61 N11 access, they argue, would enable information service
providers to provide the public with information of significant local interest quickly and

 57   Local Competition Second Report and Order at para. 329.

 58   Id. at para. 330.

 59   N11 NPRM at para. 13.

 60 Id. at para. 16. The Commission did not set out specific allocation methods because reasonable
  methods could vary with circumstances. For example, if supply exceeded demand, a first-come first-
  served allocation method might be reasonable.

 61 See, e.g., Alternative Weekly Newspapers, New Times, Inc., Sasquatch Publishing, City Pages, and
  Tuscon Weekly (collectively, Alternative Newspapers) Comments at 4; Cox Comments at 2, Datatrex
  Comments at 1; Infocom Comments at 1; Advance Reply Comments at 1.




                                                   9
conveniently.62 Such ease of access for consumers, they say, would, in turn, enhance
the viability of independent information service providers, putting them closer to an
equal footing with LECs and spurring competition. Cox asserts that enhancing
competition in information services markets is a long-standing Commission goal.63 In
an ex parte presentation, Cox emphasized that commercial uses of N11, such as
information services, which have received wide consumer acceptance, serve the public
interest and therefore necessitate the assignment of an N11 number. 64 The Alternative
Newspapers contend that N11 codes serve their needs far better than alternate dialing
arrangements, claiming that: (1) N11 provides customers an option that is "easier to
remember, easier to dial, and faster and quicker than seven or ten-digit alternatives;" (2)
900 services are too expensive for the local information services offered by the
alternative newspapers; and (3) the pricing and terms and conditions of the new 960
service are not know to the alternative newspapers.65 Local government agencies
involved in the provision of 911 emergency service contend that N11 codes should not
be available for assignment for commercial purposes, arguing that such use would
cause confusion regarding the use of 911 for emergency service 66 by increasing the
misdials to 911 in nonemergency situations67 and misdials to other N11 codes in
emergency situations.68

       16.    Among LECs filing comments, only BellSouth supports assignment of
N11 codes for information services.69 BellSouth argues that there is a need for
abbreviated dialing for information services that is not being met under the current
NANP. BellSouth suggests, however, that permissive allocation of N11 codes would be
preferable to mandatory allocation.70

 62   See, e.g., NAA Comments at 2-3; Alternative Newspapers Comments at 2-3.

 63   See Cox Reply Comments at 5 (citing Computer III Proceedings).

 64   Cox December 12, 1995 ex parte presentation.

 65   See Alternative Newspaper Comments at 3-5.

 66  See, e.g., Shelby County, Tennessee Emergency Communications District (Shelby County)
  Comments at 1-2; St. Charles Parish Communications District Comments at 1; St. Landry Parish
  Communications District Comments at 1; Texas Advisory Commission on State Emergency
  Communications (Texas Advisory Commission) Comments at 3-4.

 67  See, e.g., Shelby County, Tennessee Emergency Communications District (Shelby County)
  Comments at 1-2; St. Charles Parish Communications District Comments at 1; Claiborne Parish
  Communications District Comments at 2.

 68  See, e.g., Shelby County, Tennessee Emergency Communications District (Shelby County)
  Comments at 2; West Carroll Parish Communications District Comments at 1.

 69   See BellSouth Comments at i.

 70   See Reply of BellSouth at 5. Accord Florida PSC Reply at 2.




                                                     10
        17.    Parties opposing mandatory assignment of N11 codes raise various
concerns. Some argue that mandatory assignment of N11 codes could disrupt current
use of an N11 code in some geographic areas,71 while others argue that some LECs
utilize older switching equipment that might not be able technologically either to handle
N11 codes or to bill accurately.72 Some parties believe that N11 codes should be
reserved for non-commercial public service uses.73 Other objections raised include: the
strong likelihood that demand will exceed supply; 74 the likelihood of consumer confusion
if services using N11 codes vary from area to area;75 the difficulty of reclaiming such
codes if the Commission later determines that the public interest requires reclamation;76
the possible challenges to the Commission's jurisdiction over codes used locally; 77 the
use of N11 codes as prefixes, platforms, or gateways to reach a menu of service
providers rather than just a single provider;78 the availability of alternative dialing
arrangements;79 the likelihood of extensive litigation;80 the perceived problems caused
by multiple LECs providing N11 codes in a local dialing area; 81 the potential for
problems if interexchange carriers obtain N11 codes;82 and the problems of
implementing call blocking on pay-per-call N11 numbers.83 Some parties also argue

 71 See, e.g., APCC Comments at 3; ATU Comments at 1; Bellcore Comments at 5; OPASTCO Reply
  Comments at 2.

 72   See, e.g., GTE Comments at 4; USTA Comments at 17; U S WEST Comments at 16.

 73 See, e.g., Ameritech Comments at 5; CSCN Comments; U S WEST Comments at 6; NYNEX Reply
  Comments at 2; NCLD Reply Comments at 9.

 74 See, e.g., Ad Hoc Telecommunications Users Committee (Ad Hoc) Comments at 6; Ameritech
  Comments at 2; SNET Comments at 3; GTE Reply Comments at 5; Sprint Reply Comments at 3.

 75 See, e.g., Ad Hoc Comments at 3; AT&T Comments at 4; Ameritech Comments at 8; ARRC Reply
  Comments at 6; OPASTCO Reply Comments at 4.

 76   See, e.g., Bellcore Comments at 5; BONA Comments at 4; SWBT Comments at 9.

 77 See, e.g., ATU Comments at 2; NTCA Comments at 5; Pacific Comments at 17; NYPDS Reply
  Comments at 1.

 78 See, e.g., AT&T Comments at 3; Bell Atlantic Comments at 2; IIA Comments at 1; SNET Comments at
  5; ARRC Reply Comments at 7; Pacific Reply Comments at 3.

 79 See, e.g., Ameritech Comments at 6; NYNEX Comments at 4; USTA Comments at 9; U S WEST
  Comments at 10; NYPDS Reply Comments at 4; SWBT Reply Comments at 2.

 80   See, e.g., Ameritech Comments at 10; Rochester Comments at 3; GTE Reply Comments at 2.

 81   See, e.g., GTE Comments at 5; MFS Comments at 5; and OPASTCO Reply Comments at 3.

 82   See, e.g., Pacific Comments 10; SWBT Comments at 7.

 83   See PRTC Comments at 4.




                                                 11
that an abbreviated dialing arrangement (such as an N11 code) is merely a
convenience, and is not essential to making information services available to
consumers.84

        18.  Many commenters claim that the scarcity of such codes and the many
competing uses for them require that all the remaining N11 codes be devoted to public
service uses.85 Possible public service uses include multiple codes for emergency
services,86 special number services for persons with physical disabilities,87 and
telephone access to federal and state agencies.88 Information service providers urge
the Commission not to narrowly define public use as encompassing only nonprofit
entities. They assert that commercial uses of N11 codes serve the public interest by
providing the public access to information which is difficult for the general public to
obtain.89

        19.   Discussion. We decline to require LECs to make N11 codes available for
information services at this time. We anticipate that because only three to five N11
codes will be available in any given geographic area, demand for each N11 code is
likely to exceed supply.90 We agree with Rochester's argument that open assignment of

 84   See, e.g., USTA Comments at 12; Sprint Reply Comments at 5.

 85 See, e.g., Ameritech Comments at 5; CSCN Comments at 4; NCLD Reply Comments at 4; NYNEX
  Reply Comments at 2; SWBT Reply Comments at 5.

 86   See, e.g., Ameritech Comments at 6; NYNEX Comments at 4; Pacific Comments at 3.

 87   See, e.g., BellSouth Reply Comments at 10, NYNEX Reply Comments at 2.

 88   See GSA Petition.

 89 See Media Parties (collectively, Cox Enterprises, Inc., Advance Publications, Inc., Gannett Co., Inc.,
  The Hearst Corporation, The Washington Post Company) Reply Comments at 3-6.

 90  Generally for most of the 50 states, 911, 411, and 611 are deemed to be "special services," and are
  defined as services for which the caller either pays no charge or the charge is tariffed. This category
  also includes services that require presubscription and provide access to customer services provided by
  the LEC, including access to LEC repair services. See generally, "Central Office Code Usage Report",
  Industrial Analysis Division, Common Carrier Bureau, Federal Communications Commission, July,1993
  (FCC Report); "The Use of N11 Codes and Other Abbreviated Dialing Arrangements- State Survey",
  Sandy Ibaugh, Indiana Utility Regulatory Commission, November, 1993 (NARUC Report). For a vast
  majority of the states, the codes 211, 311, 511, and 711 are reserved for various purposes but are not
  currently in use. See FCC Report at 3.

  Some state regulatory commissions have granted assignments of N11 codes for commercial uses. By
  the terms of the Commission's Local Competition Second Report and Order and this First Report and
  Order, these grants, some of which are described below, are left in place. The Florida Public Service
  Commission, for example, approved "511" for an information service run by Cox Communications' Palm
  Beach Post as a two year experiment in 1993. State Telephone Regulation Report, Vol. 11, No. 16
  (August 12, 1993). The State of Georgia has approved the use of "211" code for Cox Communications'
  information service in Atlanta. NARUC Report at 9. The State of Hawaii has reserved 711 for TRS
  access use. Some sections of Maryland use 711 for internal LEC use by telephone company




                                                  12
N11 codes is likely to invite "endless litigation over the reasonableness of an exchange
carrier's allocation plan."91 According to Rochester and others, this potentially could
draw the Commission into numerous decisions as to who should receive unassigned
N11 codes and for what purpose.92 As a result, we believe that the burden should be
on those who urge the Commission to require that LECs assign available N11 codes to
show that the benefits of such a requirement outweigh the costs. On the record before
us, we are not satisfied that supporters of such a requirement have met this burden.

       20.    The parties offer only conjecture that, from a user's perspective, using N11
codes significantly enhances the quality of access to information services. First,
although an N11 number for information services may be considered "novel," and might
be convenient for some users, it is by no means essential to making the service
available. Second, even assuming that consumers do perceive a benefit from such
abbreviated dialing arrangements, we find there are other ways currently available to
achieve convenient dialing that do not drain scarce N11 resources. In New York, for
example, information services are assigned a common central office prefix such as 540
or 970.93 As consumers associate these prefixes with information services, they need
remember only the last four digits of an information service provider's telephone
number. Such dialing arrangements appear to offer the same results as N11 without
the competitive concern of having to decide to whom the codes should be assigned.

       21.   We recognize the concerns expressed by some information service
providers that, absent Commission order, some LECs may unjustly or unreasonably
withhold N11 codes for local information services. As discussed in the FNPRM below,
we propose that the LECs' functions related to N11 administration94 be transferred to
the neutral NANP administrator to be recommended by the NANC. 95 With a neutral

  employees. See FCC Report at 25 and 49. According to a staff member of the New York State
  Department of Public Services, Teleport currently allows end users to dial 211 at its own payphones to
  permit callers to access Port Authority Police for access to its emergency services. This use of 211 is in
  addition to the use of 911 for access to emergency services at New York City PSAPS. While Teleport
  does not use 211 in this manner as a result of an NYSDPS requirement, according to the NYSDPS staff
  member, the NYSDPS does not prohibit such use. See E-mail reply from Yog Varma, NYSDPS, to
  Elizabeth Nightingale, FCC, CCB, dated November 7, 1996.

 91   Rochester Comments at 3.

 92   See, e.g., Rochester Comments at 3; Ameritech Comments at 10; GTE Reply Comments at 2.

 93 New York Telephone states that the 540, 550 and 976 prefixes currently available to enhanced service
  providers allow for 30,000 seven-digit numbers within a LATA. By contrast, up to only eight N11 codes
  would be available for local information services in the New York Telephone service area. See New
  York Telephone Comments at 4.

 94 By the terms of the Commission's Local Competition Second Report and Order and this First Report
  and Order the incumbent LECs are permitted to continue performing functions related to N11
  administration they performed prior to enactment of the 1996 Act amendments to the 1934 Act.

 95   See NANP Order at para. 65-67.




                                                   13
administrator, the concerns of the information service providers should be mitigated.
We also note that when a LEC assigns N11 codes, it must do so in a reasonable, non-
discriminatory manner, such as on a first-come, first-served basis.96 Should, however,
there be particular problems related to the availability of one or more N11 codes from a
particular LEC serving as the administrator prior to the transfer of functions to a new
NANP administrator, parties can bring these unresolved disputes to our attention by
filing a complaint pursuant to Section 208. We also are prepared to address specific
problems even after a transfer of N11 code administration to a new entity.
              3.     National Assignment of Specific N11 Codes

                           a.     Background

        22.    The N11 NPRM did not propose to disturb 911's existing designation as a
national code for emergency services97 nor did it propose to disturb the use of 411 for
local directory assistance. Currently, 411 directory assistance services are classified as
basic or adjunct to basic services for purposes of the Commission's rules even if those
numbers are not presently used in some geographic areas for those purposes. 98 In
addition, the Commission tentatively concluded: (1) that 211, 311, 511, and 711, which,
at the time of the N11 NPRM were "apparently not used at all,"99 should be available for
abbreviated dialing; and (2) that the 611 code now used by some LECs for repair
services and the 811 code now used for quick connection to LEC business offices
should also be available for abbreviated dialing.100

                           b.     Emergency Services (911)

       23.  As stated above, AT&T designated 911 as a national code for reaching
emergency services. Commenters generally agree that the current use of 911 for
emergency services should remain unchanged.101 We find that use of a national
uniform N11 code for this purpose clearly serves the public interest because end users

 96    See May 4 1992 FCC General Counsel Letter to BellSouth.

 97    See footnote 12, supra, regarding AT&T's designation of 911 as a national code.

 98   N11 NPRM at para. 11. A basic service is an offering of transmission capacity between two or more
  points suitable for a user's transmission needs, and subject only to the technical parameters of fidelity
  and distortion. See North American Telecommunications Association, Petition for Declaratory Ruling
  Under Section 64.702 of the Commission's Rules Regarding the Integration of Centrex, Enhanced
  Services, and Customer Premises Equipment, 101 FCC 2d 349, 358 at para. 23 (1985) NATA Centrex
  Order), recon., 3 FCC Rcd 4385 (1988). An adjunct to basic service is a service that might fall within a
  literal reading of our definition of enhanced service (see footnote 8, supra) but which is clearly basic in
  purpose and use and which brings maximum benefits to the public through its provision in the network.

 99    N11 NPRM at para. 8.

 100    Id. at para. 12.

 101    See, e.g., Ameritech Comments at 7; Sprint Reply Comments at 4.




                                                     14
know that they can dial this code from virtually any exchange in the country in order to
obtain emergency assistance. Moreover, 911's virtual ubiquity and long-standing
nationwide status as the phone number for quick and easy access to emergency
services along with the absence of equally useful numbers for this important public
purpose, supports its continuing use.102 We, therefore, do not intend to alter 911's
designation as a national code.103

                         c.     Access          to        Government
                                Services

        24.   Background. GSA, in its petition, requests that the Commission assign an
N11 number for access to federal government agencies. GSA proposes that callers
dialing the GSA N11 code be connected to a menu of services, and select the federal
agency or service desired by responding to recorded prompts.104 GSA also contends
that such an N11 assignment would serve the public interest by providing easy access
to the federal government through a uniform nationwide three-digit code. NASTD seeks
uniform nationwide assignment of an N11 code, specifically 211, to facilitate public
access to state agencies.105 NASTD, in comments supporting its request, argues that
such a number would serve the public interest because: (a) virtually everyone needs
the services of state agencies at one time or another; (b) state government institutions
and programs would be made more readily available to state citizens; and (c) national
uniformity would enhance accessibility regardless of the state in which a person
happens to be located.106 The Department of Justice, in its request, asks that the

 102 The Minnesota Department of Administration 911 Program, based on a compilation of state-by state
  estimates of population coverage as of late 1996, estimates that approximately 87 percent of the
  population in the United States is served by 911. See, facsimile transmission from Jim Beutelspacher,
  Minnesota 9-1-1 Program to Elizabeth Nightingale of the FCC Common Carrier Bureau dated November
  22, 1996.

 103  In an Order released July 26, 1996, the Commission adopted rules regarding enhanced 911 (E911)
  emergency service for wireless providers. See In The Matter of Revision of the Commission's Rules to
  Ensure Compatibility with Enhanced 911 Emergency Calling Systems, CC Docket No. 94-102, RM-8143
  Report and Order and Further Notice of Proposed Rulemaking, FCC 96-264 (released July 26, 1996)
  (Wireless E911 Report and Order and FNPRM). The Commission, also in CC Docket No. 94-102,
  currently is considering establishing E911 rules in the wireline context. See Revision of the
  Commission's Rules to Ensure Compatibility with Enhanced 911 Emergency Calling Systems, Notice of
  Proposed Rulemaking, 9 FCC Rcd 6170 (1994). We also note that, under the Act, BOCs, before they
  are permitted to offer in-region, interLATA services, must show that the access or interconnection they
  offer to other telecommunications carriers includes, among other things, "non discriminatory access to . .
  . 911 and E911 services." 47 U.S.C. §271(c)(2)(B)(vii)(I). We highlight this obligation here to emphasize
  the duty imposed by Congress on each BOC to provide competitors with nondiscriminatory access to
  911 and E911 services.

 104   GSA Petition at 2-3.

 105  See NASTD September 22, 1993 Letter to FCC Commissioner Quello. Comments filed in response
  to the GSA and NASTD requests will be referred to as Government Comments.

 106   NASTD Government Comments at 2.




                                                     15
Commission reserve an N11 number, specifically 311, for use for non-emergency police
telephone calls and suggests that the number could be used to give access to other
government services, at the discretion of each jurisdiction.

        25.   Comments. While many commenters agree that N11 codes should be
assigned for national public use, and acknowledge the benefit of quick and convenient
public access to government services, commenters are divided on the issue of whether
these services warrant a national N11 assignment. Several commenters support
assignment of a national N11 code for access to government services.107 For example,
the City of Dallas (Dallas) "urge[s] the Commission not only to assign a 3 digit number
for national usage of Federal Government offices, but also one for local government and
one for state government use."108 In noting that it is seeking use of an N11 code
(preferably 511) for access to its city's services, Dallas asserts that "use of a simple to
dial, easy to remember number will aid in our desire to be more responsive and
accountable to our citizens."109 Dallas notes the N11 usage it seeks is similar to that
proposed by GSA. The Tennessee Valley Authority (TVA) supports the Commission's
proposal to establish a national N11 code, arguing that such a code would provide
greater awareness and access to its services.110 The United States Department of
Agriculture (USDA) claims that use of a national N11 code will enable it to more
effectively control their emergency preparedness programs in times of natural
disaster.111 Further, USDA suggests that the use of an N11 code will encourage public
calls on a more timely basis, thereby increasing efficiency and its ability to serve the
public.112

      26.     Nevertheless, many argue that it would be premature to grant GSA's or
NASTD's request at this time. MCI and Sprint, for example, argue that the Commission
should first establish a comprehensive policy governing assignment of available N11


 107 See, e.g., Overseas Private Investment Corporation Government Comments at 2; City of Dallas
  Government Comments at 2; Tennessee Valley Authority Government Comments at 2.

 108   Dallas Government Comments at 2.

 109   Id. at 1.

 110   TVA Government Comments at 2.

 111   USDA Government Comments at 1.

 112 Several federal executive agencies take the same position with respect to increased efficiency and
  public responsiveness. See, e.g., Department of Health and Human Services (DHHS) Government
  Comments at 2; The Department of Justice Government Comments at 2; U.S. Department of
  Transportation (DOT) Government Comments at 2; Department of Veteran Affairs (VA) Government
  Comments at 3; Environmental Protection Agency (EPA) Government Comments at 2; Overseas Private
  Investment Corporation (OPIC) Government Comments at 2; Consumer Products Safety Commission
  (CPSC) Government Comments at 1; National Aeronautics and Space Administration (NASA)
  Government Comments at 1.




                                                 16
codes, including codes assigned to the government.113 NENA expresses concerns
about possible public confusion between N11 codes for emergency and non-emergency
government information programs.114 As noted above, in opposing assignment of N11
codes for commercial purposes, several agencies also express concern about
confusion with 911. Several of these parties ask that the Commission not allow any
new N11 code assignments, or in the alternative, if the Commission decides to allow
new assignments, limit the new assignments to access to public service and
governmental entities.115 The Caddo Parish Communications District Number One
(Caddo Parish) cautions that if the Commission grants the GSA and NASTD requests,
close cooperation will be needed between local governments operating 911 emergency
systems and all Federal and State agencies participating in the use of the N11
number.116 There is also concern expressed that there are numerous technical and
cost issues that must be resolved before abbreviated codes can be implemented. For
example, BellSouth notes that the N11 use contemplated by GSA has not yet been
tested.117    GSA responds that alleged technical and other barriers are not
insurmountable and that, in any event, it does not envision a "flash cut" to ubiquitous
nationwide access to its proposed information services.118 Finally, the Ad Hoc
Telecommunications Users Committee (Ad Hoc) argues that the GSA request, as well
as the state requests, should be denied. Ad Hoc suggests that the Commission act
expeditiously to ensure that N11 codes are allocated on a uniform national basis 119 and
acknowledges that an N11 code may provide users with the benefits of ease and
recognition.120 Ad Hoc argues, nonetheless, that GSA fails to demonstrate a compelling
need for the assignment.121

       27.   Acadian Ambulance Service, Inc. (Acadian), a privately-owned ambulance
service in Louisiana using 311 since August 1, 1994,122 supports the Commission's


 113   See MCI Government Comments at 3-4; Sprint Government Comments at 3.

 114   NENA Government Reply Comments at 3.

 115 See, e.g., Texas Advisory Commission Government Comments at 4-5; Jackson Parish 9-1-1
  Communication District Government Comments at 1.

