Abbreviated Dialing for One Call Notification Issue Management

Abbreviated Dialing for One Call Notification Issue Management Group Report November 5, 2003 Chairperson: Penn Pfautz ATT Presented By: Jim Castagna Verizon

Background • The Pipeline Safety Improvement Act (Public Law 107 -355) mandates the establishment of a 3 digit nationwide toll-free telephone number system for use by State One Call notification systems. • Based on NANC discussions at its January 22, 2003 meeting, the Abbreviated Dialing for One Call Notification IMG was formed to examine issues related to implementation of this mandate. 2

Background • On August 28, 2003, the DOT issued a petition for rulemaking by the FCC for the allocation of a three-digit TN to access excavation damage prevention (one call centers) services nationwide. • At its September 25, 2003 meeting, the NANC requested the IMG to consider two alternative approaches to its three-digit 811 recommendation, namely, the sharing of an existing N 11 code and the use of a national 800 number. 3

Background - DOT Petition Excerpts • Urges 3 -digit number to promote broadest possible use of service and to secure the maximum benefits. • Facility damage imposes substantial costs across the economy well beyond the direct cost of repair to the affected facilities and pose a serious threat to public safety and the environment. • 3 -digit assignment is vital to improving public safety by reducing pipeline failures associated with excavation damage, strengthening homeland security by protecting critical energy and telecommunications infrastructure nationwide from disruption. 4

DOT Petition Excerpts 1999 - 2001 Study Statistics • 39% of oil pipeline spills caused by road construction, underground operators and other pipeline operators, accounting for 28% of the oil volume spilled. • Although homeowners and farming caused 24 and 7% of pipeline spills, respectively, each alone accounted for 21% of oil volume spilled or together, 42% of total oil volume spilled. • The FCC acknowledged the more lengthy or more varied the TN, the greater the likelihood of ignorance and disuse. (N 11 Order, CC-Docket 92 -105, FCC 97 -51) 5

DOT Petition Excerpts • Three digit dialing codes are scarce resources, allocated only for those uses which serve the needs of a broad public. (N 11 Order, CC-Doc 92 -105, FCC 97 -51) • In this case such a code would offer added protection to the pipelines, local and long distance telecommunications lines, fiber optic cables, electrical power cables, and water and sewer systems that comprise the nation’s underground infrastructure. • The perspective beneficiaries of the petition thus encompass virtually the entire population of the United States. 6

Background The IMG’s September 25, 2003 report recommended the use of 811 after considering the following alternatives: 1 - Vertical Service like Code #344, *344, 344# 2 - Geographic NPA/Easily Recognizable Code ERC 344 3 - N 11 Special Access Code 811 - the only remaining N 11 code not reserved or in widespread use 7

Background The IMG’s September 25, 2003 Recommendation to the NANC stated that: • Both wireless and wireline should implement 811 • Wireless retains #344 as well, either indefinitely or for some transition period 8

Analysis of Additional Alternatives and Issues Identified by NANC The IMG was asked to further investigate: • the use of a single national 10 -digit mnemonic toll -free number rather than a 3 -digit code such as 344 or 811 • the integration of the One Call access service onto an existing N 11 code • the handling of potentially misdialed 911 calls reaching the One Call Centers via 811 9

Analysis of Additional Alternatives and Issues Identified by NANC • The IMG also engaged the participation of representatives from the Common Ground Alliance and One Call Systems International to help us understand the perspective of the One Call Centers. • To aid in understanding the current One Call Center environment and preferences with respect to implementation of the One Call access mandate, the IMG conducted a survey of One Call Center directors. 10

10 -digit mnemonic toll-free number • Compared to a 3 -digit solution, a 10 -digit TN may be harder to remember. • An 8 YY solution can only use the calling TN to route calls, thereby limiting the ability to route wireless calls based upon tower location. • While this alternative would meet the toll free aspect of the mandate, 8 YY is not 3 -digits in length as stipulated in the legislation. 11

10 -digit mnemonic toll-free number • Switch development is not required and all networks are capable of implementation • Avoids use of the last N 11 Code and potential 911 misdials reaching 811 • No number optimization impact compared to assignment of an ERC 344 • Customers are used to dialing toll free numbers to access a variety of services and understand the call is free. • Facilitates a national single number customer education program 12

Integration into an Existing N 11 Code • Consumer Confusion with mixed-use N 11 Advertising, e. g. , 511 “call before you dig” or “dial before you drive” • Caller confusion may lead to missed opportunities if callers must first use an Interactive Voice Response System (IVR) to select the desired service, e. g. , 511 Traffic versus One-call • Integration adds complexity, cost, and may delay deployment - changes existing N 11 arrangements • Survey Respondents strongly opposed the use of a shared N 11 code 13

Other Issues • Ability of Centers to transfer calls to 911 – current best practices specify that the centers tell the caller to hang up and dial 911 rather than attempt to transfer calls since in the transfer, E 911 capabilities are lost – The IMG felt that network modifications to preserve location capabilities on transfer would be prohibitively complex 14

Final Recommendation After considering the implementation timeliness, technical aspects and comparing the alternatives, including 811 versus 8 YY, the IMG elected to satisfy the legislative mandate for a 3 -digit number and therefore maintains its original recommendation, namely: • Both wireless and wireline should implement 811 • Wireless retains #344 as well, either indefinitely or for some transition period 15