[From https://docs.cpuc.ca.gov/published/report/5281.htm]
Before the Public Utilities Commission of the State of California
Order Instituting Rulemaking on the Commission's own Motion into Competition for
Local Exchange Service.
R.95-04-043
(Filed April 26, 1998)
Order Instituting Investigation on the Commission's own Motion into Competition
for Local Exchange Service.
I.95-04-044
(Filed April 26, 1995)
AUDIT REPORT ON THE 310 AREA CODE
(REDACTED VERSION)
Submitted in Compliance with CPUC Decision 00-09-073
Issued on September 21, 2000
CALIFORNIA PUBLIC UTILITIES COMMISSION TELECOMMUNICATIONS DIVISION
Respectfully submitted
February 16, 2001
Jack Leutza, Director
Telecommunications Division
505 Van Ness Avenue, 3rd Floor
San Francisco, CA 94102
AUDIT REPORT ON THE 310 AREA CODE
REDACTED VERSION
CALIFORNIA PUBLIC UTILITIES COMMISSION
TELECOMMUNICATIONS DIVISION
February 16, 2001
Prepared by Telecommunications Division:
Michael Amato Cherrie Conner
Bishu Chatterjee Stanton Puck
Herb Chow Craig Stevens
Nathaniel Cole James Wuehler
TABLE OF CONTENTS Page
EXECUTIVE SUMMARY 1
1. INTRODUCTION 6
1.1 Audit Scope and Objective 6
1.2 Audit Sample 6
1.3 The Telephone Number Inventory Database System 7
2. PACIFIC BELL 9
2.1 Audit Findings 9
2.2 Staff Recommendations 11
3. VERIZON CALIFORNIA INC. 12
3.1 Audit Findings 12
3.2 Staff Recommendations for Assigned Numbers 16
3.3 Staff Recommendations for Administrative Numbers 19
3.4 Staff Recommendations for Reserved Numbers 20
4. WORLDCOM TECHNOLOGIES INC. 22
4.1 Audit Findings 22
4.2 Staff Recommendations 24
5. XO CALIFORNIA INC. 25
5.1 Audit Findings 25
5.2 Staff Recommendations 26
6. SPRINT SPECTRUM PCS 27
6.1 Audit Findings 27
6.2 Staff Recommendations 28
7. AT&T WIRELESS SERVICES 29
7.1 Audit Findings 29
7.2 Staff Recommendations 30
8. TYPE 1 NUMBERS 32
8.1 Type 1 Number Arrangements 32
8.2 Audit Findings 33
8.3 Staff Recommendations 34
APPENDICES 36
A-1 CARRIER DATA SOURCE AND AUDIT METHODOLOGY 37
PACIFIC BELL 37
VERIZON 38
WORLDCOM 42
XO CALIFORNIA 43
SPRINT 43
AT & T WIRELESS 44
TYPE 1 NUMBERS 45
A-2 Audit findings of Verizon's Uncontaminated Thousand Blocks 46
A-3 Verizon: Inventory Status of Telephone Numbers by Number Of Years 47
A-4 Distribution of all Type 1 Numbers in the 310 Area Code 48
A-5 Pacific Bell Type 1 TN Summary (By Rate Center) reported for the March
310 Report 49
A-6 Verizon Type 1 TN Summary (By Rate Center) Reported for the March 310
Report 50
A-7 List of Delinquent Type 1 Carriers 51
AUDIT REPORT ON THE 310 AREA CODE (310 AUDIT)
EXECUTIVE SUMMARY
The purpose of this audit of the 310 area code is to verify that wireline
and wireless carriers reported accurate telephone number (TN) utilization data
to the California Public Utilities Commission (CPUC) for the report on "The 310
Area Code"(March 310 Report).1 This report provides the analysis and results of
the CPUC staff audit (October-December 2000) of TN utilization data that
carriers in the 310 area code submitted in compliance with Decision (D.)
99-09-067 in November 1999. Based on the utilization data that carriers
submitted, the CPUC's Telecommunications Division (TD) estimated approximately
three million unused TNs in the 310 area code. In compliance with Decision (D.)