 116   See Caddo Parish Government Reply Comments at 7.

 117   BellSouth Government Comments at 6-7.

 118   GSA Government Reply Comments 13-14.

 119   Ad Hoc Government Comments at 4.

 120   Id. at 7.

 121   Id. at 7-8.

 122   Acadian states that is serves 23 Louisiana parishes.




                                                     17
proposal in the N11 NPRM that LECs be required to provide abbreviated dialing
arrangements. Acadian states that customer confusion will not result from the use of
abbreviated dialing arrangements,123 but requests that the Commission provide
grandfathering preferences for medical communications systems "that are already
saving lives on existing N11 service code authorizations."124 Acadian requests that the
grandfathering include retaining existing medical and emergency services' use of N11
codes as authorized by other governmental bodies, such as state public service
commissions, and requiring recall of N11 codes used for emergency services (after a
minimum one-year notice period) only after the recall of those used for other services.125
According to Acadian, these grandfathering preferences are warranted because of the
life-saving services provided by emergency communications systems such as
Acadian's.126 Several local government agencies involved in the provision of 911
emergency service, while requesting that the Commission not allow any new N11 code
assignments, assert that if the Commission decides to allow new assignments, the new
assignments should be limited to access to public service and governmental entities.127

      28.    Many parties filing comments128 in response to the Department of Justice's
request for assignment of 311 for non-emergency police calls support that request.129
For example, asserting that their 911 systems have been overloaded by calls that may
not be of an emergency nature, various fire departments across the country filed
comments supporting national assignment of 311 as beneficial to their ability to deliver
emergency services.130 Asserting the need to reduce the number of calls placed to 911,



 123   Acadian Comments at 4.

 124   Id.

 125   Id. at 4-5.

 126   Id. at 5.

 127 See, e.g., Texas Advisory Commission Government Comments at 4-5; Jackson Parish 9-1-1
  Communication District Government Comments at 1.

 128 The comments filed in response to the Department of Justice request are referred to as "311
  Comments."

 129  See, e.g., Ameritech 311 Comments at 2-3; AT&T 311 Comments at 2-3; National Association of
  Police Organizations, Inc. (ANPO) 311 Comments; City of Austin Comments; Fire Commissioner/Chief
  of the Boston Fire Department 311 Comments.

 130 See, e.g., Dallas Fire Chief 311 Comments; Fort Worth Fire Chief 311 Comments; Fire Chief of the
  City of Pittsburgh, Department of Public Safety 311 Comments; Fire Chief of the Seattle Fire Department
  311 Comments; Commissioner of the Philadelphia Fire Department 311 Comments; Fire
  Commissioner/Chief of the Boston Fire Department 311 Comments. Cf. International Association of Fire
  Chiefs, Inc., and International Municipal Signal Association (collectively, International Fire
  Chiefs/Municipal Signal); Fairfax County Fire and Rescue Department 311 Comments.




                                                  18
various police departments131 and associations,132 as well as the National Sheriff's
Association133 and the National Troopers Coalition,134 support the Department of
Justice's request.

        29.    The Maryland Public Service Commission (MDPSC) filed comments
supporting the request in which it asserts that 911 is overburdened in many
jurisdictions135and provides information about the two-year trial in Baltimore (Baltimore
311 Trial), which commenced on October 2, 1996, and in which individuals in the City of
Baltimore may dial 311 for access to non-emergency police services.136 The MDPSC
asks that if the Commission does not grant the request that we refrain from taking action
that would compromise the Baltimore 311 Trial.

       30.    Several commenters, while supporting assignment of a non-emergency
number, express concern about issues related to implementation. These concerns
include issues such as routing, translation programming, funding and technical
compatibility with existing 911 systems.137 For example, APCO argues that addition of
this number may cause problems for development of wireless location technology for
911 services.138 CBT cautions that nationwide implementation of 311 will necessitate
translation programming in central offices so that 311 calls that are translated into a
standard seven-digit number in the central office switches will ring to the corresponding


 131 See, e.g., The Dallas Police Department 311 Comments; the San Jose, California 311 Comments;
  the San Bernadino, California Police Department 311 Comments; the Los Angeles Police Department
  311 Comments; City and County of Denver Department of Safety, Chief of Police 311 Comments.

 132 See, e.g., Maryland Chiefs of Police Association 311 Comments; National Association of Police
  Organizations 311 Comments; National Fraternal Order of Police 311 Comments.

 133   See National Sheriff' Association 311 Comments.

 134   See National Troopers Coalition Comments.

 135   See MDPSC 311 Comments at 3.

 136  On October 31, 1996, the MDPSC filed two responses to requests for supplemental information by
  Commission staff. See Response of the Maryland Public Service Commission to Request for
  Supplemental Information From the Federal Communications Commission, CC Docket No. 92-105,
  October 31, 1996; Response of the Maryland Public Service Commission to Request for Supplemental
  Information From the Federal Communications Commission November 6, 1996 (November 6, 1996
  Supplemental Filing).

 137   See, e.g., Cellular Telecommunications Industry Association (CTIA) comments; Ameritech 311
  Comments at 2-3; The Association of Public-Safety Communications Officials-International, Inc. (APCO)
  311 Comments at 2-3; Cincinnati Bell Telephone Company (CBT) 311 Comments at 4-5; County of Los
  Angeles 311 Comments at 2; Los Angeles Police Department 311 Comments; Texas Department of
  Information Resources (Texas DIR) 311 Comments at 2-3.

 138   APCO 311 Comments at 2.




                                                   19
local law enforcement agency.139 The County of Los Angeles expresses concerns
about expenditures, staffing and technical compatibility with 911 systems, such as
Automatic Location Identification (ALI) and Automatic Number Identification (ANI). 140
The Los Angeles Police Department contends, for example, that: a national non-
emergency N11 number should be supported by the same network selective routing
system as E911/911 to ensure appropriate routing of non-emergency and emergency
calls; the non-emergency calls should be supported with full ANI and ALI, provided
through the same database platform; and in the future network, as with 911 calls, 311
calls should be routed using signalling system 7 over the public switched telephone
network instead of on dedicated trunking.141 The Texas DIR supports the request, with
the stipulation that a local jurisdiction could provide access to other government
information and services,142 but asserts that the FCC must first consider such things as
the possibility of adverse impacts to 911 and that access to government information
should include all levels of government and both voice and data information.143 The
Texas DIR expresses concern that the Justice Department proposal does not address
funding, noting that for the Baltimore 311 project, the Justice Department has provided
$350,000 dollars to the City of Baltimore for the two-year project and that AT&T has
donated phone lines and invested over $1 million in the program.144

       31.   Parties also raise concerns about the ability to analyze the results of the
Baltimore 311 Trial prior to the Commission's making a determination in this
proceeding.145    Several other parties suggest that it is premature to make a
determination that 311 should be assigned for non-emergency police calls,146 claiming,
for example, that the issue should be referred to industry fora,147 that the Commission

 139   See CBT 311 Comments at 4.

 140 See County of Los Angeles 311 Comments at 2. Other commenters raise the issue of the use of ALI
  for 311 non-emergency services. See, e.g., Cellular Telecommunications Industry Association (CTIA)
  311 Comments (expressing concern about whether ALI would be required for 311); City of Houston 311
  Comments (asserting that the 311 code will not require a dedicated telephone network because, unlike
  911 ALI will not be needed).

 141   See Los Angeles Police Department 311 Comments at 2.

 142   See Texas DIR 311 Comments at 2.

 143   See Id. at 2-3.

 144   Id. at 2.

 145   See, e.g., California Highway Patrol 311 Comments; Cox 311 Comments at 1-2.

 146 See, e.g., GTE 311 Comments at 2-4; BellSouth 311 Comments at 3; The Office of Information
  Resources of the Budget and Control Board of the State of South Carolina (South Carolina OIR) 311
  Comments.

 147   See, e.g., GTE 311 Comments at 2-4; BellSouth 311 Comments at 4-5.




                                                  20
should subject the issue to further scrutiny in the context of a broader review of
abbreviated dialing arrangements,148 and that alternative dialing arrangements such as
800 and seven-digit or ten-digit numbers should be considered.149 Several parties
opposing the Department of Justice's request also cite available 800, seven-digit and
ten-digit alternatives.150

       32.     Parties opposing the Department of Justice's request include entities
currently assigned 311 for local use, several state 911 communications centers,151 the
National Emergency Number Association (NENA)/National Association of State Nine
One One Administrators (NASNA) (collectively, National 911 Commenters), and the
International Association of Fire Chiefs, Inc., and International Municipal Signal
Association (collectively, International Fire Chiefs/Municipal Signal). Many parties
opposing the Department of Justice's request cite implementation concerns, 152 suggest
education efforts as an alternative,153 and caution that implementation of a non-
emergency number prior to ubiquitous 911 service would be detrimental to efforts to
make it so.154

      33.     The National 911 Commenters oppose the Department of Justice request,
arguing, for example, that 911 networks in most of the country are not overloaded;155
time and speed dialing are not important in non-emergency situations; N11 numbers,
unlike seven-digit and ten-digit numbers (such as 800 numbers) are scarce;
implementation is costly; and there are wide local variations of use of N11 numbers,


 148   See South Carolina OIR 311 Comments.

 149   See GTE 311 Comments at 2-4.

 150 See, e.g., Texas Advisory Commission on State Emergency Communications (TX-ACSEC) 311
  Comments at 2; Arizona APCO Chapter 311 Comments; Mesa 311 Comments at 1-2; King County E911
  Program Manager Comments at 1-2; International Association of Fire Chiefs, Inc., and International
  Municipal Signal Association 311 Comments at 9-11 (suggesting a 555 number alternative).

 151See, e.g., City of Mesa, Arizona, Police Department Communications (City of Mesa) 311 Comments;
  Southern Idaho Regional Communications Center 311 Comments; Greater Harris County 9-1-1
  Emergency Network 311 Comments.

 152 See, e.g., National 911 Commenters 311 Comments at 6-7; Arizona APCO Chapter 311 Comments;
  City of Mesa 311 Comments at 1-2; International Fire Chiefs/Municipal Signal 311 Comments at 7-9.

 153   See, e.g., Bismark Emergency Management & Combined Communications (Bismark) 311
  Comments; Cox 311 Comments at 4; Greater Harris County 9-1-1 Emergency Network 311 Comments
  at 1; Mesa Comments at 1; Southern Idaho Regional Communications Center 311 Comments; Fairfax
  County Fire and Rescue Department 311 Comments; King County E911 Program Manager 311
  Comments at 1; International Fire Chiefs/Municipal Signal 311 Comments at 7.

 154   See, e.g., Mesa 311 Comments at 1; Arizona APCO 311 Comments at 1.

 155   National 911 Commenters 311 Comments at 4.




                                                21
which, in some cases are causing confusion for 911 callers.156 The National 911
commenters ask whether national uniformity is superior to local choice and also contend
that the Commission must consider that there are other pending requests for N11
numbers.157 The State of New York Department of Public Service (NYSDPS), while
supporting the concept of a national non-emergency police N11 number, opposes the
use of 311 for this purpose because this code is used in New York state by individuals
with hearing or speech disabilities to access New York State Police emergency
services.158 NYNEX also opposes the particular use of 311 for the same reason, but,
unlike NYSDPS, opposes the use of an N11 code for this purpose generally, on the
grounds that it may be too easily confused with 911. 159 NYNEX suggests, as an
alternative, an interchangeable numbering plan area (INPA) three digit code such as
222, 333, 444, 777 or 933, and any conflicts between the INPA and an NXX could be
resolved through "interdigital dialing" by having switches programmed to determine
whether an NXX is dialed after the INPA.160 Other opponents, like NYNEX, cite
possible confusion with 911 as a reason not to choose 311 as a non-emergency police
number.161 The City of Fresno, California Chief of Police (Fresno Police Chief), while
not objecting to a national three digit number for non-emergency police calls, contends
that the national number should not have any of the numbers contained in 911, and
suggests, for example, a number such as 333. The Fresno Police Chief also suggests
that the national number should not be mandatory and that if it is, "legislation be passed
to fund the cost of establishing and maintain[ing] the non-emergency telephone
system."162 Costs of upgrading the network and funding issues are raised not only by
opponents of the Department of Justice's request163 but also by its supporters who
express concern about implementation of 311.164



 156   Id. at 6-7.

 157   Id. at 8.

 158   NYSDPS 311 Comments at 1.

 159   See NYNEX 311 Comments at 2.

 160 See id. at 3. See also Florence Cainoce, Staff Manager for NYNEX Consumer Affairs 311 Comments
  at 2, stating that she is a member of the Deaf community and she hopes 311 will continue to be used in
  New York for its current purpose until the year 2000.

 161  See, e.g. National 911 Commenters 311 Comments at 8; Cox 311 Comments at 5-6; International
  Fire Chiefs/Municipal Signal 311 Comments at 6.

 162   Fresno Police Chief 311 Comments.

 163See, e.g., City of Mesa 311 Comments at 2; Arizona APCO 311 Comments at 2; National 911
  Commenters 311 Comments at 6-7; International Fire Chiefs/Municipal Signal 311 Comments at 8.

 164   See, e.g., AT&T 311 Comments at 3; Los Angeles Police Department 311 Comments at 2;




                                                 22
       34.    Several other parties note current uses of 311. Acadian Ambulance and
AIR MED Services of Louisiana (Acadian et. al.),165 while generally supporting the non-
emergency number effort, opposes the selection of 311, which it has been using since
March 1994 to provide rural ambulance service in Louisiana. Acadian et al. requests
that the Commission, if it chooses 311 as a national non-emergency number, direct the
Louisiana PSC to award Acadian a replacement number. 166 The Kentucky Department
of Transportation (Kentucky DOT) and the Ohio Department of Transportation (Ohio
DOT), while both supporting the assignment of a national non-emergency N11 number,
object to the choice of 311 because each uses that number in its state for traffic
information. The Ohio DOT cites its current cellular use of the number and pending
request for landline use for the Advanced Regional Traffic Interactive Management and
Information System (ARTIMIS), a traffic management system that according to the Ohio
DOT has been very successful.167 The Kentucky DOT states that it views N11 as a
scarce numbering resource that should be assigned for public, rather than private
projects, but contends that it has spent much money, including a "business opportunity"
fee of $45,000.00 per year to Cincinnati Bell Telephone Company (CBT), for its use of
311.168 The Kentucky DOT suggests 611 as an appropriate number, contending that
very few telephone customers actually know that this number can be used for telephone
company repair calls.169 CBT, although expressing implementation concerns and noting
the Kentucky DOT's current use of 311, supports the Department of Justice's request.170
Morris Communications Corporation (Morris) of Augusta, Georgia, opposes the request
because the company uses 311 in three cities in Georgia and one in Florida as a pay-
per-call number providing updates on, for example, news, sports and entertainment.
Morris requests that a different three digit code be used, suggesting that 811 might be
better because it immediately precedes 911.171 Finally, Morris states that it would
investigate whether its legal rights would be infringed by a "taking" of the 311
number.172


 165 Acadian Ambulance Service, Inc. (Acadian) filed comments in response to the N11 NPRM. See para.
  28, supra. Acadian filed together with AIR MED Services of Louisiana (Acadian et. al.) in response to
  the Department of Justice request. Acadian et. al. states that it serves 26 Louisiana parishes, three
  more than Acadian said it served in 1994.

 166   See Acadian et. al 311 Comments at 2-4.

 167   See Ohio DOT 311 Comments at 1-2.

 168   See Kentucky DOT 311 Comments at 2.

 169   Id.

 170   See CBT 311 Comments at 2.

 171   See Morris 311 Comments at 1.

 172 Id. The Commission has stated that carriers do not own numbers and that numbers are a national
  public resource. See para. 71, infra.




                                                 23
        35.    Discussion. We find assignment of a national number through which the
public could gain access quickly to non-emergency police and other government
services173 to be in the public interest. After reviewing the record, we conclude that this
number should be an N11 code, specifically 311. We direct Bellcore, as of the effective
date of this First Report and Order, in its capacity as NANP administrator, to assign 311
for this purpose. When a provider of telecommunications services receives a request
from an entity (for example a local police chief or local fire chief) to use 311 for access
to non-emergency police and other government services in a particular jurisdiction, it
must ensure that, within six months of the request: (1) entities that were assigned 311
at the local level prior to the effective date of this First Report and Order relinquish non-
compliant uses; and (2) it takes any steps necessary (for example reprogramming
switch software) to complete 311 calls from its subscribers to a requesting 311 entity in
its service area.

        36.   We find that use of an N11 code for access to non-emergency police
services could alleviate congestion on 911 circuits, which could permit more effective
operation of 911 emergency services. By promoting the safety of life and property,
ensuring the public prompt access to emergency services is consistent with the purpose
stated in Section 1 of the Act.174 In determining not to alter 911's designation as a
national code for emergency services, we have already noted that the use of 911 for
this purpose "clearly serves the public interest because end users know that they can
dial this code from virtually any exchange in the country in order to obtain emergency
assistance."175 Therefore, ensuring that 911 circuits are not overburdened with non-
emergency calls is also of utmost importance. Eventually, the use of a single N11 code
nationwide for non-emergency calls will let callers know that they can dial this code from
any exchange (to obtain necessary governmental services) without hampering others'
access to 911 for emergencies. We also are confident that local education programs
will help ensure that members of communities become aware of: (1) the new non-
emergency number and its primary purpose; (2) the importance of continuing to dial
911 in real emergencies; and (3) any secondary uses for the new code in the particular
jurisdiction.

      37.    We also leave with local jurisdictions in the first instance the discretion to
determine whether 311 should be used locally to reach other government services, as
the Department of Justice has suggested.176 Local jurisdictions can better determine
whether this code could or should be used for access to services in addition to non-
emergency police services. We find that state public utilities commissions, in
conjunction with state and local governments, can address any conflicting requests for

 173   See discussion at para. 37, infra.

 174   See 47 U.S.C. § 151.

 175   See para. 23, supra.

 176   See Department of Justice August 26, 1996 Letter.




                                                   24
use of 311 (for example situations in which city and county law enforcement agencies
both request 311 implementation in the same geographic area) better than us.

       38.    The record indicates that 311 is being used in several jurisdictions. Our
decision to allow other uses of the 311 code to continue for a reasonable period will
ensure that there is no unreasonably abrupt disruption of those uses. We expect that,
in ensuring relinquishment of non-compliant uses of 311 as required above, providers of
telecommunications services also ensure that this occurs with the least disruption
possible to the user's business.177 We are particularly concerned that there be no
confusion for individuals with hearing or speech disabilities who currently use 311 to
access emergency services in the State of New York. Our decision to allow non-
compliant uses to continue until six months after a request is made to use 311 for non-
emergency services in a particular jurisdiction will provide the State of New York
additional time: (1) to educate users with hearing and speech disabilities about the
future unavailability of 311 for emergency services; and (2) to ensure that 911 and other
emergency services are directly accessible by users with disabilities, as required by
regulations implementing the Americans with Disabilities Act (ADA).178

        39.   While we acknowledge that many commenters raise concerns about using
311 for non-emergency police calls (citing the possibility of user confusion with 911,
technical issues related to implementation, costs, funding and the potential effects on
the 911 system), we find, nonetheless, that the benefits of a national N11 assignment
for non-emergency calling in those communities choosing to use 311 will outweigh the
implementation concerns, which are most appropriately addressed by local
governments. This national assignment is intended to reduce the burden on 911
circuits, when needed, by providing an easy-to-remember number for such use. We
realize, as the National 911 Commenters assert, that not all 911 circuits are congested.
Local governments are best suited to determine the need for relief of their 911 systems
from non-emergency calling, and therefore, whether to avail themselves of the ability,
made easier by this national assignment, to request 311 implementation in their
respective jurisdictions. Several parties suggest that prior to considering 311 for non-
emergency calling, the Commission should focus on making ubiquitous 911 emergency
calling. As noted above,179 thirty years ago, AT&T designated 911 for access to
emergency services, and this First Report and Order declines to alter this designation
for 911.180 Decisions to implement 911 service continue to be made locally. We do not
require local jurisdictions to implement 911 because they are best fit, as they are with
311, to determine the need for it.

 177   See para. 35, supra.

 178 See 28 C.F.R. § 35.162, implementing Title II of the Americans with Disabilities Act (ADA), 42 U.S.C.
  § 12131 - 12161.

 179   See footnote 12, supra.

 180   See para. 23, supra.




                                                  25
        40.    Some of the concerns that lead certain parties to suggest alternatives to a
national N11 number for non-emergency calls, such as a three digit number without "11"
as the last two digits (such as 222), an 800 number, or a seven-digit number,181 are the
same reasons that have led us to find an N11 number superior to those alternatives:
namely, the similarity to 911. While it may be technically possible to implement the
alternatives above, the similarity between an N11 number and 911 will make the non-
emergency number both easy to remember and easy to use, thus resulting in greater
reduction of non-emergency calls on 911 emergency circuits. We are confident that, to
lessen the possibility of confusion between 311 and 911, local education programs in
jurisdictions requesting 311 service, will focus on the importance of continuing to dial
911 in real emergencies. If a local government concludes that an alternative number is
working well for non-emergency calling, it may decide not to request 311
implementation. Our assignment leaves the choice to local governments.

        41.    We deny requests that current non-compliant uses of 311 at the local level
be grandfathered. Grandfathering existing uses would make it impossible for a local
government, in a jurisdiction that may need to relieve overburdened 911 circuits and in
which 311 is already assigned for non-compliant uses to choose to use 311 to obtain
that relief. We note, however, that uses of 311 for other purposes prior to the effective
date of this First Report and Order may continue until the local government in that area
is prepared to activate a non-emergency 311 service. Our actions here are consistent
with existing Bellcore guidelines permitting local use of N11 codes provided that such
assignments and use can be discontinued on short notice.182 The need to provide
relief, in a timely fashion, when 911 circuits become congested with non-emergency
calls makes it unreasonable for us to defer implementation issues to industry fora.

       42.    States and local governments may deploy 311 through their 911 centers
or devise alternative procedures for routing and answering 311 calls. We acknowledge
that a provider of telecommunications services may incur certain costs (for example, in
reprogramming switch software) to enable implementation of 311. Since 311 calls, like
911 calls, are typically intrastate, states would regulate cost recovery in most
instances.183 Funding of 311 service also is a local issue.

 181  We note that parties have expressed interest in other abbreviated dialing arrangements generally as
  alternatives to N11 codes. We discuss these alternatives at para. 59-62, infra. We find that, on the
  record before us, we are unable to find that the public interest supports national reservation at this time
  of any alternative dialing arrangements for any particular purpose. See para. 61, infra.

 182   See Network Notes, "Numbering Plan and Dialing Procedures" at 3.4.1.

 183 Cf. 47 U.S.C. § 332(c)(3) (preempting state regulation of rates and entry for CMRS, but allowing the
  states to petition the Commission for authority to regulate rates in limited circumstances). Section 332
  provides that CMRS providers are to be treated as common carriers, but permits the Commission to
  forbear from applying certain sections of Title II. Specifically, the Commission may forbear from applying
  any section of Title II, except Sections 201, 202, and 208. See 47 U.S.C. § 332(c)(1)(A). In the CMRS
  Second Report and Order, the Commission determined that it would be in the public interest to forbear
  from imposing most Title II requirements on CMRS providers, including tariffing requirements. See




                                                    26
        43.   The wireless industry expresses concern about costs and other
implementation issues. CTIA,184 while supporting nationwide reservation of 311 for
non-emergency police telephone calls, contends that the Commission must define the
scope of 311 service so that CMRS providers are technically capable of providing the
service. CTIA states that the Commission should, therefore, address how calls would
be routed and terminated. CTIA emphasizes that 311 non-emergency service is
separate and distinct from 911 emergency service and argues, therefore, that carriers
should not be required to provide the same features or the same terms for 311 service
that they do for 911 emergency service (for example, carriers should be able to provide
311 service for a fee). We agree with CTIA that 311 should be used to provide a non-
emergency service that is distinct from 911 service. For this reason, it is not our
intention by this First Report and Order to impose the same types of obligations on
wireless providers with regard to 311 service as we did with regard to 911 service. 185

         44.    We deny GSA's request to assign an N11 code specifically for access to
federal government services. Even though they are not 911 emergency situations, we
find an element of urgency likely attaching to calls to police that is lacking when the
public is seeking access to other governmental services. There are other easily
remembered numbers available from toll free dialing codes that could give the public
prompt and easy access to services for which there is not the urgency associated with
calls to local police. We note, however, that the discretion we give local governments to
use 311 for other government service access, in addition to non-emergency police
access, grants in part NASTD's request for national assignment of an N11 code to
facilitate public access to state agencies.




  Implementation of Sections 3(n) and 332 of the Communications Act, Regulatory Treatment of Mobile
  Service, Second Report and Order, 9 FCC Rcd 1411, 1463-93 (1994).

 184   See CTIA 311 Comments.

 185   See Wireless E-911 Report and Order and FNPRM, cited at footnote 80, supra.




                                                  27
                        d.      Access to Repair Services
                                (611) and Business Office Uses
                                (811)

       45.    Some LECs currently use 611 and 811 to facilitate repairs and other
customer services. Use of these two codes, however, appears to be far less ubiquitous
than use of 411 for directory assistance and 911 for emergency services. For example,
unlike 911 emergency service, LECs may use 611, 811, or other unassigned N11 codes
for other local services. Several LECs that currently use 611, 811, or both for customer
services and internal functions request that they be allowed to continue to use these
N11 codes.186 Because the record does not support reassignment of either of these
N11 codes, we conclude that these two codes may continue to be used for their present
purposes until one or both of them is needed for other national purposes.

       46.      With multiple LECs in the local market, access to these codes for repair
and business office uses by only one facilities-based carrier serving that market would
be anticompetitive. The possibility of anticompetitive effects is not an issue with respect
to other facilities-based carriers because 811 and 611 are only used within a carrier's
own network. Therefore, a facilities-based LEC can use one or both of these codes
even if it is already being used by another LEC. In an effort to ensure that no facilities-
based LEC gains an unfair advantage over its competitors, we conclude that: (1) all
providers of telephone exchange service, both incumbents and new market entrants,
whether facilities or non facilities-based providers of telephone exchange service,
should be enabled to use the 611 and 811 codes for repair services and business office
uses as the incumbent LECs do now; and
(2) by dialing these N11 numbers, customers should be able to reach their own carriers'
repair or business services.        These conclusions are consistent with the Act's
requirement that all LECs permit competing providers of telephone exchange service
and telephone toll service to have nondiscriminatory access to telephone numbers.187




 186   See, e.g., Ameritech Comments at 4; SNET Comments at 2.

 187    See 47 U.S.C. § 251(b)(3). We note that the Commission, in Implementation of the Local
  Competition Provisions in the Telecommunications Act of 1996, CC Docket No. 96-98, First Report and
  Order, FCC 96-325 (rel. Aug. 8, 1996) (First Interconnection Order), motion for stay of the FCC's rules
  pending judicial review denied, Implementation of the Local Competition Provisions in the
  Telecommunications Act of 1996, CC Docket No. 96-98, FCC 96-378 (rel. Sep. 17, 1996), partial stay
  granted, Iowa Utilities Board v. FCC, No. 96-3321, 1996 WL 589204 (8th Cir. Oct. 15, 1996) (Iowa
  Utilities Board v. FCC) (Local Competition First Report and Order) found that CMRS providers
  (specifically cellular, broadband PCS and covered SMR), in addition to meeting the statutory definition of
  telecommunications carriers, also provide telephone exchange service and exchange access as defined
  by the Act. This means that these CMRS providers would have nondiscriminatory access to telephone
  numbers from LECs. See Local Competition First Report and Order at para. 1012-1013. The
  Commission declined to treat CMRS providers as LECs at this time. See id. at para. 1004. Therefore,
  the requirements imposed on LECs in Section 251(b)(3) do not apply to CMRS providers.




                                                   28
                          e.      Directory Assistance (411)

       47.    Like 911 for access to emergency services, 411 has long been assigned
for access to local directory assistance services. Because directory assistance queries
are often made while travelling away from one's regular residence or place of business,
a short, easy-to-recall, uniform nationwide code would be very useful for obtaining
telephone numbers. For these reasons, we find continued use of 411 to call local
directory assistance services justified by public convenience and necessity.
Accordingly, as we proposed in the N11 NPRM, we do not alter the assignment of the
411 code. The number 555-1212, like 411, is a nationally-recognized number for
directory assistance.188 U S WEST, in its comments, noted:

         The 555 central office code, or prefix, is generally used for access to LEC
         directory assistance services. Typically, an end user dials 1+555-1212 to
         reach his/her LEC's 'local' directory assistance service. For directory
         assistance for an area code different than the area code from which the
         call originates . . . the end user dials 1-[area code]-555-1212.189

U S WEST suggests expanding the 555 prefix to information service providers. U S
WEST suggests that "to avoid potential conflicts with existing directory assistance
services, it might be useful to reserve the 555-1XXX series of numbers for directory
information and related services."190 The Commission, in the recent Local Competition
Second Report and Order, concluded that no Commission action was necessary "with
respect to the ability of customers to reach directory assistance services through 411 or
555-1212 arrangements"191 and decided not to require any alternatives to these two
codes for access to directory assistance. By concluding here that the assignment of
411 for such local services should continue, we do not intend to foreclose the use of
555-XXXX or any other dialing arrangements for such services.

        48.   In view of reports that some LECs were planning to use 411 for new
information service offerings that would be classified as enhanced services under our
rules,192 the N11 NPRM sought comment on whether LEC use of 411 should be
restricted to the provision of traditional directory assistance services.193 Several

 188   See Local Competition Second Report and Order at para. 149.

 189   U S WEST Comments at 13.

 190   Id. at 14.

 191   Id. at 151.

 192   See footnote 8, supra, for a definition of "enhanced services."

 193  See N11 NPRM at para. 11. By "traditional" directory assistance services we refer to operator
  provision of local telephone numbers. The Commission has determined that traditional directory
  assistance services are "adjunct" to basic services and are regulated pursuant to Title II of the
  Communications Act. See Amendment of Section 64.702 of the Commission's Rules and Regulations,




                                                      29
commenters argue that we should link a decision to allow a particular LEC to provide
enhanced services through 411 with a decision to direct assignment of N11 codes to
information service providers competing with that LEC.194 Others argue that 411 should
always be restricted to basic directory assistance.195 While we encourage LECs to
expand the range of services they offer to the public, we recognize the possible
competitive advantage that LECs would be given if they were able to use N11 codes for
their enhanced services offerings. We conclude, therefore, that a LEC may not itself
offer enhanced services using a 411 code, or any other N11 code, unless that LEC
offers access to the code on a reasonable, nondiscriminatory basis to competing
enhanced service providers in the local service area for which it is using the code to
facilitate distribution of their enhanced services.196 LECs offering enhanced services
through the use of an N11 code are subject to rules designed to protect against
discrimination and possibly other anticompetitive conduct.197 Moreover, the Bell
Operating Companies (BOCs) are subject to additional safeguards pursuant to
Computer III.198 For example, BOCs offering such services today must file and receive
approval of comparably efficient interconnection (CEI) plans.199 Such measures will
help ensure that competing enhanced service providers will have access to basic
transmission facilities on an unbundled and functionally equivalent basis. 200 These

  77 FCC 2d 384 at para. 421 (1980) (Computer II), modified on recon, 84 FCC 2d 50 (1980) (Computer II
  Reconsideration Order), modified on further recon., 88 FCC 2d 512 (1981) (Computer II Further
  Reconsideration Order), aff'd sub nom., Computer and Communications Industry Assoc. v. FCC, 693
  F.2d 198 (D.C. Cir. 1982), cert. denied, 461 U.S. (1983).

 194   See, e.g., Ameritech Comments at 3; Pacific Comments at 4; USTA Comments at 30.

 195   See, e.g., Mobile Comments at 2.

 196We note that the Commission has established its ancillary jurisdiction over enhanced services in its
  Computer II decision. See Computer II at paras. 124-125.

 197   See, e.g., Computer II at para. 231.

 198    See Amendment of Section 64.702 of the Commission's Rules and Regulations (Computer III), CC
  Docket No. 85-229, Phase I, 104 FCC 2d 958 (1986) (Phase I Order), recon., 2 FCC Rcd 3035 (1987)
  (Phase I Recon. Order), further recon., 3 FCC Rcd 1135 (1988) (Phase I Further Recon. Order),
  second further recon., 4 FCC Rcd 5927 (1989) (Phase I Second Further Recon.), Phase I Order and
  Phase I Recon. Order vacated, California v. FCC, 905 F.2d 1217 (9th Cir.1990) (California I); Phase II, 2
  FCC Rcd 3072 (1987) (Phase II Order), recon., 3 FCC Rcd 1150 (1988) (Phase II Recon. Order), further
  recon., 4 FCC Rcd 5927 (1988) (Phase II Further Recon. Order), Phase II Order, vacated, California v.
  FCC, 905 F.2d 1217 (9th Cir.1990); Computer III Remand Proceedings, 5 FCC Rcd 7719 (1990) (ONA
  Remand Order), recon., 7 FCC Rcd 909 (1992), pets. for review denied, California v. FCC, 4 F.3d 1505
  (9th Cir.1993) (California II); Computer III Remand Proceedings: Bell Operating Company Safeguards
  and Tier 1 Local Exchange Company Safeguards, 6 FCC Rcd 7571 (1991) (BOC Safeguards Order);
  BOC Safeguards Order vacated in part and remanded, California v. FCC, 39 F.3d 919 (1994) (California
  III).

 199 See, e.g., Bell Operating Companies Joint Petition for Waiver of Computer II, 10 FCC Rcd 13758
  (Com. Car. Bur. 1995).

 200   See Phase I Order at para. 147.




                                                   30
conclusions are also consistent with the Act's requirements that all LECs permit
competing providers of telephone exchange service and telephone toll service to have
nondiscriminatory access to directory assistance and to telephone numbers, 201 and that
BOCs, before they are permitted to offer in-region, interLATA services, must show that
the access or interconnection they offer to other telecommunications carriers includes,
among other things, nondiscriminatory access to directory assistance services. 202

                           f.       Access to Telecommunications Relay Services

         49.   Background. NCLD's petition requests that two N11 numbers be assigned
or reserved for TRS access.203 It states that under the ADA, common carriers are
required to provide TRS, a telephone transmission service designed to provide persons
with speech or hearing disabilities functionally equivalent access to the telephone
network.204 NCLD argues that assignment of N11 numbers will facilitate TRS access
and thus further the goals of the ADA. NCLD states that variations among and within
states in the TRS numbers assigned make access to the relay service confusing and
difficult. NCLD also states that access can be especially difficult for TTY 205 users
because they cannot directly call directory assistance, and thus cannot easily determine
the local relay number. In addition, NCLD argues that an N11 number would
significantly reduce the number of digits that must be dialed when placing a relay call.
NCLD explains that many relay centers have an eleven digit 800 number, and that as
many as twenty-one digits (eleven to reach the relay center, and ten to reach the final
destination) may be needed to complete a call. Finally, NCLD notes that while a
majority of states use two numbers for relay access, one for access by TTY users and
one for access by voice users, approximately seventeen states use only one number for
both TTY and voice callers.



 201 See 47 U.S.C. § 251(b)(3). See footnote 164, supra, for a discussion of the application of this
  provision of the Act to CMRS providers.

 202   47 U.S.C. § 271(c)(2)(B)(vii)(II).

 203  TRS allows people with hearing or speech disabilities to use the telephone. TRS facilities are
  equipped with specialized equipment and staffed by communications assistants who relay conversation
  between people who use text telephones and people who use traditional telephones. The Commission
  issued a Notice of Inquiry (NOI) seeking comment on TRS issues in Telecommunications Relay
  Services, the Americans with Disabilities Act of 1990, and the Telecommunications Act of 1996, Notice
  of Inquiry, CC Docket No. 90-571, FCC 97-7, ___ FCC Rcd. ___, (Released January 14, 1997) (TRS
  NOI). This TRS NOI, states that it will not include consideration of assignment of N11 numbers to
  access TRS because that issue is pending before the Commission and will be addressed in this
  proceeding. See id. at n. 6.

 204   See 47 U.S.C. § 225(a)(3), (c).

 205   TTY is a teletypewriter, which is a device for communicating alphanumeric information over
  telecommunications networks.




                                                 31
      50.   Comments. Most commenters support reservation or assignment of a
nationwide N11 code for TRS access. Commenters agree that a uniform N11 code will
reduce confusion, provide quicker dialing and promote TRS use.206

         51.   States filing comments generally support assignment of nationwide N11
codes for TRS access.207 In particular, the Attorney General of the State of Illinois
(Illinois) supports the allocation of both 711 and a second N11 number to access TRS
on a nationwide basis.208 Texas, relying on the ADA, states that it believes that a
nationwide assignment of N11 codes for TRS is appropriate.209 The Florida Public
Service Commission (Florida), however, while noting that it does not oppose the
assignment of 711 and the use of another N11 code for access to TRS systems,
observes that its investigation of the use of N11 codes, in which it decided not to
reserve N11 codes for TRS access, has revealed that "other numbers such as 555-
XXXX or 1-800-XXX-XXXX could be better suited and more easily converted to TRS
access."210 Florida asserts that any Commission rulemaking should "address N11
access in comparison with other potential access arrangements . . . ." 211

        52.   LECs generally favor reservation of a single N11 code for TRS access, but
question whether an N11 assignment is appropriate at this time.212 Commenters
supporting an N11 reservation, rather than assignment, generally argue that a number
of policy and technical issues must be resolved before a nationwide N11 code for TRS
can be implemented.213        Bell Atlantic states that a dialing arrangement that
automatically routes all TRS callers to a single TRS provider would place other TRS
providers at a competitive disadvantage.214 GTE warns that a "flashcut" to N11 access,
on either a nationwide or statewide basis, would require a heavy commitment of
resources, would be difficult to coordinate, and would create network problems during

 206 See, e.g., Louisiana Relay Comments at 1; Leigh Comments at 1; Life After Deafness/California
  Comments at 1; Gallaudet/Kapi'olani Comments at 1. Comments and reply comments cited in
  paragraphs 30-36 are responding to the NCLD petition.

 207 See, e.g., Oregon Public Utility Commission Comments at 1; Attorney General of the State of Illinois
  Comments at 1; State of Texas Comments in response to Emergency Petition for Rulemaking by
  National Center for & Deafness and Telecommunications for the Deaf, Inc (hereinafter NCLD/TDI
  petition) at 3.

 208   Illinois Comments at 1.

 209   Texas Comments in response to NCLD/TDI petition at 3.

 210   Florida Reply Comments at 3.

 211   Id.

 212   See U S WEST Comments at 3-4.

 213   See, e.g., SWBT Comments at 1-7; U S WEST Comments at 3-4.

 214   Bell Atlantic Comments at 4.




                                                  32
implementation and testing.215 GTE suggests that industry fora could resolve technical
issues and could establish a state by state schedule for implementation.216

        53.    Noting that N11 codes are a scarce resource, several parties suggest
alternative solutions such as a uniform nationwide 800 number, 555-XXXX number, or
950-XXXX number for TRS access. Cox contends that technical and operational issues
render N11 numbers unsuitable for providing uniform access to relay service in the near
future.217 Cox, in its December 12, 1995, ex parte presentation, reiterated its position
that there should be no N11 numbers reserved for national use for access to TRS. 218
Cox presented three general reasons for its position: (1) N11 cannot provide "ubiquity"
in that it would not be possible to make the code available to all subscribers, regardless
of their location; (2) N11, because of the needed modifications in switches around the
country, is too expensive for such a non-commercial use; and (3) N11 is best suited for
purely local services because, for example, current network architectures support such
use, and there are no comparable resources available for local services. Cox asserts
that 800 service would and should be made available for TRS access. Cox notes that
800 service is designed for regional and nationwide coverage. It asserts that,
especially with 800 number portability, a national 800 number for TRS access would be
ubiquitous and much less expensive than an N11 number. U S WEST asserts that "it is
clear that not all U S WEST end offices have the capability to replace the current 800
numbers [through which it accesses service arrangements to route TRS calls] with a
711 telephone number."219 U S WEST suggests that, until technical issues are
resolved, "the industry should promote the deployment of a single national 800
telephone number that can direct calls to the nearest TRS bureau." 220 It asserts that
with a national 800 number using geographic routing, each originating call would go to
the nearest TRS provider. As noted above, Florida, while stating that it does not
oppose the assignment of 711 and the use of another N11 code for access to TRS
systems, suggests the need for a Commission investigation into alternatives to an N11
code, such as an 800 number.221

     54.      Other parties, however, assert that an 800 number, necessitating dialing
many digits, is not a viable alternative to an N11 number for TRS access. Illinois, for
example, states that an 800 number necessitates dialing 17 digits, thus doubling the

 215   GTE Reply Comments at 9.

 216   GTE Comments at 9.

 217   Cox Reply Comments at 3-6.

 218   Cox December 12, 1995 Ex parte Presentation.

 219   U S WEST Comments at 5.

 220   Id. at 7.

 221   Florida Reply Comments at 3.




                                                 33
length of time to dial, and adds that currently each state has one or more different
telephone numbers to access TRS. Illinois asserts that the existence of multiple
numbers may pose difficulties for those travelling to various states:

         In Illinois, for example, voice users and TTY users of the TRS must dial
         one of two 1-800 numbers to access TRS. If a person who is severely
         hard of hearing, deaf, or has speech disabilities travels from another state
         to Illinois and attempts to make a telephone call using TRS, he/she must
         know the 1-800 number or know someone who knows the number or must
         have access to a current telephone book, because one can only reach
         directory assistance (411) through the relay service, not directly by TTY.
         This is especially frustrating for those who travel to many different
         states.222

The State of Wisconsin, Department of Health and Social Sciences (Wisconsin), in
advocating reservation of an N11 number for TRS, expresses concern that currently
"deaf/hard of hearing and speech impaired users of the relay [service] must dial a 11-
digit (800) number to access the service, then enter the 7 or 10-digit number they wish
to call."223 According to Wisconsin, this necessity fails to provide "equal access in
telecommunications." The Triangle Association of the Deaf (Triangle) notes a similar
problem with the use of 1-800 numbers for access to TRS: "often more than 17
numbers must be dialed before reaching the called party, which can double the length
of time on the line needed to dial for relay users."224 NCLD, in its reply comments,
refers to the Commission proceeding that resulted in its July 26, 1991 issuance of rules
implementing title IV of the ADA. Those rules imposed minimum guidelines regarding
TRS service:

         [i]ncluded within the reply comments of [over 70 organizations submitting
         comments to the FCC] was a request that access to relay services be
         made available through a single 800 nationwide telephone number set
         aside through the North American Numbering Plan. The Commission
         responded that because 800 numbers are assigned to particular carriers,
         it did not find it feasible to establish a single, nationwide relay number at
         that time. Nevertheless, even then, the Commission recognized the
         benefits of a universal number: 'We encourage state systems and all other
         relay providers to use numbers that are easy for consumers to remember
         and would further the goal of nationwide access . . . .'225

 222   Illinois Comments at 2.

 223   Wisconsin Comments at 1.

 224   Triangle Comments at 1.

 225NCLD Comments at 8, note 6, quoting Telecommunications Services for Individuals with Hearing and
  Speech Disabilities, and the Americans with Disabilities Act of 1990, Report and Order and Request for
  Comments, CC Docket No. 90-571 at para. 42.




                                                 34
        55.    Discussion. We conclude that an N11 code, specifically 711, should be
assigned for TRS use. We agree with parties asserting that certain issues related to
technical and operational capability, cost, and competition, must be resolved before a
nationwide N11 code for TRS access can be implemented. We address such issues in
the FNPRM. We tentatively conclude that nationwide implementation of 711 for TRS
access should occur within three years of the effective date of this First Report and
Order and we seek comment on this proposal. Three 800-855-XXXX numbers have
been allocated for TRS access by the Industry Carriers Compatibility Forum (ICCF) of
the Alliance for Telecommunications Industry Solutions.226 In the FNPRM, we state that
we do not anticipate any conflict between allowing activation of the 800-855-XXXX
numbers and the later implementation of a 711 code for access by individuals with
hearing or speech disabilities to TTY. The 711 code, unlike the 800 codes, will support
three digit access to TTY by people with hearing or speech disabilities. We believe this
offers distinct advantages to such persons for whom, as commenters note, the time on
the line before reaching the called party would possibly be doubled due to the number
of digits that access through an 800 number would require. A nationwide N11 code
would also eliminate the current need for TRS users travelling from state to state to
remember different lengthy 800 numbers for each state.

         56.   An N11 code may significantly facilitate TRS access, thus furthering the
goals of both the 1996 Act227 and the ADA. In particular, a nationwide N11 code will
significantly reduce the number of digits that must be dialed when placing a relay call,
and will eliminate the problem of determining the appropriate local relay number. We
also note that most commenters agree that assignment of an N11 code for TRS is in the
public interest. Because N11 codes are a scarce resource, and because many states
already provide TRS access for both TTY and voice users through a single number, we
conclude that only one N11 number should be used for TRS. Moreover, because
Hawaii and Canada already use 711 for TRS access, and because uniformity would
facilitate access to TRS, we conclude that 711 is the most appropriate code to support
TRS access. We, therefore, determine that 711 should be assigned as a national code
for TRS use, and we direct Bellcore, in its capacity as NANP administrator, to assign
711 for such use as of the effective date of this First Report and Order.
 226  The entire 855 "NXX" code, within the 800 area code, has been reserved for disability access. NXX
  refers to the first three digits of a North American local telephone number and identifies the local central
  office. N represents any digit from 2 to 9 and X is any digit. Of the approximately ten thousand numbers
  associated with this NXX code, three have been specifically reserved by the industry for access by
  persons with speech or hearing disabilities.

 227 The Act requires that telecommunications services, telecommunications equipment, and customer
  premises equipment be accessible to persons with disabilities, if readily achievable. The duty to ensure
  accessibility is imposed on: (1) telecommunications service providers regarding their services; and (2)
  equipment manufacturers regarding their telecommunications equipment and customer premises
  equipment. See 47 U.S.C. § 255. The Commission released a Notice of Inquiry on September 19, 1996,
  beginning the Commission's implementation of Section 255. See In the Matter of Implementation of
  Section 255 of the Telecommunications Act of 1996, Notice of Inquiry, WT Docket No. 96-198, FCC 96-
  382, 61 Fed. Reg. 50465 (September 26, 1996) (Section 255 NOI).




                                                    35
                4.      Statutory Preemption

      57.    The Act gives the Commission exclusive jurisdiction over numbering in the
United States.228 Because the Commission's jurisdiction is exclusive, the states have
no authority to permit the use of N11 codes in a manner inconsistent with the
conclusions reached in this First Report and Order. As noted above, the release of the
N11 NPRM and the filing of the comments and replies all occurred prior to enactment of
the 1996 Act amendments to the 1934 Act. Insofar as they discuss the issue of
preemption, therefore, they have become moot.229

       58.     Moreover, we find that a nationwide, uniform system of numbering is
essential to the efficient delivery of interstate and international telecommunications. 230
Despite the fact that most individual N11 calls are likely to be intrastate, N11 numbers,
like 911, have significance that go beyond state boundaries. At times, an end user who
is travelling can dial the same N11 code used at home to access the same service
accessed at home. In order to achieve the maximum public benefit from the allocation
of particular codes to certain services, those codes must be allocated in a consistent
manner on a nationwide basis.

                5.      Other Issues

                        a.         Alternate Abbreviated Dialing Arrangements

       59.    Background. In the N11 NPRM, the Commission stated that other
abbreviated dialing arrangements, such as "XX#" or "*XX", might accommodate many
times the number of providers that N11 service codes could serve. 231 We said that
using these arrangements, however, might require substantial time to implement and be
expensive. For example, if "#" were required in an abbreviated dialing arrangement,
dialing could not occur from millions of rotary telephones still in service. Moreover, "#"
and "*" are used today to activate switch capabilities, not for customer dialing. It is

 228   See 47 U.S.C § 251(e)(1).

 229 Few commenters addressed the preemption issue directly. The State of Texas noted that the FCC
  does not have general preemptive authority over the assignment of N11 codes used for "purely intrastate
  uses" but conceded that Title IV of the ADA provides authority for the "FCC to require the uses of a
  particular N11 code for access to interstate relay programs and to condition approval of state programs
  on the use of the same code." See Texas Comments in response to NCLD/TDI petition at 3, citing 47
  U.S.C. §§ 225(b)(2), (c)(2), (d).

 230   See NANP Order at para. 26; Ameritech Order at para. 13.

 231 See N11 NPRM at para. 19. By "alternate dialing arrangements," we mean arrangements other than
  the conventional seven and ten digit sequences that facilitate recall and use by the general public.
  "Abbreviated dialing arrangements" are alternate dialing arrangements that involve less than seven and
  usually four or fewer dialing digits."xx#" is an example where "X" may be any number from 0 to 9.




                                                   36
noteworthy, however, that with CLASS services, if it is not possible to use "*XX" dialing,
for example with a rotary telephone, "11XX" is an alternative abbreviated dialing
arrangement.232 The N11 NPRM invited comment on the feasibility of requiring
abbreviated dialing arrangements to be made quickly available in lieu of or in addition to
requiring exchange carriers to make N11 codes available.

       60.     Comments/Discussion. The record shows that there is considerable
interest in alternative abbreviated dialing arrangements.233 Some commenters seek
abbreviated numbers in only one local calling area,234 while others seek a uniform
abbreviated number for an entire state, a region, or the whole country. 235 Commenters
suggest using numbers with two to four digits plus a "*" or a "#", such as *XX or NXX#.
One commenter suggests codes with "**X."236

        61.   We conclude that abbreviated dialing could clearly serve many useful
purposes and we urge industry fora to continue to explore the feasibility of their use.
When those entities identify abbreviated dialing arrangements that would be practical,
both economically and technically, we encourage them to develop reasonable
guidelines for the implementation and allocation of the related numbers. In addition, we
ask the NANC to explore how rapidly abbreviated dialing arrangements could be
deployed and to report back to the Commission on this issue. On the record before us,
however, we are unable to find that the public interest supports national reservation at
this time of any alternative dialing arrangements for any particular purpose, except as
previously described in this First Report and Order.

      62.     While we decline to make any national assignment or other reservation of
abbreviated dialing arrangements at this time, we reiterate that no federal policy bars
the use of such arrangements for intrastate service offerings.

                        b.      Recall Procedures

      63.   Background/Comments. In the N11 NPRM, the Commission solicited
comment on methods for recalling N11 service codes and any notice periods that
should precede such recalls.237 Several commenters express concern that this

 232  CLASS is a set of calling party number (CPN)-based services, such as caller ID, auto call return,
  selective call forwarding and other services.

 233 See, e.g., Alternative Newspapers Comments at 4; Cox Comments at 4; Advance Reply Comments
  2; Cox Reply Comments at 29.

 234   See, e.g., Cox Comments at 4.

 235   See, e.g., Mobile Comments at 3; MCI Reply Comments at 7.

 236   PBS/PG Comments at 3.

 237   N11 NPRM at para. 13.




                                                  37
Commission or state commissions will be unable to recall on short notice those N11
codes that have been made available for local uses.238 They request establishment of
specific time periods and other procedures for recall to avoid any unreasonable delay if
the public convenience and necessity requires that assigned N11 codes be used for
other purposes.

        64.    Discussion. We believe it unnecessary to adopt specific rules for future
recall of N11 codes at this time. First, widely distributed industry numbering documents
consistently and unambiguously state that an N11 code assignment is not a permanent
assignment and is subject to termination on short notice.239 Second, when state
commissions have allowed N11 use, their authorization orders, which, by the terms of
the Commission's Local Competition Second Report and Order remain in effect,240
consistently state that such use is subject to termination or other modification on short
notice, typically six months.241 If an N11 assignee is unable or unwilling to cooperate in
a national recall of an N11 code, we would not hesitate to order termination of the
switching services necessary to the functioning of that N11 code or to take other action
required to make the N11 code available for other purposes. In the event of a national
recall, the Commission will take such action as necessary to give interested parties
sufficient notice of the recall and an opportunity to be heard on how the recall should be
enforced. Moreover, as the time needed for code relinquishment could vary depending
on the use of codes in question, parties will further be given an opportunity to address
the network, customer, and administrative concerns that affect recall.




 238   See, e.g., SWBT Comments at 9-10.

 239 See Network Notes. "Numbering Plan and Dialing Procedures" at 3-8. As stated above, Network
  Notes does not define short notice.

 240   See para. 13, supra.

 241  See, e.g., Request for Approval of Tariff Filing to Introduce N11 Service, Order Regarding N11
  Abbreviated Dialing, Docket No. 920962-TL, Florida Public Service Commission, Nov. 4, 1993 (noting
  that Southern Bell's tariff clearly states that any and all N11 codes could be recalled by the NANP at any
  time, and if so, must be relinquished within six months).




                                                   38
               6.      Regulatory Flexibility Act

       65.     See Appendix E, infra, for the Final Regulatory Flexibility Analysis.


       IV.     FURTHER NOTICE OF PROPOSED RULEMAKING

       A.      Introduction

       66.    The proposals below, and the comments we seek regarding them, are part
of our analysis of the Commission's role with respect to numbering administration. The
guiding principal shaping these proposals is that a uniform numbering plan is an
essential prerequisite to an integrated public switched telephone network. There must
be a single, consistent set of numbering principles allowing all switching equipment
connected to the network to route every call to its correct destination. Concomitant with
the need for one uniform numbering plan is the imperative that any numbering plan be
capable not only of serving incumbents, but also of accommodating new market
entrants. For this reason, we have attempted, wherever possible, to ensure that new
telecommunications carriers have access to numbering resources on the same basis as
incumbents.

       B.      Access to Telecommunications Relay Services

       67.    While we believe that an N11 code to support nationwide TRS access is in
the public interest, it is not clear, as several commenters note, whether it is technically
feasible to implement such a code at this time.242 We specifically request parties to
address whether there can be nationwide implementation of an N11 code and how to
address less than nationwide implementation, if network facilities of some
telecommunications carriers preclude use of N11 for TRS access. Parties should also
address the following issues:
(1) how competition among relay providers would be maintained; (2) whether
implementation is technically feasible and, if so, the details of such implementation; (3)
the projected costs of implementation and how those costs should be recovered; and
(4) what effect, if any, nationwide implementation of an N11 code for TRS access will
have on CMRS providers and their networks.

      68.    We tentatively conclude that nationwide implementation of 711 for TRS
access should occur within three years of the effective date of the First Report and
Order and we seek comment on this proposal. Sprint, we note, has projected this as a
reasonable timeframe for switched-based N11.243 We understand switched-based N11

 242  For example, there are technical issues associated with the switch modifications necessary to route
  N11 calls on a local basis. Configuring the dialing arrangements to enable relay service users to choose
  interexchange carriers is another technical issue.

 243 Switched-based N11 is only one example of an architectural arrangement supporting the use of N11.
  Another example may be an arrangement using intelligent network capabilities.




                                                  39
in the context of TRS to mean that the N11 dialing information would be stored in the
switch, and when TRS users in a calling area dial the N11 code, the
telecommunications carrier's end office switch would automatically route the call to the
relay center. We understand from Sprint that such implementation may not permit end
users to select a preferred TRS provider.244 We ask that interested parties comment on
what steps must be taken to ready the network for use of 711 as the TRS code and
whether these steps can be completed in the three year timeframe or perhaps even
sooner. We ask parties addressing implementation issues to present a timeline for
completion of steps they foresee as necessary to introduce 711. We also ask parties if
it would be possible to develop within a reasonable time an N11 "gateway" offering
access to multiple TRS providers. With such a gateway, a database query would be
launched, and parties would be able to select their TRS providers, or parties would have
their calls routed to a presubscribed TRS provider. In addition, we request comment on
whether any other important disability services could be accessed through the same
gateway and whether such a gateway would be consistent with Section 255 of the
Act.245 We request comment on whether, with such gateway access, TRS calls would
still be answered within our mandatory minimum standards for TRS answer times,
which require 85% of calls to be answered within 10 seconds.246 Finally, we request
comment from interested parties, particularly TRS providers, about the possibility of
providing both voice and text TRS services through the same abbreviated N11 code.

         C.      Sale or Transfer of N11 Codes

       69.    Background. In the N11 NPRM, the Commission identified the extremely
limited number of service codes available in each geographic area. The Commission
stated that because these codes may acquire some value, holders of these codes may
wish to sell or transfer their numbers to others.247 Accordingly, the Commission sought
comment on whether N11 codes should be permitted to be sold or transferred.248

     70.    Comments. Most commenters oppose the transfer or sale of N11
numbers.249 They argue that the assignment of a public resource, such as N11 codes,

 244   Sprint Ex Parte presentation of July 24, 1995.

 245 This section of the Act requires that telecommunications services, telecommunications equipment,
  and customer premises equipment be accessible to persons with disabilities, if readily achievable. The
  duty to ensure accessibility is imposed on: (1) telecommunications service providers regarding their
  services; and (2) equipment manufacturers regarding their telecommunications equipment and customer
  premises equipment. See 47 U.S.C. § 255. The Commission has begun implementing Section 255.
  See Section 255 NOI, cited at footnote 204, supra.

 246   See 47 C.F.R. § 64.604(b)(2).

 247   N11 NPRM at para. 15.

 248   Id.

 249   See, e.g., AT&T Comments at 7; U S WEST comments at 21.




                                                        40
does not confer property rights upon the assignee.250 Some commenters support the
transfer or sale of N11 codes, but urge the Commission to develop and enforce rules
regarding such transfers and that the transfer or sale be limited to companies that
merge or are acquired.251

        71.   Discussion. The Commission has stated that carriers do not "own" codes
or numbers but rather administer their distribution for the efficient operation of the public
switched telephone network.252 The Commission, also on several occasions, has
further characterized telephone numbers as a national public resource. 253 Based on our
review of the record, we tentatively conclude that N11 codes should not be transferred
or sold through private transactions at this time. N11 codes are not only essential public
resources that serve important national and state goals, but are also much more scarce
than other codes. Parties are asked to comment on our statutory authority to sell the
right to use N11 codes. We also ask parties to distinguish statutory authority to sell the
right to use N11 codes from the right to sell other abbreviated dialing arrangements.

         D.     Administration of N11 Codes

        72.   As stated above, prior to enactment of the 1996 Act amendments to the
1934 Act, Bellcore, the states, the incumbent LECs, and the Commission each
performed functions relating to the administration of N11 codes. Since the AT&T
divestiture, Bellcore has served as the administrator of the NANP. Bellcore has
assigned N11 codes at the national level. In addition, the Commission may direct
Bellcore to assign an N11 code for national use if the Commission determines that such
a national assignment is in the public interest.

      73.    Bellcore, in its role as NANP administrator, has issued specific guidelines
addressing the use of N11 codes.254 These guidelines permit local use of N11 if such
assignments and use can be discontinued on short notice.255 In states where N11

 250   See, e.g., Sprint Reply Comments at 7; USTA Comments at 19-20, 31.

 251   See, e.g., Rochester Comments at 4; Mobile Comments at 4; Mtel Comments at 7;

 252  See The Need to Promote Competition and Efficient Use of Spectrum for Radio Common Carrier
  Services, Memorandum Opinion and Order, 59 Rad. Reg. (P&F)1275,1284 (1986). We note that
  Bellcore, as current administrator of the NANP, also has characterized numbers as a public resource
  and has specifically rejected that the assignment of a number implies ownership by either the assignor or
  assignee. See Personal Communications Services N00 NXX Code Assignment Guidelines, Para. 2.10
  (April 8, 1995 Revision).

 253 See, e.g., NANP Order at para. 4 (stating that telephone numbers are a public resource); The Need to
  Promote Competition and Efficient Use of Spectrum for Radio Common Carrier Services, Declaratory
  Ruling, 2 FCC Rcd 2910, 2912 (1987), recon., 4 FCC Rcd 2369 (1989) (stating that NXX codes are a
  national resource).

 254   See Network Notes "Numbering Plan and Dialing Procedures."

 255   Id.




                                                   41
codes have been used locally, state public utilities commissions have directed the LECs
to assign and administer these codes. The specific procedures for assignment of N11
codes for local use vary from state to state. Three local N11 codes have been assigned
for particular uses in at least some LEC service areas (411 for local directory
assistance; 611 for LEC repair service; and 811 for LEC business office use).

       74.    As part of our analysis of the Commission's role with respect to numbering
administration, we seek comments below on issues related to administration of N11
codes. The Commission had already embarked on an extensive analysis of its role with
respect to numbering prior to enactment of the 1996 Act amendments to the 1934 Act.
The Commission, in adopting a new model for administration of the NANP in the NANP
Order, decided not only that the NANP administrator's existing functions will be
transferred to a neutral entity to be recommended by the NANC, but also that "the
functions associated with CO code administration shall be transferred from the LECs to
the new NANP administrator no more than 18 months after the transfer of the existing
NANP administrative functions from Bellcore to the new administrator has been
completed."256

       75.    We propose that the administration of N11 codes for local use, to the
extent that this administration was done by the incumbent LECs prior to enactment of
the 1996 Act amendments to the 1934 Act, and would otherwise continue under the
terms of this First Report and Order and the Commission's Local Competition Second
Report and Order, should instead be transferred from the incumbent LECs to the neutral
NANP administrator to be recommended by the NANC. We propose that the transfer
occur with the transfer of the functions associated with CO Code administration. 257 We
seek comment on our proposal.

         E.       Procedural Matters

                  1.      Ex Parte Presentations

       76.    This is a non-restricted notice-and-comment rulemaking proceeding. Ex
parte presentations are permitted, except during the Sunshine Agenda period, provided
that they are disclosed as provided in the Commission's rules. See generally 47 C.F.R.
§§ 1.1202, 1.1203, 1.1206. Written submissions, however, will be limited as discussed
below.258


 256   NANP Order at para. 115.

 257  The Commission did not intend to limit the functions to be transferred to the new entity to those
  specifically listed in the NANP Order. The Commission stated there that it seeks recommendations from
  the NANC on several issues, one of which is "[w]hat number resources, beyond those currently
  administered by Bellcore, as the NANP administrator, should the new NANP administrator administer?"
  Id. at para. 118.

 258   See paras. 78-80, infra.




                                                 42
              2.      Regulatory Flexibility Act

       77.    See Appendix F, infra for the Initial Regulatory Flexibility Analysis.

       F.     Comment Filing Procedures

       78.    General Requirements. Pursuant to applicable procedures set forth in
sections 1.415 and 1.419 of the Commission's rules, 47 C.F.R. §§ 1.415, 1.419,
interested parties may file comments on or before March 31, 1997, and reply comments
on or before April 30, 1997. To file formally in this proceeding, you must file an original
and twelve copies of all comments, reply comments, and supporting comments. If you
want each Commissioner to receive a personal copy of your comments, you must file an
original and 16 copies. Comments and reply comments should be sent to Office of the
Secretary, Federal Communications Commission, 1919 M Street, N.W., Room 222,
Washington, D.C. 20554, with a copy to Janice Myles of the Common Carrier Bureau,
1919 M Street, N.W., Room 544, Washington, D.C. 20554. Parties should also file one
copy of any documents filed in this docket with the Commission's copy contractor,
International Transcription Services, Inc., 2100 M Street, N.W., Suite 140, Washington,
D.C. 20037. Comments and reply comments will be available for public inspection
during regular business hours in the FCC Reference Center, 1919 M Street, N.W.,
Room 239, Washington, D.C. 20554.

       79.     Other requirements. In order to facilitate review of comments and reply
comments, both by parties and by Commission staff, we require that comments be no
longer than seventy-five (75) pages and reply comments be no longer than thirty-five
(35) pages, including exhibits, appendices, and affidavits of expert witnesses. Empirical
economic studies and copies of relevant state orders will not be counted against these
page limits. These page limits will not be waived and will be strictly enforced.
Comments and reply comments must include a short and concise summary of the
substantive arguments raised in the pleading. Comments and reply comments must
also comply with Section 1.49 and all other applicable sections of the Commissions
rules.259 We also direct all interested parties to include the name of the filing party and
the date of the filing on each page of their comments and reply comments. Comments
and reply comments also must clearly identify the specific portion of this Notice of
Proposed Rulemaking to which a particular comment or set of comments is responsive.
If a portion of a party's comments does not fall under a particular topic listed in the
outline of this Notice, such comments must be included in a clearly labelled section at
the beginning or end of the filing. Parties may not file more than a total of ten (10)
pages of ex parte submissions, excluding cover letters. This 10 page limit does not
include: (1) written ex parte filings made solely to disclose an oral ex parte contact; (2)

 259 See 47 C.F.R. § 1.49. We require, however, that a summary be included with all comments and reply
  comments, although a summary that does not exceed three pages will not count towards the 75 page
  limit for comments or the 35 page limit for reply comments. The summary may be paginated separately
  from the rest of the pleading (e.g., as "i, ii"). See 47 C.F.R. § 1.49.




                                                43
written material submitted at the time of an oral presentation to Commission staff that
provides a brief outline of the presentation; or (3) written material filed in response to
direct requests from Commission staff. Ex parte filings in excess of this limit will not be
considered as part of the record in this proceeding.

       80.     Parties are also asked to submit comments and reply comments on
diskette. Such diskette submissions would be in addition to and not a substitute for the
formal filing requirements addressed above. Parties submitting diskettes should submit
them to Gloria Shambley of the Common Carrier Bureau, Network Services Division,
2000 M Street, N.W., Room 235, Washington, D.C. 20554. Such a submission should
be on a 3.5 inch diskette formatted in an IBM compatible form using MS DOS 5.0 and
WordPerfect 5.1 software. The diskette should be submitted in "read only" mode. The
diskette should be clearly labelled with the party's name, proceeding, type of pleading
(comment or reply comments) and date of submission. The diskette should be
accompanied by a cover letter.

                               V. ORDERING CLAUSES

      81.     Accordingly, IT IS ORDERED, pursuant to Sections 1, 4(i), 201-205 and
251(e)(1) of the Communications Act of 1934, as amended, 47 U.S.C. §§ 151, 154(i),
201-205, and 251(e)(1), that the First Report and Order is hereby ADOPTED.

       82.   IT IS FURTHER ORDERED, that Bellcore, as the NANP administrator,
shall assign 711 as a national code for TRS use as of the effective date of this First
Report and Order, as discussed in this First Report and Order.

       83.    IT IS FURTHER ORDERED, that Bellcore, as the NANP administrator,
shall assign 311 as a national code for access to non-emergency police and other
government services as of the effective date of this First Report and Order, as
discussed in this First Report and Order.

        84.    IT IS FURTHER ORDERED, that when a provider of telecommunications
services receives a request from an entity to use 311 for access to non-emergency
police and other government services in a particular jurisdiction, it must ensure that,
within six months of the request: (1) entities that were assigned 311 at the local level
prior to the effective date of this First Report and Order relinquish non-compliant uses;
and (2) it takes any steps necessary (for example reprogramming switch software) to
complete 311 calls from its subscribers to a requesting 311 entity in its service area.

       85.     IT IS FURTHER ORDERED, that (1) all providers of telephone exchange
service, both incumbents and new market entrants, whether facilities or non facilities-
based providers of telephone exchange service, should be enabled to use the 611 and
811 codes for repair services and business office uses as the incumbent LECs do now;
and (2) by dialing these N11 numbers, customers should be able to reach their own
carriers' repair or business services.




                                            44
        86.   IT IS FURTHER ORDERED, that a LEC may not itself offer enhanced
services using a 411 code, or any other N11 code, unless that LEC offers access to the
code on a reasonable, nondiscriminatory basis to competing enhanced service
providers in the local service area for which it is using the code to facilitate distribution
of their enhanced services.

       87.    IT IS FURTHER ORDERED, that the North American Numbering Council
will explore how rapidly abbreviated dialing arrangements could be deployed and report
back to the Commission on this issue.

      88.   IT IS FURTHER ORDERED that GSA's request for a national N11
assignment is DENIED and that NASTD's request for a national assignment is
GRANTED IN PART as discussed in this First Report and Order, and otherwise
DENIED.

       89.    IT IS FURTHER ORDERED, pursuant to Sections 1, 4(i) and (j), 201-205,
218 and 251(e)(1) of the Communications Act as amended, 47 U.S.C. Sections 151,
154(i), 151(j), 201-205, 218 and 251(e)(1), that the Further Notice of Proposed
Rulemaking is hereby ADOPTED.


                     FEDERAL COMMUNICATIONS COMMISSION



                                          William F. Caton

                                          Acting Secretary




                                             45
                                Appendix A
                         Comments Filed on N11 NPRM
                             CC Docket 92-105


Comments

1.    Ad Hoc Telecommunications Users Committee (Ad Hoc)
2.    Alternate Weekly Newspapers, New Times, Inc., Sasquatch
      Publishing, City Pages, and Tuscon Weekly (Alternative Newspapers)
3.    American Public Communications Council (APCC)
4.    American Telephone and Telegraph Company (AT&T)
5.    Ameritech Operating Companies (Ameritech)
6.    Anchorage Telephone Utility (ATU)
7.    Bell Atlantic Telephone Companies (Bell Atlantic)
8.    Bell Communications Research, Inc. (Bellcore)
9.    BellSouth Telecommunications, Inc. (BellSouth)
10.   BT North America (BONA)
11.   Canadian Steering Committee on Numbering (CSCN)
12.   Central Telephone Company (Centel)
13.   Cox Enterprises, Inc. (Cox)
14.   Datatrex
15.   Florida Public Service Commission (FPSC)
16.   GTE Service Corporation (GTE)
17.   Infocom International, Incorporated (Infocom)
18.   Information Technology Association of America (ITAA)
19.   Information Industry Association (IIA)
20.   LO/AD Communications (LO/AD)
21.   MCI Telecommunications Corporation (MCI)
22.   Metropolitan Fiber Systems, Inc. (MFS)
23.   Mobile Connections, Inc. (Mobile)
24.   Mobile Telecommunications Technologies Corporation (Mtel)
25.   National Telephone Cooperative Association (NTCA)
26.   Newspaper Association of America (NAA)
27.   NYNEX Telephone Companies (NYNEX)
28.   Pacific Bell and Nevada Bell (Pacific)
29.   Puerto Rico Telephone Company (PRTC)
30.   Rochester Telephone Corporation (Rochester)
31.   Southern New England Telephone (SNET)
32.   Southwestern Bell Telephone Company (SWBT)
33.   Sprint Corporation (Sprint)
34.   Telesector Resources Group (Telesector)
35.   United States Telephone Association (USTA)
36.   U S WEST Communications, Inc. (U S WEST)

Reply Comments




                                       46
1.    Advance Publications, Inc. (Advance)
2.    AT&T
3.    Ameritech
4.    Bell Atlantic
5.    Bellcore
6.    BellSouth
7.    BONA
8.    Cox
9.    Datatrex
10.   First Financial Management Corporation (FFMC)
11.   FPSC
12.   GTE
13.   Illinois Commerce Commission,          Indiana Utility Regulatory Commission,
Michigan Public Service Commission, Public Utilities Commission of Ohio, Public
Service Commission of Wisconsin (Ameritech Regional Regulatory Committee, or
ARRC)
14.   Information Industry Association (IIA)
15.   LO/AD
16.   MCI
17.   Mtel
18.   National Center for Law and Deafness (NCLD)
19.   New York State Department of Public Service (NYPDS)
20.   Newsday
21.   NYNEX
22.   Organization for the Protection and Advancement
      of Small Telephone Companies (OPASTCO)
23.   Pacific
24.   PBS/The Print Group
25.   Sprint
26.   SWBT
27.   United Cerebral Palsy Association, Inc. (UCPA)
28.   USTA
29.   U S WEST




                                        47
                                Appendix B
                        Comments Filed on TRS Petition

Comments

1.    Access Independence and Mobility
2.    Ad Hoc
3.    ALDA California Style
4.    ALDA Sacramento
5.    Alexander Graham Bell Association for the Deaf, Inc.
      American Council of the Blind
6.    American Society for Deaf Children
7.    American Speech-Language Hearing Association
8.    Ameritech
9.    Anderson, Herker
10.   AT&T
11.   Baltimore's Empowered Advocates for the
      Right's of Deaf and Hard of Hearing People
12.   Bell Atlantic
13.   BellSouth
14.   Bourne-Firl, Bridgetts
15.   Center for Media Education
16.   Chicago Hearing Society
17.   Commonwealth of Massachusetts
18.   Cox and Dallas Morning News
19.   Deafness Education Advocacy Foundation
20.   Eakes, Dorothy
21.   Eakes, Malcolm
22.   Fitts, Beth
23.   Gallaudet University Regional Center- Ohlone College
24.   Gallaudet University Regional Center- Kapiolani Community College
25.   General Communications, Inc.
26.   GTE
27.   Hamilton Telephone Co.
28.   Hawaii State Coordinating Council on Deafness
29.   Helen Keller National Center
30.   Illinois Commerce Commission, Indiana Utility Regulatory Commission,
      Public Utilities Commission of Ohio, Public Service Commission of
      Wisconsin
31.   Illinois, Attorney General
32.   Illinois Alliance for the Hearing Impaired
33.   Jacksonville Community Center for the Deaf
34.   Jacob, Philip
35.   Joint Commission Indiana Utility Reg. Comm.,
      Illinois Commerce Commission, PUC of Ohio and the PSC of Wisconsin
36.   Jones, Samuel




                                      48
37.     Lake County Center for Independent Living
38.     Leigh, Irene
39.     Life After Deafness Magazine- Gayle McCullough
40.     Life After Deafness
41.     LING Inc.
42.     Mame Telecommunications Relay Service Advisory Committee
43.     McBroom, Betty
44.     MCI
45.     Minnesota Telecommunications Access for Communication-Impaired Persons
Board
46.     Missouri Commission for the Deaf
47.     National Technical Institute for the Deaf
48.     National Association of the Deaf
49.     New York Society for the Deaf
50.     North Carolina; Division of Services for the Deaf and Hard of Hearing
51.     North Country Club of the Deaf
52.     Northern Virginia Resource Center for Deaf and Heard of Hearing Persons
53.     NYNEX
54.     Oregon Public Utility Commission
55.     Oregon Association of the Deaf, Inc.
56.     Pacific
57.     People Mutual Telephone Company, Inc.
58.     Public Utility Commission of Texas
59.     Relay Texas Advisory Committee
60.     Riker, David
61.     Rochester Institute of Technology
62.     Schaumberg Township Disabled Services
63.     Self Help for Hard of Hearing People
64.     South Carolina Telecommunications Relay Service Advisory Committee
65.     South Carolina Budget and Control Board
66.     SWBT
67.     Springfield Center for Independent Living
68.     Sprint Corporation for Sprint Communications Co. LP
        & The 69. United and Centel Telephone Companies
70.     Still, G. Howard
71.     Telecommunications for the Deaf, Inc.
72.     Telecommunications Relay Services Advisory Council
73.     Texas Attorney General
74.     Texas, Public Utility Commission
75.     Triangle Association of the Deaf
76.     USTA
77.     United States Department of Agriculture
78.     USDA- Southwestern Region
79.     U S WEST Communications, Inc.
80.     Virginia Department for the Deaf and Heard of Hearing (VDDHH)
81.     Walker, Kristina Leitch




                                          49
82.   Washington Post Company
83.   Wisconsin, Department of Health and Social Services
84.   WisTRS

Reply Comments

1.    Alexander Graham Bell Association for the Deaf
2.    Association of Late Deafened Adults
3.    Bell Atlantic
4.    BellSouth
5.    Chicago Hearing Society
6.    Florida PSC
7.    General Communication, Inc.
8.    GTE
9.    Illinois Alliance for the Hearing Impaired
10.   Joint Parties (Cox and Dallas Morning Times)
11.   Minnesota
12.   National Association of the Deaf
13.   National Center for Law and Deafness
14.   National Fraternal Society of the Deaf
15.   Nevada Bell
16.   Newspaper Association of America
17.   Pacific Bell
18.   Pacific Telesis
19.   Saks, Andrea
20.   Self Help For Hard of Hearing People, Inc.
21.   SWBT
22.   Sprint Corporation, on Behalf of:
      Sprint Communications Company LP
      United & Central Telephone Companies
23.   Telecommunications for the Deaf, Inc.
24.   USTA
25.   Washington Post




                                        50
                                 Appendix C
                         Comments Filed on GSA Petition
Comments

1.    Acadian Ambulance Service, Inc.
2.    Ad Hoc
3.    American Public Telecommunications Council
4.    Ameritech
5.    Bell Atlantic
6.    BellSouth
7.    Caddo Parish Communications District No. One
8.    Citizen Tribune
9.    City of Dallas
10.   Claiborne Parish Communications District
11.   Consumer Product Safety Commission
12.   Cox, Advance, Gannett, Washington Post
13.   Daily Republic
14.   Department of Agriculture
15.   Department of Health and Human Services
16.   The Department of Justice
17.   Department of Transportation
18.   Department of Veterans Affairs
19.   Environmental Protection Agency
20.   Federal Labor Relations Authority
21.   Florida PSC
22.   Goldsboro News-Argus
23.   GTE
24.   Idaho Public Utilities Commission
25.   Information Industry Association
26.   Iowa Utilities Board
27.   Jackson Parish 9-1-1 Communication District
28.   Louisiana Public Service Commission
29.   MCI
30.   Mulvany, Dana
31.   National Aeronautics and Space Administration
32.   National Association of Regulatory Utility Commissioners
33.   National Association of State Telecommunications Directors
34.   National Center for Law and Deafness, Nat'l Association of the Deaf,
      Self Help for Hard of Hearing People, and
      Telecommunications for the Deaf, Inc.
35.   National Newspaper Association
36.   Newspaper Association of America
37.   Office of Personnel Management
38.   Overseas Private Investment Corporation
39.   Relay Administration Board
40.   Southwestern Bell Corporation




                                         51
41.   Sprint
42.   St. Charles Parish Communications District
43.   St. Landry Parish Communications District
44.   Stein, Paul
45.   Tennessee Valley Authority
46.   Texas Advisory Commission on State Emergency Communication
47.   West Carroll Parish Communication District
48.   Wilson Daily Times

Reply Comments

1.    Acadian Ambulance Service, Inc.
2.    Ad Hoc
3.    American Public Telecommunications Council
4.    Bell Atlantic
5.    BellSouth
6.    Caddo Parish Communications District No. One
7.    Cox, Advance, Gannett, Washington Post Co.
8.    Francis Dummer Fisher
9.    General Services Administration
10.   MCI
11.   National Emergency Number Association (NENA)
12.   National Newspaper Association
13.   Southwestern Bell Corporation
14.   Texas Department of Information




                                     52
                                Appendix D
               Comments Filed on Department of Justice Request

1.     311 Direct, Inc.
2.     Ameritech
3.     AT&T
4.     Cincinnati Bell Telephone Company (CBT)
5.     The County of Los Angeles
6.     The Los Angeles Police Department
7.     The Texas Department of Information resources (Texas DIR)
8.     SBC Communications, Inc. (SBC)
9.     U S WEST
10.    Warren W. Owens
11.    The Riverside County Sheriff's Department
12.    The City of Austin
13.    The Attorney General for the State of California
14.    Dallas Police Department
15.    Dallas Fire Chief
16.    The Fort Worth Fire Chief
17.    The Fire Chief of the City of Pittsburgh, Department of Public Safety
18.    The Fire Chief of the Seattle Fire Department
19.    The Commissioner of the Philadelphia Fire Department
20.    The Fire Commissioner/Chief of the Boston Fire Department
21.    The City of Garland Texas
22.    Janice F. Hill
23.    The City of Houston
24.    The Maryland Chiefs of Police Association
25.    The Maryland Public Service Commission (MDPSC)
26.    The National Association of Police Organizations, Inc. (ANPO)
27.    The National Sheriff's Association
28.    The San Jose, California Police Department
29.    The San Bernadino, California Police Department
30.    The City of University Park, Texas
31.    The National Fraternal Order of Police
32.    The National Troopers Coalition
33.    Daniel Ginty
34.    The California Highway Patrol (CHP)
35.    The City of Sacramento, California Police Department (Sacramento)
36.    GTE
37.    BellSouth
38.    The Office of Information Resources of the Budget and Control Board of the
State of 39. South Carolina (South Carolina OIR)
40.    Acadian Ambulance and AIR MED Services of Louisiana (Acadian)
41.    The Ohio Department of Transportation (Ohio DOT)
42.    The Commonwealth of Kentucky Transportation Cabinet (Kentucky DOT)




                                       53
43. The Association of Public-Safety Communications Officials-International, Inc.
    (APCO)
44. The Arizona APCO Chapter
45. Bismark Emergency Management & Combined Communications (Bismark)
46. Cox Enterprises, Inc.
47. The City of Fresno, California Chief of Police (Fresno Police Chief)
48. The Greater Harris County 9-1-1 Emergency Network
49. The City of Mesa, Arizona, Police Department Communications (Mesa)
50. Morris Communications Corporation (Morris)
51. The State of New York Department of Public Service (NYSDPS)
52. NYNEX
53. Florence Cainoce, Staff Manager for NYNEX Consumer Affairs
54. The Southern Idaho Regional Communications Center
55. The Texas Advisory Commission on State Emergency Communications (TX-
ACSEC)
56. The National Emergency Number Association (NENA) and the National
            Association of State Nine One Administrators (NASNA) (National
    911 Commenters)
57. Francis Dummer Fisher
58. Dr. Bill Munn, PhD, First Vice President of NENA
59. The Louisiana Public Service Commission
60. The National Association of the Deaf (NAD)
61. Bell Atlantic
62. Fairfax County Fire and Rescue Department, Fire Chief
63. County of Los Angeles Fire Department, Fire Chief
64. City of Miami Fire Chief
65. International Association of Fire Chiefs, Inc., and
    International Municipal Signal Association 311
66. King County E-911 Program Manager (Seattle, Washington)
67. Cellular Telecommunications Industry Association
68. City of Phoenix Fire Department.
69. City and County of Denver Department of Safety, Chief of Police
70. Kootenai County, Idaho 911 Director
71. Charlotte-Mecklenburg, North Carolina Chief of Police




                                       54
                 APPENDIX E: FINAL REGULATORY FLEXIBILITY ANALYSIS

        1.     As required by the Regulatory Flexibility Act (RFA), 5 U.S.C. § 601 et.
seq., the Commission considered regulatory flexibility issues in the Notice of Proposed
Rulemaking (NPRM) in this proceeding, and certified that there was no significant
economic impact on a substantial number of small entities.260 The Commission sought
written public comments on the proposals in the NPRM. Although there were no
comments filed in response to the certification, on our own motion we have
reconsidered our certification in the NPRM and decided to undertake a Final Regulatory
Flexibility Analysis (FRFA) in conformity with the RFA, as amended by the SBREFA.

         A.       Need for and Objectives of this First Report and Order

        2.    "Abbreviated dialing arrangements" are telephone numbers of less than
the standard 7 or 10 digits. Among abbreviated dialing arrangements, "N11 codes" are
3-digit telephone numbers of which the first digit may be any digit other than 0 or 1, and
the last two digits are both 1, e.g., 911. This First Report and Order directs Bell
Communications Research (Bellcore) to assign 711 as a national number for access to
telecommunications relay services for the deaf (TRS) and 311 as a national number for
access to non-emergency police services; concludes that, as the incumbent LECs can
do currently, all providers of telephone exchange service must be able to have their
customers call 611 and 811 to reach their repair and business service offices and that a
LEC may not itself offer enhanced services using a 411 code, or any other N11 code,
unless that LEC offers access to the code on a reasonable, nondiscriminatory basis to
competing enhanced service providers.

       B.     Analysis      of   Significant   Issues    Raised     in   Response      to   the
Certification

       3.    As stated above, no comments were submitted in response to the
Commission's certification in the NPRM that the rules it proposed to adopt in this
proceeding would not have a significant economic impact on a substantial number of
small business entities.261 Nonetheless, we have reconsidered our certification in the
NPRM and have decided to undertake an FRFA. We do so because the requirements
governing agency treatment of regulatory flexibility issues have become more stringent
while this docket has been open, and because even though a review of the general
comments for issues that might impact small businesses revealed that most comments



 260  See NPRM at para. 21 We note that the certification was issued prior to enactment of the
  amendments to the RFA in the Small Business Regulatory Enforcement Fairness Act of 1996
  ("SBREFA"), which was enacted as Title II of the Contract With America Advancement Act of 1996
  (CWAAA), 5 U.S.C. § 605(b), Pub. L. No. 104-121, 110 Stat. 847 (1996).

 261   See id.




                                               55
did not specifically address possible impacts on small entities,262 we realize that a
substantial number of small entities may be affected by this First Report and Order. In
reaching our determinations in this First Report and Order, we have considered all
arguments raised by parties.

         C.      Description and Estimates of the Number of Small
                 Entities Affected by this First Report and Order

       4.     The RFA defines "small entity" to include the definition of "small business
concern" under the Small Business Act, 15 U.S.C. § 632.263 Under the Small Business
Act, a "small business concern" is one that: (1) is independently owned and operated;
(2) is not dominant in its field of operation; and (3) meets any additional criteria
established by the Small Business Administration (SBA).264 The SBA has defined
companies listed under Standard Industrial Classification (SIC) categories 4812
(radiotelephone communications) and 4813 (telephone communications, except
radiotelephone) to be small entities when they have 1500 or fewer employees. 265
These standards also apply in determining whether an entity is a small business for
purposes of the RFA.

       5.      Because the small incumbent LECs that would be subject to these rules
are either dominant in their field of operations or are not independently owned and
operated, consistent with our prior practice, they are excluded from the definition of
"small entity" and "small business concerns."266 Accordingly, our use of the terms
"small entities" and "small businesses" does not encompass small incumbent LECs. 267

 262  We note that the Organization for the Promotion and Advancement of Small Telecommunications
  Companies (OPASTCO) (formerly known as the Organization for the Protection and Advancement of
  Small Telephone Companies), which represents more than 440 independently owned and operated
  telephone companies serving rural areas, opposes mandatory assignment of N11 codes because they
  could disrupt current use of an N11 code in some geographic areas (See OPASTCO Reply Comments
  at 2-3, expressing concern about 611 and 811) and also argues that customer confusion could ensue if
  services using N11 codes vary from area to area (See id. at 4).

 263 See 5 U.S.C. § 601(6) (incorporating by reference the definition of "small business concern" in 15
  U.S.C. § 632).

 264   See 15 U.S.C. § 632(1)(a).

 265 See 13 C.F.R. § 121.201, Standard Industrial Classification (SIC) Codes 4812 and 4813 (SIC 4812
  and SIC 4813, respectively).

 266  See Implementation of the Local Competition Provisions in the Telecommunications Act of 1996,
  First Report and Order, 11 FCC Rcd 15499 (1996) (First Interconnection Order), motion for stay of the
  FCC's rules pending judicial review denied, Implementation of the Local Competition Provisions in the
  Telecommunications Act of 1996, Order, 11 FCC Rcd 11754 (1996), partial stay granted, Iowa Utilities
  Board v. FCC, No. 96-3321, 1996 WL 589204 (8th Cir. Oct. 15, 1996) (Iowa Utilities Board v. FCC) at
  paras. 1328-1330 and 1342.

 267   See id. at para. 1342.




                                                 56
Out of an abundance of caution, however, for regulatory flexibility analysis purposes, we
will consider small incumbent LECs within this analysis and use the term "small
incumbent LECs" to refer to any incumbent LECs that arguably might be defined by
SBA as "small business concerns."

     6.      The decisions made by the Commission in this First Report and Order
may apply to a variety of entities listed below.

       7.     Local Exchange Carriers.        Neither the Commission nor SBA has
developed a definition of small entity specifically applicable to providers of local
exchange services. The closest applicable definition is that under SBA rules for
telephone communications, except radiotelephone, SIC 4813, which defines a small
entity as one with 1500 or fewer employees. The most reliable source of information
regarding the number of LECs nationwide of which we are aware appears to be the data
that we collect annually in connection with the Telecommunications Relay Service
(TRS). According to our most recent data, 1,347 companies reported that they were
engaged in the provision of local exchange service. 268 Although it seems certain that
some of these carriers are not independently owned and operated, or have more than
1500 employees, we are unable at this time to estimate with any more certainty the
number of LECs that would qualify as small business concerns. Consequently, we
estimate that there are fewer than 1,347 small incumbent LECs that may be affected by
the decision and rules adopted in this First Report and Order.

        8.     Interexchange Carriers. Neither the Commission nor SBA has developed
a definition of small entity specifically applicable to providers of interexchange services
(IXCs). The closest applicable definition is that under SBA rules for telephone
communications, except radiotelephone, SIC 4813. The most reliable source of
information regarding the number of IXCs nationwide of which we are aware appears to
be the data that we collect annually in connection with TRS. According to our most
recent data, 130 companies reported that they were engaged in the provision of
interexchange services, and 30 companies reported they were engaged in "other" toll
services. 269     Although it seems certain that some of these carriers are not
independently owned and operated, or have more than 1500 employees, we are unable
at this time to estimate with greater precision the number of IXCs that would qualify as
small business concerns under SBA's definition. Consequently, we estimate that there
are fewer than 130 small entity IXCs and 30 "other" toll carriers that may be affected by
the decision and rules adopted in this First Report and Order.


 268 Federal Communications Commission, CCB, Industry Analysis Division, Telecommunications Industry
  Revenue: TRS Fund Worksheet Data, Tbl. 1 (Average Total Telecommunications Revenue Reported by
  Class of Carrier) (Dec. 1996) (TRS Worksheet).

 269 Id. Firms filing TRS Worksheets are asked to select a single category that best describes their
  operation. As a result, some carriers describes themselves as IXCs, some as resellers, some as OSPs,
  and some as "other."




                                                57
        9.     Wireless Service Providers. Neither the Commission nor SBA has
developed a definition of small entity specifically applicable to providers of wireless
services. The closest applicable definition is that under SBA rules for radiotelephone
communications, SIC 4812, which defines a small entity as one with 1500 or fewer
employees. The 1992 Census of Transportation, Communications, and Utilities,
conducted by the Bureau of the Census, shows that only 12 radiotelephone firms out of
a total of 1,176 such firms that operated during 1992 had 1,000 or more employees. 270
Therefore, even if all 12 of these large firms were radiotelephone companies, all of the
remainder were small businesses under the SBA's definition. We assume that, for
purposes of our evaluations and conclusions in the FRFA, all of the current
radiotelephone licensees are small entities, as that term is defined by the SBA.
        10.    Cellular and Mobile Radio Telephone Service.         In an effort to further
refine our calculation of the number of radiotelephone companies affected by the rules
adopted herein, we consider the categories of radiotelephone carriers, Cellular Service
Carriers and Mobile Service Carriers. Neither the Commission nor the SBA has
developed a definition of small entities specifically applicable to Cellular Service
Carriers and to Mobile Service Carriers. The closest applicable definition under SBA
rules for both services is for telephone companies other than radiotelephone (wireless)
companies. The most reliable source of information regarding the number of Cellular
Service Carriers and Mobile Service Carriers nationwide of which we are aware appears
to be the data that we collect annually in connection with the TRS. According to our
most recent data, 792 companies reported that they are engaged in the provision of
cellular services and 138 companies reported that they are engaged in the provision of
mobile services.271 Although it seems certain that some of these carriers are not
independently owned and operated, or have more than 1,500 employees, we are
unable at this time to estimate with greater precision the number of Cellular Service
Carriers and Mobile Service Carriers that would qualify as small business concerns
under SBA's definition. Consequently, we estimate that there are fewer than 792 small
entity Cellular Service Carriers and fewer than 138 small entity Mobile Service Carriers
that might be affected by the actions and rules adopted in this First Report and Order.
We assume that all of the current rural cellular and mobile licensees are small
businesses.

       11.     Personal Communications Service. The broadband PCS spectrum is
divided into six frequency blocks designated A through F and the Commission has held
auctions for each block. The Commission defined "small entity'' for Blocks C and F as
an entity that has average gross revenues of less than $40 million in the three previous




 270 U.S. Bureau of the Census, U.S. Department of Commerce, 1992 Census of Transportation,
  Communications, and Utilities, UC92-S-1, Subject Series, Establishment and Firm Size, Table 5,
  Employment Size of Firms: 1992, SIC 4812 (issued May 1995).

 271   See TRS Worksheet.




                                              58
calendar years.272 For Block F, an additional classification for "very small business"
was added and is defined as an entity that, together with their affiliates, has average
gross revenues of not more than $15 million for the preceding three calendar years. 273
These regulations defining "small entity'' in the context of broadband PCS auctions have
been approved by the SBA. No small businesses within the SBA-approved definition
bid successfully for licenses in Blocks A and B. There were 90 winning bidders that
qualified as small entities in the Block C auctions. A total of 93 small and very small
business bidders won approximately 40% of the 1,479 licenses for Blocks D, E, and
F.274 However, licenses for blocks C through F have not been awarded fully, therefore
there are few, if any, small businesses currently providing PCS services. Based on this
information, we conclude that the number of small broadband PCS licensees will
include the 90 winning C Block bidders and the 93 qualifying bidders in the D, E, and F
blocks, for a total of 183 small PCS providers as defined by the SBA 275 and the
Commission's auction rules.

         12.    Paging and Radiotelephone Service, and Private Land Mobile Radio
Services, Paging Operations. Neither the Commission nor SBA has developed a
definition of small entity specifically applicable to providers paging services. The closest
applicable definition is that under SBA rules for radiotelephone communications, SIC
4812, which defines a small entity as one with 1500 or fewer employees. The
Commission anticipates that a total of 15,531 non-nationwide geographic area licenses
will be granted or auctioned. The geographic area licenses will consist of 3,050 MTA
licenses and 12,481 EA licenses. In addition to the 47 Rand McNally MTAs, the
Commission is licensing Alaska as a separate MTA and adding three MTAs for the U.S.
territories, for a total of 51 MTAs. No auctions of paging licenses have been held yet,
and there is no basis to determine the number of licenses that will be awarded to small
entities. Because nearly all radiotelephone companies have fewer than 1,000
employees, and no reliable estimate of the number of prospective paging licensees can
be made, we assume, for purposes of this FRFA, that all the 15,531 geographic area
paging licenses will be awarded to small entities, as that term is defined by the SBA.
We estimate that the approximately 600 current paging carriers could partition or
disaggregate a license or take the opportunity to obtain an additional license through
partitioning or disaggregation. We estimate that up to 48,393 licensees or potential
licensees could take the opportunity to partition or disaggregate a license or obtain a
license through partitioning or disaggregation. This estimate is based on the total

 272 See Amendment of Parts 20 and 24 of the Commission's Rules -- Broadband PCS Competitive
  Bidding and the Commercial Mobile Radio Service Spectrum Cap, Report and Order, FCC 96-278, WT
  Docket No. 96-253, paras. 57- 60 (rel. June 24, 1996); See also 47 C.F.R. § 24.720(b) .

 273 See Amendment of Parts 20 and 24 of the Commission's Rules -- Broadband PCS Competitive
  Bidding and the Commercial Mobile Radio Service Spectrum Cap, Report and Order, FCC 96-278, WT
  Docket No. 96-253, para. 60 (1996).

 274   FCC News, Broadband PCS, D, E and F Block Auction Closes, Mimeo No. 71744 (rel. Jan. 14, 1997).

 275   See para. 9, supra.




                                                  59
estimate of paging carriers (approximately 600) and non-nationwide geographic area
licenses to be awarded (15,531) and our estimate that each license will probably not be
partitioned or disaggregated among more than three parties. Because nearly all
radiotelephone companies have fewer than 1,000 employees, and no reliable estimate
of the number of future paging licensees can be made, we assume for purposes of this
FRFA that all of the licensees will be awarded to small businesses. We believe that it is
possible that a significant number of the estimated 48,393 licensees or potential
licensees who could take the opportunity to partition or disaggregate a license or who
could obtain a license through partitioning or disaggregation will be a small business.

        13.    Competitive Access Providers. Neither the Commission nor SBA has
developed a definition of small entity specifically applicable to providers of competitive
access services (CAPs). The closest applicable definition is that under SBA rules for
telephone communications, except radiotelephone, SIC 4813, which defines a small
entity as one with 1500 or fewer employees. The most reliable source of information
regarding the number of CAPs nationwide of which we are aware appears to be the
data that we collect annually in connection with TRS. According to our most recent data
57 companies reported that they were engaged in the provision of competitive access
services.276 Although it seems certain that some of these carriers are not independently
owned and operated, or have more than 1500 employees, we are unable at this time to
estimate with greater precision the number of CAPS that would qualify as small
business concerns under SBA's definition. Consequently, we estimate that there are
fewer than 57 small entity CAPS that may be affected by the decision and rules adopted
in this First Report and Order.

       14.    Operator Service Providers. Neither the Commission nor SBA has
developed a definition of small entity specifically applicable to providers of operator
services. The closest applicable definition is that under SBA rules for telephone
communications, except radiotelephone, SIC 4813. The most reliable source of
information regarding the number of operator service providers nationwide of which we
are aware appears to be the data that we collect annually in connection with TRS.
According to our most recent data 25 companies reported that they were engaged in the
provision of operator services.277 Although it seems certain that some of these carriers
are not independently owned and operated, or have more than 1500 employees, we are
unable at this time to estimate with greater precision the number of operator service
providers that would qualify as small business concerns under SBA's definition.
Consequently, we estimate that there are fewer than 25 small entity operator service
providers that may be affected by the decision and rules adopted in this First Report
and Order.

      15.  Pay Telephone Operators. Neither the Commission nor SBA has
developed a definition of small entity specifically applicable to providers of pay

 276   See TRS Worksheet.

 277   Id.




                                           60
telephone operator services. The closest applicable definition is that under SBA rules
for telephone communications, except radiotelephone, SIC 4813. The most reliable
source of information regarding the number of pay telephone operators nationwide of
which we are aware appears to be the data that we collect annually in connection with
TRS. According to our most recent data, 271 companies reported that they were
engaged in the provision of pay telephone services. 278 Although it seems certain that
some of these carriers are not independently owned and operated, or have more than
1500 employees, we are unable at this time to estimate with greater precision the
number of pay telephone operators that would qualify as small business concerns under
SBA's definition. Consequently, we estimate that there are fewer than 271 pay
telephone operators that may be affected by the decision and rules adopted in this First
Report and Order.

        16.    Resellers. Neither the Commission nor the SBA has developed a
definition of small entity specifically applicable to resellers. The closest applicable
definition is that under SBA rules for all telephone communications companies, SIC
4812 and SIC 4813, combined, both of which define a small entity as one with 1500 or
fewer employees. The most reliable source of information regarding the number of
resellers nationwide of which we are aware appears to be the data that we collect
annually in connection with TRS. According to our most recent data, 260 companies
reported that they were engaged in the resale of telephone services.279 Although it
seems certain that some of these carriers are not independently owned and operated,
or have more than 1500 employees, we are unable at this time to estimate with greater
precision the number of resellers that would qualify as small business concerns under
SBA's definition. Consequently, we estimate that there are fewer than 260 small entity
resellers that may be affected by the decision and rules adopted in this First Report and
Order.

      17.     Telecommunications Equipment Manufacturers.       The SBA classifies
manufacturers of telecommunications equipment in two categories, one for wireless and
another for wireline.

       18.    Wireline Telecommunications Equipment Manufacturers. Neither the
Commission nor the SBA has developed a specific definition of small entities applicable
to manufacturers of wireline telecommunications equipment. Therefore, we will utilize
the SBA definition of manufacturers of Telephone and Telegraph Apparatus. According
to the SBA's regulations, a small entity must have 1000 or fewer employees in order to
qualify as a small business concern.280 Census Bureau data indicates that there are
479 U.S. firms that manufacture telephone and telegraph equipment, and that 436 of
these firms have fewer than 1000 employees and would be classified as small

 278   Id.

 279   Id.

 280   13 C.F.R. § 121.201, SIC 3661.




                                           61
entities.281 The Census Bureau category is very broad, and specific figures are not
available as to how many of these firms are manufacturers of wireline
telecommunications equipment that would be subject to these rules or how many are
independently owned and operated. Consequently, we estimate that there are fewer
than 436 small manufacturers of wireline telecommunications equipment.

        19.   Wireless Telecommunications Equipment Manufacturers. Neither the
Commission nor the SBA has developed a specific definition of small entities applicable
to manufacturers of wireless telecommunications equipment. Therefore, we will utilize
the SBA definition of manufacturers of Radio and Television Broadcasting and
Communications Equipment.282 According to the SBA's regulations, a small entity must
have 750 or fewer employees in order to qualify as a small business concern. 283
Census Bureau data indicates that there are 858 U.S. firms that manufacture radio and
television broadcasting and communications equipment, and that 778 of these firms
have fewer than 750 employees and would be classified as small entities. 284 The
Census Bureau category is very broad, and specific figures are not available as to how
many of these firms are manufacturers of wireless telecommunications equipment or
how many are independently owned and operated. Consequently, we estimate that
there are fewer than 778 small manufacturers of wireless telecommunications
equipment.

        20.   Fire and Burglar Equipment Manufacturers. The Commission has not
developed a definition of small entities applicable to manufacturers of fire and burglar
alarm equipment. We will utilize the SBA classification of such manufacturers under
Communications Equipment Not Elsewhere Classified. This definition provides that a
small entity is an alarm equipment manufacturer employing 750 or less persons. 285
Census Bureau data indicates that there are 498 U.S. firms that manufacture alarm
equipment, and that 469 of these firms have fewer than 750 employees and would be
classified as small entities.286 The Census Bureau category is very broad, and includes
manufacturers of other equipment such as traffic signalling and intercommunications
equipment. Specific figures are not available as to how many of these firms produce

 281  U.S. Dept. of Commerce, 1992 Census of Transportation, Communications and Utilities, Table 1D,
  (issued May 1995), SIC 3661.

 282 This category excludes establishments primarily engaged in the manufacturing of household audio
  and visual equipment which is categorized as SIC 3651.

 283   13 C.F.R. § 121.201, SIC 3663.

 284  U.S. Dept. of Commerce, 1992 Census of Transportation, Communications and Utilities, Table 1D,
  (issued May 1995), SIC 3663.

 285   13 C.F.R. § 121.201, SIC 3669.

 286  U.S. Dept. of Commerce, 1992 Census of Transportation, Communications and Utilities, Table 1D,
  (issued May 1995), SIC 3669.




                                                62
alarm equipment or how many are independently owned and operated. Consequently,
we estimate that there are fewer than 469 small manufacturers of alarm equipment that
may be affected by the decision and rules adopted in this First Report and Order.

       21.    Alarm Service Providers. The SBA has developed a definition of alarm
service providers (SIC 7382) which are entities that are primarily engaged in the
monitoring and maintenance of security systems devices, such as burglar and fire
alarms.287 According to the SBA, a small security system provider must have $9 million
or less in annual receipts.288 Census Bureau data reports that there were 2,190 security
system service providers with $7.499 million or less in annual receipts and 2,200 with
less than $9.999 million in annual receipts.289 Therefore, we tentatively conclude that
there are approximately 2,190 small security system service providers that may be
affected by the decision and rules adopted in this First Report and Order.

        D.      Description of Projected Reporting, Recordkeeping
                and Other Compliance Requirements of the Rules

       22.     The First Report and Order requires Bell Communications Research, as
the NANP administrator, to assign, as of the effective date of this First Report and
Order, to assign 311 as a national code for access to non-emergency police and other
government services and to assign 711 as a national code for TRS use. The First
Report and Order also requires that when a provider of telecommunications services
receives a request from an entity (for example a local police chief or local fire chief) to
use 311 for access to non-emergency police and other government services in a
particular jurisdiction, it must ensure that, within six months of the request: (1) entities
that were assigned 311 at the local level prior to the effective date of this First Report
and Order relinquish non-compliant uses; and (2) it takes any steps necessary (for
example reprogramming switch software) to complete 311 calls from its subscribers to a
requesting 311 entity in its service area. We recognize that some of these requirements
may require the use of professional engineering skills.

        E.      Significant Alternatives Minimizing Impact on Small
                Entities and Consistent with Stated Objectives

       23.  The Commission considers and implements alternatives in this First
Report and Order that seek to benefit competing providers of telephone exchange
service and telephone toll service which may include small business entities. As

 287Standard Industrial Classification Manual, (SIC) 7382, Executive Office of the President, Office of
  Management and Budget (1987).

 288   13 C.F.R. § 121.201, SIC 7382.

 289 1992 Economic Census Industry and Enterprise Receipts Size Report, Table 2D, SIC 7382 (U.S.
  Bureau of the Census data under contract to the Office of Advocacy of the U.S. Small Business
  Administration).




                                                 63
alternatives to the determination to require Bellcore to assign 311 as a national number
for access to non-emergency police services and 711 for national TRS access, we
considered, for example, the possibility of using other numbering resources such as 800
numbers. See First Report and Order at paras. 40 and 55. The Commission's
determination to allow local governments to determine whether they need to avail
themselves of the 311 non-emergency option should serve to lessen possible
implementation burdens (cost, time, etc.) on smaller telecommunications carriers in
particular. This determination avoids not only unnecessary investments for providers
of telecommunications services but also unnecessary relinquishment of the customers'
(some of which may be small) uses of 311 assignments made at the local level prior to
the effective date of the First Report and Order. Furthermore, allowing six months from
a request for 311 service in a local jurisdiction to prepare for 311 non-emergency
service should lessen implementation burdens that may have been more costly if
implementation were required during a shorter period. This six-month period should
prove beneficial also to customers that were assigned 311 at the local level prior to the
effective date of the First Report and Order. See First Report and Order at paras. 35-
43.

             F.     Report to Congress

      24.     The Commission shall send a copy of this Final Regulatory Flexibility
Analysis, along with this First Report and Order, in a report to Congress pursuant to the
Small Business Regulatory Enforcement Fairness Act of 1996, 5 U.S.C. § 801(a)(1)(A).
A copy of this FRFA will also be published in the Federal Register.




                                           64
APPENDIX F: INITIAL REGULATORY FLEXIBILITY ANALYSIS




                        65
       1.     As required by the Regulatory Flexibility Act (RFA), 5 U.S.C. § 601 et seq.,
the Commission is incorporating an Initial Regulatory Flexibility Analysis (IRFA) of the
expected impact on small entities of the policies and proposals in this Further Notice of
Proposed Rulemaking (FNPRM).290 Written public comments concerning the effect of
the proposals in the FNPRM, including the IRFA, on small businesses are requested.
Comments must be identified as responses to the IRFA and must be filed by the
deadlines for the submission of comments in this proceeding. The Secretary shall send
a copy of this FNPRM, including the IRFA, to the Chief Counsel for Advocacy of the
Small Business Administration in accordance with paragraph 603(a) of the RFA,
amended by the SBREFA.

        A.       Reasons Why the Actions Are Being Considered and
                 Need for and Objectives of this FNPRM

        2.     The FNPRM is initiated to obtain comment on the technical feasibility of
implementing 711 for TRS access. The FNPRM also asks parties: (1) if it would be
possible to develop within a reasonable time an N11 "gateway" offering access to
multiple TRS providers; (2) whether, with such gateway access, TRS calls would still be
answered within our mandatory minimum standards for TRS answer times; (3) whether
such a gateway would be consistent with Section 255 of the Telecommunications Act of
1934 (Act), as amended by the Telecommunications Act of 1996;291 and (4) whether
any other important disability services could be accessed through the same gateway.
Regarding TRS, the FNPRM also requests comment from interested parties, particularly
TRS providers, about the possibility of providing both voice and text TRS services
through the same abbreviated N11 code. Finally, the FNPRM asks for comment on the
proprietary nature of N11 codes and on our proposal to transfer the administration of
N11 codes at the local level from the incumbent LECs to the NANP administrator. The
objective of this FNPRM is to develop a record that addresses issues related to the
efficient use of scarce numbering resources and adheres to the imperative, concomitant
with the need for one uniform numbering plan, that any numbering plan be capable of
serving all telecommunications carriers, both incumbents and new market entrants.

        B.       Legal Basis

       3.      Authority for actions proposed in this FNPRM may be found in: Sections 1,
4(i) and (j), 201-205, 218 and 251(e)(1) of the Communications Act as amended, 47
U.S.C. Sections 151, 154(i), 151(j), 201-205, 218 and 251(e)(1).

        C.       Reporting, Recordkeeping and Other Compliance Requirements




 290Pub. L. No. 96-354, 94 Stat. 1164, 5 U.S.C. § 601 et. seq. (1981), as amended. Amendments to the
  RFA were enacted in the Small Business Regulatory Enforcement Fairness Act of 1996 ("SBREFA"),
  which was enacted as Title II of the Contract With America Advancement Act of 1996 (CWAAA), Pub. L.
  No. 104-121, 110 Stat. 847 (1996).

 291   Telecommunications Act of 1996, Pub. L. No. 104-104, 110 Stat. 56 (1996).
      4.          No new recording, recordkeeping or other compliance requirements are
proposed.

         D.       Federal Rules that Duplicate, Overlap, or Conflict With Proposed
Rules

         5.       None.

         E.       Description and Estimate of the Number of Small
                  Entities To Which the Proposed Rules Would Apply

       6.     For entities to which the proposals in this FNPRM may apply, as well as
for the definition of small entity and discussion of small independent LECs, See
Appendix E, supra, Final Regulatory Flexibility Analysis, Heading C (Description and
Estimates of the Number of Small Entities Affected by this First Report and Order)
(paras. 4-21). In addition, as described below, the proposed rules would apply to TRS
providers.

        7.     TRS Providers. Neither the Commission nor SBA has developed a
definition of small entity specifically applicable to providers of telecommunications relay
services (TRS). The closest applicable definition is that under SBA rules for telephone
communications, except radiotelephone, SIC 4813. According to our most recent data,
there are 12 interstate TRS providers, which consist of interexchange carriers, 292 local
exchange carriers,293 state entities, and non-profit organizations. Although it seems
certain that some of these TRS providers are not independently owned and operated, or
have more than 1500 employees, we are unable at this time to estimate with greater
precision the number of TRS providers that would qualify as small business concerns
under SBA's definition. Consequently, we estimate that there are fewer than 12 small
entity TRS providers that may be affected by the proposals in this FNPRM.

         F.       Significant Alternatives Minimizing Impact on Small
                  Entities and Consistent with Stated Objectives

       8.     The proposals in the FNPRM, and the comments the Commission seeks
regarding them, are part of the Commission's analysis of its role with respect to
numbering administration. The guiding principal shaping these proposals is that a
uniform numbering plan is an essential prerequisite to an integrated public switched
telephone network. There must be a single, consistent set of numbering principles
allowing all switching equipment connected to the network to route every call to its
correct destination. Concomitant with the need for one uniform numbering plan is the
imperative that any numbering plan be capable not only of serving incumbents, but also
of accommodating new market entrants. For this reason, we have attempted, wherever
possible, to ensure that new telecommunications carriers have access to numbering
resources on the same basis as incumbents. These competing providers of telephone

 292   See Appendix E, supra, Final Regulatory Flexibility Analysis at para. 8.

 293   See id. at para. 7.




                                                       2
exchange service and telephone toll service may include small business entities. To
gather information from all interested parties about alternative timeframes for nationwide
implementation of 711 for TRS access, in addition to seeking comment on our tentative
conclusion that this implementation should occur within three years of the effective date
of the First Report and Order, we ask, among other things, that parties addressing
implementation issues present a timeline for completion of steps they foresee as
necessary to introduce 711. See First Report and Order at para. 68. We tentatively
conclude that our proposals in the FNPRM would impose minimum burdens on small
entities. We seek comment on this tentative conclusion.




                                            3
ATTACHMENT 3
311 INITIAL
SURVEY


                      DATE  POPULATION    INITIAL     ANNUAL            ANNUAL      MANAGED "211"         TYPE SVC.
    CITY      STATE STARTED   SERVED      COSTS       COSTS STAFF        CALLS         BY    Y/N       CITY/NON-EMER

Detroit       MI     1997   1,000,000    $2,000       NA         61    780,000   Police Dept.    Y   City Service Calls
San Jose      CA     1997   1,300,000    $175,000     $100,000   6     262,870   Police Dept.    N   Non-Emergency
Baltimore     MD     1997   670,000      $60,000      $20,000    8     600,000   Police Dept.    N   Non-Emergency
Las Vegas     NV     2000   2,000,000    *            NA         17    1,000,000 Police Dept.    N   Non-Emergency
Chicago       IL     1998   3,000,000    $3,997,949   $788,141   12    10,000,000Police Dept.    N   City Service Calls
Columbia      SC     2002   117,000      $300,000     $400,000   5     26,000    311 Call Ctr.   Y   City Service Calls
Hampton       VA     1999   146,000      $300,000     $427,000   9     237,000   DPW.            N   City Service Calls
Rochester     NY     1998   200,000      $999,672     $443,992   12    750,000   Police Dept.    N   Non-Emergency
Austin        TX     2001   552,434      $350,000     $6,600     27    2,700,000 Police Dept.    N   Non-Emergency
Houston       TX     2001   1,500,000    $2,333       $5,399     77    16,000,000Mayor's         N   City Service Calls
                                                                                 Office
Washington    D.C.   2000   1,500,000    $5,900,000 $1,300       173   1,000,000 Police Dept.    N   Non-Emergency
San Antonio   TX     2002   1,400,000                            29    600,000   Customer        N   City Service Calls
                                                                                 Services
ATTACHMENT 4
PSAP NAME          Wireless      Wireline      Wireless      Wireline      Wireless Wireline       Wireless        Wireline         Wireless       Wireline       Wireless       Wireline    Wireless      Wireline
Call Volume 2002   Jan           Jan           Feb           Feb           March      March        April           April            May            May            June           June        July          July
Ansonia PD                  84           442            64           376         78          398              67              396             81            398             98         445            80            4
Avon PD                     87           205            58           234         43          354              16              445             20            488             16         588             7            5
Berlin PD                   85           317            90           279         97          340              74              408             89            448             69         442            81            4
Bethel PD                   62           283            32           267         45          347              39              330             37            353             40         374            25            3
Bloomfield PD              118           675            91           639         75          807              60              912             72          1,067             75       1,117            53           10
Branford PD                108           648           140           586        163          647             139              700            148            865            181         835           187            9
Bridgeport FD              252         8,106           260         7,244        245        8,060             325            8,540            354          9,331            368      10,175           393          107
Bristol PD                 173         1,224           129         1,077         61        1,654              23            2,060             34          2,157              5       2,395             7           31
Brookfield PD               84           261            64           235         69          312              42              511             59            656             90         663            83           23
Canton PD                   23            96            33            94          8          208               6              190              2            192              7         235             2            2
Cheshire PD                 90           466            77           376         93          485              43              614             60            701             50         727            49            7
Clinton ECC                 37           196            23           168         43          166              33              186             50            200             59         193            72            2
Colchester EC              860           707           820           557        938          622             948              597          1,213            717          1,137         701          1141            7
Cromwell PD                 73           237            68           214         59          302              78              277             75            246            106         286            89            2
Danbury FD                 512         1,938           386         1,673        503        1,977             455            2,152            512          2,358            548       2,270           546           25
Darien PD                   71           406            66           400         84          414              85              456            112            451            109         524            70            4
Deep River ECC               7           226             6           171          6          173              11              199             12            247             10         212            16            2
Derby PD                    87           281            92           293        131          312              95              267            108            389            127         354           112            3
East Hartford PD           188         1,282           174         1,261        206        1,516             214            1,497            218          1,600            249       1,688           284           18
East Haven FD              140           682           120           639        132          710             114              847            128            743            146         803           152            8
East Lyme ECC               12         1,547             9         1,404          6        1,699               8            1,789             18          2,024             11       2,242            17           22
East Windsor PD             55           231            49           214         35          269              58              321             59            356             44         369            64            3
Easton PD                   30           116            19            97         20          112              16              116             23            120             17         117            18            1
Enfield PD                 128           678           135           600        117          783             148              881            125            837            190         920           177            9
Fairfield ECC              239         1,206           218         1,196        223        1,259             227            1,302            317          1,432            307       1,348           297           12
Farmington PD              141           401           120           357         76          527              42              798             46            896             54         844            57           10
Glastonbury PD              78           371            59           335         76          471              70              562             95            536             98         505           112            5
Granby PD                   41           196            26           178         14          542               3              349              9            475              4         449             5            4
Greenwich PD               272         1,710           192         1,511        274        1,692             241            1,890            354          1,880            343       2,211           312           20
Groton ECC                 176         1,010           160           856        174        1,074             191            1,133            212          1,220            195       1,337           209           13
Guilford ECC                37           435            22           352         36          399              18              382             37            419             32         438            30            4
Hamden ECC                 306         1,427           272         1,205        296        1,341             268            1,556            272          1,657            274       1,586           265           17
Hartford PD              1,805         9,137         1,676         8,779      1,710       10,549           1,944           11,019          2,106         13,190          1,940      12,382          2098          129
Ledyard ECC                  6           257             1           216          4        1,357               4            1,212              3            436              1         518             1            5
Litchfield LCD           2,163           842         1,909           733      1,720          781           1,335              883          1,662            870          1,347         944          1418           11
Madison PD                  49           271            38           247         46          277              37              245             65            280             80         307           110            3
Manchester PD              306         1,210           274         1,080        289        1,278             296            1,347            357          1,380            370       1,489           362           15
Meriden PD                 277         1,352           252         1,200        285        1,428             283            1,578            323          1,683            392       1,837           369           18
Middlebury PD               22           110            37           108         30          118              34              154             42            158             39         193            47            1
Middletown FD              502         6,284           392         4,695        290        1,356             328            1,421            397          1,455            427       1,389           385           14
Milford FD                263   1,116      248         992      225   1,136      258   1,144      311   1,281      291   1,301     320   13
Monroe PD                  81     277       58         230       74     340       27     482       29     520       36     583      18    6
Montville ECC               6   1,105       11         967        8   1,096        3   1,196        5   1,407       11   1,227       8   13
Naugatuck PD              117     559       71         473       99     528      111     530      115     555      120     568     113    6
New Britain ERC           402   2,501      349       2,283      357   2,677      350   2,849      378   3,145      359   3,214     388   32
New Canaan PD              80     346       61         295       50     305       45     334       56     348       47     364      59    4
New Fairfield PD           10     149        6         154        6     211        2     193        8     220        3     224       4    2
New Haven ECC           1,300   6,269    1,218       5,552    1,359   6,626    1,429   7,168    1,551   7,820    1,632   7,970    1647   87
New London PD             195   1,104      207         972      220   2,495      250   3,537      192   3,643      216   3,638     259   40
New Milford PD             97     350       60         320       53     437       34     497       53     559       67     624      46    5
Newington PD              185     678      169         637      130     725       90   1,053      103   1,178      111   1,056     108   11
Newtown PD                121     405       86         337      108     415       83     406      102     514      120     439      94    5
North Branford PD          50     181       50         138       41     199       45     209       47     236       38     291      48    2
North Haven PD            155     507      148         443      159     458      137     493      161     496      141     575     175    6
Northwest CT PS         4,084     627    3,701         508    4,291     599    4,342     617    4,498     666    5,218     709    5094    7
Norwalk PD                522   2,548      438       2,299      538   2,383      518   2,525      663   2,656      680   2,640     605   28
Norwich PD                251   1,072      158       1,040      237   1,042      200   1,251      224   1,332      253   1,296     235   15
Old Saybrook PD            43     230       33         160       30     203       38     196       54     188       64     218      73    2
Orange PD                 137     270      122         209      156     309      108     325      159     342      145     369     148    3
Plainville PD              74     422       66         366       50     492       51     483       41     603       46     612      57    5
Plymouth EC                33     176       25         200       10     283        8     278        6     270        7     397       9    3
Putnam PD                  20     190       10         198       22     166       16     230       18     220       23     257      15    2
Quinebaug ECC           1,041   1,586      925       1,293    1,031   1,469    1,072   1,409    1,363   1,505    1,291   1,648    1349   17
Redding PD                 49      98       33          98       24     145        7     175        8     192        7     187      12    2
Ridgefield PD             119     490       88         408       81     547       36     643       40     691       42     713      44    7
Rocky Hill PD              66     333       51         314       45     376       55     460       75     467       78     513      68    5
Seymour PD                 25     246       18         215       37     235       22     238       24     264       45     258      25    2
Shelton PD                167     806      106         667      161     722      123     800      172     855      147     931     149    9
Simsbury PD                95     307       66         280       35     353        9     366       14     405        8     464       9    5
South Windsor              52     340       60         309       41     346       40     404       53     485       36     436      48    4
Southbury PD               36     331       36         284       25     321       38     280       42     339       36     350      53    3
South Cent Reg ECC         21     508       13         392       26     444       20     484       25     501       27     497      23    5
Southington PD            143     689      122         622      134     729      123     762      155     880      135     823     145    8
Stamford PD               833   4,713      667       4,383      769   4,735      826   4,634      942   4,999    1,093   5,118    1024   49
State Police Trp "A"    5,154     128    4,452         134    5,013     152    4,710     220    5,486     263    5,626     274    5481    2
State Police Trp "B"      248     176      209         117      259     144      222     136      222     145      269     164     314    2
State Police Trp "C"      441     257      341         241      456     306      477     293      417     318      498     403     507    3
State Police Trp "D"      227     280      169         240      221     277      204     320      260     290      273     337     286    3
State Police Trp "E"    5,387     449    4,596         369    5,066     438    4,567     549    5,210     616    5,331     653    5871    8
State Police Trp "F"      367     135      289          95      381     130      348     121      375     109      526     148     551    1
State Police Trp "G"   27,147     204   23,595         167   27,937     247   29,096     357   32,266     402   34,090     550   32145    8
State police Trp "H"   22,358     197   20,041         230   20,917     499   20,143     684   20,984     733   21,062     569   21830    5




                                                 2
State Police Trp "I"        8,665        129      8,075        142     8,330         211            8,024            341        9,272          413     9,019       414      8981      5
State Police Trp "W"            8        526          5        540         0         504                3            479            1          472         2       491         3      5
Stonington PD                  48        313         42        273        46         348               45            430           55          547        63       589        74      6
Stratford PD                  256      1,238        219      1,144       227       1,242              262          1,386          297        1,579       315     1,526       318     15
Suffield PD                     3        169                   156         0         210                1            217            0          198         2       223         0      2
Thomaston PD                   19         93          9         70        16          96                4            112           17           92        18       115        11
Tolland County MAD          2,090      1,188      1,827      1,160     2,159       1,318            2,184          1,434        2,412        1,593     2,462     1,431      2430      15
Torrington PD                 124        788         87        679       141         720              115            708          151          782       145       852       175       8
Trumbull PD                   144        726         84        661       131         636               91            758           97          949        94       836        95       8
Valley Shore EC             3,898        677      3,448        542     3,765         599            4,001            620        5,158          754     5,742       793      6062       9
Vernon PD                     111        509        115        438       115         546              151            554          170          550       160       593       178       6
Wallingford FD                234        640        166        605       148         747              143            862          160          956       182       985       180       9
Waterbury PD                1,061      4,316        840      3,799       989       3,972            1,086          3,998        1,218        4,352     1,464     4,788      1356      51
Waterford ECC                  92        407         91        367        88         489               70            609           74          677       105       692        97       7
Watertown PD                   57        308         80        304        65         315               53            422           62          403        46       398        61       4
West Hartford PD              329      1,269        292        991       196       1,345              196          1,646          194        1,683       229     1,747       239      19
West Haven ERS                244      1,852        248      1,712       284       1,909              323          1,999          362        2,211       390     2,361       331      22
Weston ECC                     40        236         25        169        28         162               21            253           28          273        30       286        16       2
Westport PD                   126        632        124        556       147         642              160            589          237          712       232       724       218       6
Wethersfield PD               100        539        108        456        86         593               69            693          101          687       100       694       103       7
Willimantic FD                 21      1,667         11      1,503        26       1,591               22          1,616           18        1,801        31     1,694        37      18
Wilton PD                     118        329        112        264        82         351               50            456           50          509        59       553        41       5
Windsor Locks PD               34        249         23        205        20         256               14            253           29          314        38       310        22       3
Windsor PD                     92        492                   722        87         542               81            654          100          688       111       705       107       7
Winsted PD                     26        183         41        177        27         203               36            191           47          221        32       222        53       2
Wolcott PD                     37        214         36        182        41         187               27            204           43          181        37       171        46       2
Woodbridge PD                  42        148         42        116        50         178               48            161           47          180        47       153        47       1
                       100,007    100,661    87,975     89,710     96,976    102,768     95,981             111,498      107,213      121,346        111,058   124,406   110,540   133,4




PSAP NAME              Wireless     Wireless Wireless     Wireless     Wireless Wireless        6 month




Call Volume 2002       Jan          Feb        Mar        April        May        June          TOTAL
Ansonia PD                     84         64         78           67         81            98        472




                                                             3
Avon PD              87      58      43          16      20      16     240
Berlin PD            85      90      97          74      89      69     504
Bethel PD            62      32      45          39      37      40     255
Bloomfield PD       118      91      75          60      72      75     491
Branford PD         108     140     163         139     148     181     879
Bridgeport FD       252     260     245         325     354     368    1,804
Bridgeport PD      1,313   1,127   1,494       1,462   1,722   1,770   8,888
Bristol PD          173     129      61          23      34       5     425
Brookfield PD        84      64      69          42      59      90     408
Canton PD            23      33       8           6       2       7      79
Cheshire PD          90      77      93          43      60      50     413
Clinton ECC          37      23      43          33      50      59     245
Colchester EC       860     820     938         948    1,213   1,137   5,916
Cromwell PD          73      68      59          78      75     106     459
Danbury FD          512     386     503         455     512     548    2,916
Danbury PD          304     226     249         226     238     265    1,508
Darien PD            71      66      84          85     112     109     527
Deep River ECC        7       6       6          11      12      10      52
Derby PD             87      92     131          95     108     127     640
East Hartford PD    188     174     206         214     218     249    1,249
East Haven FD       140     120     132         114     128     146     780
East Lyme ECC        12       9       6           8      18      11      64
East Windsor PD      55      49      35          58      59      44     300
Easton PD            30      19      20          16      23      17     125
Enfield PD          128     135     117         148     125     190     843
Fairfield ECC       239     218     223         227     317     307    1,531
Farmington PD       141     120      76          42      46      54     479
Glastonbury PD       78      59      76          70      95      98     476
Granby PD            41      26      14           3       9       4      97
Greenwich PD        272     192     274         241     354     343    1,676
Groton ECC          176     160     174         191     212     195    1,108
Guilford ECC         37      22      36          18      37      32     182
Hamden ECC          306     272     296         268     272     274    1,688




                                           4
Hartford PD         1,805   1,676   1,710       1,944   2,106   1,940   11,181
Ledyard ECC            6       1       4           4       3       1       19
Litchfield LCD      2,163   1,909   1,720       1,335   1,662   1,347   10,136
Madison PD            49      38      46          37      65      80      315
Manchester PD        306     274     289         296     357     370     1,892
Meriden PD           277     252     285         283     323     392     1,812
Middlebury PD         22      37      30          34      42      39      204
Middletown FD        502     392     290         328     397     427     2,336
Milford FD           263     248     225         258     311     291     1,596
Monroe PD             81      58      74          27      29      36      305
Montville ECC          6      11       8           3       5      11       44
Naugatuck PD         117      71      99         111     115     120      633
New Britain ERC      402     349     357         350     378     359     2,195
New Canaan PD         80      61      50          45      56      47      339
New Fairfield PD      10       6       6           2       8       3       35
New Haven ECC       1,300   1,218   1,359       1,429   1,551   1,632    8,489
New London PD        195     207     220         250     192     216     1,280
New Milford PD        97      60      53          34      53      67      364
Newington PD         185     169     130          90     103     111      788
Newtown PD           121      86     108          83     102     120      620
North Branford PD     50      50      41          45      47      38      271
North Haven PD       155     148     159         137     161     141      901
Northwest CT PS     4,084   3,701   4,291       4,342   4,498   5,218   26,134
Norwalk PD           522     438     538         518     663     680     3,359
Norwich PD           251     158     237         200     224     253     1,323
Old Saybrook PD       43      33      30          38      54      64      262
Orange PD            137     122     156         108     159     145      827
Plainville PD         74      66      50          51      41      46      328
Plymouth EC           33      25      10           8       6       7       89
Putnam PD             20      10      22          16      18      23      109
Quinebaug ECC       1,041    925    1,031       1,072   1,363   1,291    6,723
Redding PD            49      33      24           7       8       7      128
Ridgefield PD        119      88      81          36      40      42      406




                                            5
Rocky Hill PD             66       51       45          55       75       78       370
Seymour PD                25       18       37          22       24       45       171
Shelton PD               167      106      161         123      172      147       876
Simsbury PD               95       66       35           9       14        8       227
South Windsor             52       60       41          40       53       36       282
Southbury PD              36       36       25          38       42       36       213
South Cent Reg ECC        21       13       26          20       25       27       132
Southington PD           143      122      134         123      155      135       812
Stamford PD              833      667      769         826      942     1,093     5,130
State Police Trp "A"    5,154    4,452    5,013       4,710    5,486    5,626    30,441
State Police Trp "B"     248      209      259         222      222      269      1,429
State Police Trp "C"     441      341      456         477      417      498      2,630
State Police Trp "D"     227      169      221         204      260      273      1,354
State Police Trp "E"    5,387    4,596    5,066       4,567    5,210    5,331    30,157
State Police Trp "F"     367      289      381         348      375      526      2,286
State Police Trp "G"   27,147   23,595   27,937   29,096      32,266   34,090   174,131
State police Trp "H"   22,358   20,041   20,917   20,143      20,984   21,062   125,505
State Police Trp "I"    8,665    8,075    8,330       8,024    9,272    9,019    51,385
State Police Trp "K"     295      253      294         257      323      385      1,807
State Police Trp "L"     244      258      313         266      341      304      1,726
State Police Trp "W"       8        5        0           3        1        2        19
Stonington PD             48       42       46          45       55       63       299
Stratford PD             256      219      227         262      297      315      1,576
Suffield PD                3                 0           1        0        2         6
Thomaston PD              19        9       16           4       17       18        83
Tolland County MAD      2,090    1,827    2,159       2,184    2,412    2,462    13,134
Torrington PD            124       87      141         115      151      145       763
Trumbull PD              144       84      131          91       97       94       641
UCONN PD                   5       17       19          29       12       11        93
Valley Shore EC         3,898    3,448    3,765       4,001    5,158    5,742    26,012
Vernon PD                111      115      115         151      170      160       822
Wallingford FD           234      166      148         143      160      182      1,033
Waterbury PD            1,061     840      989        1,086    1,218    1,464     6,658




                                                  6
Waterford ECC                 92            91               88              70           74             105         520
Watertown PD                  57            80               65              53           62               46        363
West Hartford PD          329               292            196             196           194             229        1,436
West Haven ERS            244               248            284             323           362             390        1,851
Weston ECC                    40            25               28              21           28               30        172
Westport FD                   1               7              7               5            18               9            47
Westport PD               126               124            147             160           237             232        1,026
Wethersfield PD           100               108              86              69          101             100         564
Willimantic FD                21            11               26              22           18               31        129
Wilton PD                 118               112              82              50           50               59        471
Windsor Locks PD              34            23               20              14           29               38        158
Windsor PD                    92                             87              81          100             111         471
Winsted PD                    26            41               27              36           47               32        209
Wolcott PD                    37            36               41              27           43               37        221
Woodbridge PD                 42            42               50              48           47               47        276
                   102,169         89,863         99,352          98,226          109,867          113,802        613,279




PSAP NAME          Wireline        Wireline       Wireline        Wireline        Wireline      Wireline        6 month
Call Volume 2002   Jan             Feb            March           April           May           June            TOTAL
Ansonia PD                442               376            398             396           398             445        2,455
Avon PD                   205               234            354             445           488             588        2,314
Berlin PD                 317               279            340             408           448             442        2,234
Bethel PD                 283               267            347             330           353             374        1,954
Bloomfield PD             675               639            807             912          1,067           1,117       5,217
Branford PD               648               586            647             700           865             835        4,281
Bridgeport FD            8,106           7,244         8,060              8,540         9,331          10,175      51,456
Bridgeport PD            2,334           1,935         2,021              2,094         2,524           2,385      13,293




                                                                     7
Bristol PD         1,224   1,077    1,654       2,060    2,157    2,395   10,567
Brookfield PD       261     235      312         511      656      663     2,638
Canton PD            96      94      208         190      192      235     1,015
Cheshire PD         466     376      485         614      701      727     3,369
Clinton ECC         196     168      166         186      200      193     1,109
Colchester EC       707     557      622         597      717      701     3,901
Cromwell PD         237     214      302         277      246      286     1,562
Danbury FD         1,938   1,673    1,977       2,152    2,358    2,270   12,368
Danbury PD          495     406      595         598      672      707     3,473
Darien PD           406     400      414         456      451      524     2,651
Deep River ECC      226     171      173         199      247      212     1,228
Derby PD            281     293      312         267      389      354     1,896
East Hartford PD   1,282   1,261    1,516       1,497    1,600    1,688    8,844
East Haven FD       682     639      710         847      743      803     4,424
East Lyme ECC      1,547   1,404    1,699       1,789    2,024    2,242   10,705
East Windsor PD     231     214      269         321      356      369     1,760
Easton PD           116      97      112         116      120      117      678
Enfield PD          678     600      783         881      837      920     4,699
Fairfield ECC      1,206   1,196    1,259       1,302    1,432    1,348    7,743
Farmington PD       401     357      527         798      896      844     3,823
Glastonbury PD      371     335      471         562      536      505     2,780
Granby PD           196     178      542         349      475      449     2,189
Greenwich PD       1,710   1,511    1,692       1,890    1,880    2,211   10,894
Groton ECC         1,010    856     1,074       1,133    1,220    1,337    6,630
Guilford ECC        435     352      399         382      419      438     2,425
Hamden ECC         1,427   1,205    1,341       1,556    1,657    1,586    8,772
Hartford PD        9,137   8,779   10,549   11,019      13,190   12,382   65,056
Ledyard ECC         257     216     1,357       1,212     436      518     3,996
Litchfield LCD      842     733      781         883      870      944     5,053
Madison PD          271     247      277         245      280      307     1,627
Manchester PD      1,210   1,080    1,278       1,347    1,380    1,489    7,784
Meriden PD         1,352   1,200    1,428       1,578    1,683    1,837    9,078
Middlebury PD       110     108      118         154      158      193      841




                                            8
Middletown FD        6,284   4,695   1,356       1,421   1,455   1,389   16,600
Milford FD           1,116    992    1,136       1,144   1,281   1,301    6,970
Monroe PD             277     230     340         482     520     583     2,432
Montville ECC        1,105    967    1,096       1,196   1,407   1,227    6,998
Naugatuck PD          559     473     528         530     555     568     3,213
New Britain ERC      2,501   2,283   2,677       2,849   3,145   3,214   16,669
New Canaan PD         346     295     305         334     348     364     1,992
New Fairfield PD      149     154     211         193     220     224     1,151
New Haven ECC        6,269   5,552   6,626       7,168   7,820   7,970   41,405
New London PD        1,104    972    2,495       3,537   3,643   3,638   15,389
New Milford PD        350     320     437         497     559     624     2,787
Newington PD          678     637     725        1,053   1,178   1,056    5,327
Newtown PD            405     337     415         406     514     439     2,516
North Branford PD     181     138     199         209     236     291     1,254
North Haven PD        507     443     458         493     496     575     2,972
Northwest CT PS       627     508     599         617     666     709     3,726
Norwalk PD           2,548   2,299   2,383       2,525   2,656   2,640   15,051
Norwich PD           1,072   1,040   1,042       1,251   1,332   1,296    7,033
Old Saybrook PD       230     160     203         196     188     218     1,195
Orange PD             270     209     309         325     342     369     1,824
Plainville PD         422     366     492         483     603     612     2,978
Plymouth EC           176     200     283         278     270     397     1,604
Putnam PD             190     198     166         230     220     257     1,261
Quinebaug ECC        1,586   1,293   1,469       1,409   1,505   1,648    8,910
Redding PD             98      98     145         175     192     187      895
Ridgefield PD         490     408     547         643     691     713     3,492
Rocky Hill PD         333     314     376         460     467     513     2,463
Seymour PD            246     215     235         238     264     258     1,456
Shelton PD            806     667     722         800     855     931     4,781
Simsbury PD           307     280     353         366     405     464     2,175
South Windsor         340     309     346         404     485     436     2,320
Southbury PD          331     284     321         280     339     350     1,905
South Cent Reg ECC    508     392     444         484     501     497     2,826




                                             9
Southington PD          689     622     729         762    880     823     4,505
Stamford PD            4,713   4,383   4,735    4,634     4,999   5,118   28,582
State Police Trp "A"    128     134     152         220    263     274     1,171
State Police Trp "B"    176     117     144         136    145     164      882
State Police Trp "C"    257     241     306         293    318     403     1,818
State Police Trp "D"    280     240     277         320    290     337     1,744
State Police Trp "E"    449     369     438         549    616     653     3,074
State Police Trp "F"    135      95     130         121    109     148      738
State Police Trp "G"    204     167     247         357    402     550     1,927
State police Trp "H"    197     230     499         684    733     569     2,912
State Police Trp "I"    129     142     211         341    413     414     1,650
State Police Trp "K"    254     216     269         312    326     317     1,694
State Police Trp "L"    279     215     213         264    312     315     1,598
State Police Trp "W"    526     540     504         479    472     491     3,012
Stonington PD           313     273     348         430    547     589     2,500
Stratford PD           1,238   1,144   1,242    1,386     1,579   1,526    8,115
Suffield PD             169     156     210         217    198     223     1,173
Thomaston PD             93      70      96         112     92     115      578
Tolland County MAD     1,188   1,160   1,318    1,434     1,593   1,431    8,124
Torrington PD           788     679     720         708    782     852     4,529
Trumbull PD             726     661     636         758    949     836     4,566
UCONN PD                261     403     468         636    359     296     2,423
Valley Shore EC         677     542     599         620    754     793     3,985
Vernon PD               509     438     546         554    550     593     3,190
Wallingford FD          640     605     747         862    956     985     4,795
Waterbury PD           4,316   3,799   3,972    3,998     4,352   4,788   25,225
Waterford ECC           407     367     489         609    677     692     3,241
Watertown PD            308     304     315         422    403     398     2,150
West Hartford PD       1,269    991    1,345    1,646     1,683   1,747    8,681
West Haven ERS         1,852   1,712   1,909    1,999     2,211   2,361   12,044
Weston ECC              236     169     162         253    273     286     1,379
Westport FD              32      20      46         15      44      36      193
Westport PD             632     556     642         589    712     724     3,855




                                               10
Wethersfield PD       539      456       593         693      687       694      3,662
Willimantic FD       1,667    1,503     1,591     1,616      1,801     1,694     9,872
Wilton PD             329      264       351         456      509       553      2,462
Windsor Locks PD      249      205       256         253      314       310      1,587
Windsor PD            492      722       542         654      688       705      3,803
Winsted PD            183      177       203         191      221       222      1,197
Wolcott PD            214      182       187         204      181       171      1,139
Woodbridge PD         148      116       178         161      180       153       936
                   104,316   92,905   106,380   115,417    125,583   128,462   673,063




                                                11
ATTACHMENT 5
                           Infoline: TOP 30 Service Categories
                           Town(s): Statewide
                           Selected: All Services

                              Gender: Both Age: All
                              Period: 01/01/2001 to 12/31/2001       Report Date:
                              Total number of Transactions : 223,608 09/09/2002
                              Total number of Service Requests: Page             1o1
                              315,782                                              f
Utility Assistance                                                           26869
Substance Abuse Services                                                     21906
Housing                                                                      16014
Legal Services                                                               14527
Helpline Counseling                                                          11856
Emergency Shelter                                                            10918
Outpatient Mental Health Care/Counseling                                     10299
Food                                                                          9046
Health Insurance                                                              8922
Health and Human Services Information                                         7872
Housing Payment Assistance                                                    7396
Legal Education/Information                                                   7060
Temporary Financial Aid                                                       7052
Information Services                                                          6832
Government            Income                                                  6525
Programs
Crisis Intervention                                                           5674
Holiday Assistance                                                            4739
Transportation                                                                4715
Donor Services                                                                4594
Consumer Assistance And Protection                                            4399
Personal/Household Goods                                                      4392
Family Support Services                                                       4095
Health Care Referrals                                                         3526
Domestic Violence Services                                                    3445
Psychiatric Support Services                                                  3062
Mental       Health   Support                                                 2892
Services
Outpatient Health Care                                                        2730
Health Supportive Services                                                    2727
Volunteer Opportunities                                                       2697
WIC                                                                           2664
                           Infoline: All Service Categories
                           Town(s): Statewide
                           Selected: All Services

                               Gender: Both Age: All
                               Period: 01/01/2000 to 12/31/2000       Report Date:
                               Total number of Transactions : 204,572 09/09/2002
                               Total number of Service Requests: Page             1o3
                               273,386                                              f
Utility Assistance                                                            27652
Substance Abuse Services                                                      16959
Housing                                                                       11514
Legal Services                                                                10499
Helpline Counseling                                                           10364
Outpatient Mental Health Care/Counseling                                       8576
Emergency Shelter                                                              8252
Information Services                                                           8241
Food                                                                           7563
Health Insurance                                                               6906
Temporary Financial Aid                                                        6610
Health and Human Services Information                                          6161
Government              Income                                                 6103
Programs
Legal Education/Information                                                    6090
Housing Payment Assistance                                                     5547
Crisis Intervention                                                            4697
Transportation                                                                 4442
Family Support Services                                                        4200
Consumer Assistance And Protection                                             3832
Personal/Household Goods                                                       3358
Domestic Violence Services                                                     3241
Mental       Health    Support                                                 3066
Services
Donor Services                                                                 2790
Health Care Referrals                                                          2527
Health Supportive Services                                                     2521
Holiday Assistance                                                             2467
Medical Expense Assistance                                                     2466
Volunteer Opportunities                                                        2212
Psychiatric Support Services                                                   2198
Outpatient Health Care                                                         2157
Disease/Disability Information                                                 2087
Specialized Health Care                                                        1930
Employment Acquisition                                                         1857
WIC                                                  1833
Courts                                               1677
Case Management                                      1554
Administrative Entities                              1483
Law Enforcement Agencies                             1467
Home Improvement                                     1330
Social Insurance Programs                            1329
Adult Education/ Enrichment                          1315

Infoline:     All  Service                   09/09/2002
Categories
Town(s): Statewide                           Page       2o3
                                                          f
Animal Services                                      1313
Criminal Justice System                              1272
Consumer Regulation                                  1272
Health Assessment/ Diagnostic Services               1255
Records/Licenses/Permits                             1247
Money Management                                     1214
Recreational/Leisure Activities                      1204
Advocacy                                             1160
Human Rights Groups                                  1140
Employment Preparation                               1106
Medical Technology Services                          1096
Family Planning                                      1080
Children's Protective Services                       1043
Tourism/Business/Industry                            1039
Outreach Programs                                    1016
Law Enforcement Services                              981
Political/Government                                  967
Information
Education                                             931
Occupational/Professional Associations                896
Dental Care                                           830
Adult Protective Services                             793
Utilities Connection/Repair                           767
Meals                                                 761
Mental Health Facilities                              756
Licensing/Certification/Accredi                       722
tation
Municipal/Social Services                             710
Maternal and Infant Care                              670
Educational Programs                                  651
Immigration/Naturalization                            639
Services




                                         2
Health Education                                       623
Hospitals                                              620
Residential Facilities                                 610
In-Home Assistance                                     605
Public Safety                                          604
Disabilities Services                                  598
Child Care                                             559
Public Employment and Training Programs                544
Abused Persons Services                                532
Community Action Groups                                532
Mentoring                                              516
Libraries                                              497
Vocational Rehabilitation                              476
Research/Planning                                      398
Companionship                                          389
Community Centers                                      381
Public Health                                          375
Smoking       Education   and                          368
Prevention

Infoline:     All  Service                    09/09/2002
Categories
Town(s): Statewide                            Page       3o3
                                                           f
Youth Development                                      360
Rehabilitation                                         320
Assisted Living Facilities                             300
Nursing Home Care                                      299
Tutorial Services                                      281
Children's Health Services                             267
Interpretation/Translation                             266
Adoption                                               260
Foster Care                                            247
Environmental Improvement                              243
Group Homes                                            238
Personal Emergency Response Systems                    226
Transitional Mental Health                             215
Services
Judicial Services                                      214
Gambling Help Services                                 207
Adult Day Care                                         195
Special Education                                      181
Technical Assistance                                   173
Early Childhood Education                              150
Charities/Foundations/Funding Organizations            134




                                          3
Employment Services                 121
Direct Mail Refusal Request          91
Forms
Personal         Reassurance         61
Services
Teen Pregnancy Prevention            40
Spiritual Enrichment                 28
Sex Education                        28
Audio Recording Services             28
Utility         Disconnection        16
Notification
Employee           Assistance        16
Programs
Community Groups                     15
Computers                            15
Peer Review Organizations            15
EPSDT                                 3




                                4

				
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