00-09-073 the CPUC staff undertook an audit of the 310 utilization data to
provide a basis for determining the reliability of the data that carriers
submitted for the March 310 Report before any area code relief plan is
considered.
The audit examined the reported data of six carriers in the 310 area code.2
In this audit report, staff proposes recommendations that may extend the life of
the 310 area code and potentially other area codes by identifying problems with
data inventory and reporting systems that these carriers use today. Staff finds
that the six audited carriers did not use efficient and accurate data tracking
systems to identify and report TN utilization data for the March 310 Report.
Staff estimates 214,0003 additional unused TNs (_ 5% error) that these carriers
should have reported as Available above the three million unused TNs estimated
in March 310 Report. Staff proposes that carriers make these 214,000 unused TNs
available for customer use. Based on sampled carrier data and weighted
assumptions, staff concludes that the probability of all carriers (including
carriers who were not audited) reporting erroneous utilization data in the 310
area code is much higher than the findings from this audit.
The findings in this report include implications and recommendations for all
carriers in the 310 area code. The March 310 Report findings focused on
estimating unused TNs from carrier submitted data and examined TN utilization
policies that were contrary to TN resource conservation practices. The 310 audit
findings on the other hand focus on examining the accuracy of carrier reported
data by investigating carriers' data systems in place. The following six key
findings from the 310 Audit demonstrate that the TN inventory management
practices and data reporting methodologies of the audited carriers require
improvements.
· Carriers erroneously reported 214,000 TNs as unavailable instead of
available for assignment.
· Carriers failed to provide historical data sources used to develop
the utilization data reported to CPUC.
· Carriers had lengthy data retrieval processes.
· Carrier inventory database systems often displayed contradictory TN
status which resulted in incorrect TN inventory reporting.
· Carriers keep TNs in reserve for extended periods inconsistent with
Federal Communications Commission (FCC) requirements.
· Carriers do not adequately track Type 1 and ported out TNs.
Based on the audit findings, TD proposes the following summary of
recommendations to carriers for efficient and accurate management of numbering
resources. The first five recommendations validate the TN mismanagement
practices that were addressed in the March 310 Report. The next nine
recommendations are based on the audit findings. Carrier specific audit findings
and recommendations are described in the individual carrier audit sections.
Summary of March 310 Report Recommendations Validated by the Audit
Assigned Numbers4
1. Carriers should make available all erroneously reported
Assigned numbers and if applicable donate the 10% or less contaminated thousand
blocks to the 310 pool.
2. Carriers need to institute procedures to ensure that all TNs
including Assigned numbers with pending service orders are in compliance with
the current FCC and CPUC requirements for Assigned numbers.
Administrative Numbers5
3. All carriers should conduct a periodic internal audit to
determine the status of all numbers classified in their records as
Administrative. Numbers not in use at the time of this audit should be made
available for customer assignment.
Reserved Numbers6
4. Carriers should adhere to the current maximum number of days
(180 days) per FCC requirement for reserved numbers.
Type 1 Numbers7
5. Delinquent wireless carriers holding Type 1 TNs who still
have not reported number utilization data should immediately submit their
utilization data. Failure to comply should subject carriers to penalties and
sanctions.
Summary of Recommendations Based on Audit Findings
Accurate and Efficient Internal Data Tracking System
6. All telecommunications carriers should maintain efficient and
accurate database systems that can update the status of TN inventories and store
historic records of all utilization data submitted for future audit purposes.
7. Carriers should ensure that when a customer is disconnected
permanently from the system, the inventory system and the switch receive the
"final out orders" so that the two systems can be updated simultaneously.
8. Carriers should reconcile their telephone number inventory
system with other systems such as the central office switch, customer profile
database, and the pending order database to identify errors in the systems for
corrective action.
Report on excessive numbers
9. Carriers should adjust 214,000 TNs from Assigned to Available
as recommended by this audit and immediately arrange to return any excess TNs.
10. Carriers should institute appropriate procedures to control
unnecessary telephone number reservations made by sales representatives so
hoarding ranges of numbers can be avoided.
11. Carriers should not assume that all TN ranges associated
with a customer are working and assigned.
12. Carriers should not keep Available TNs as Reserved and if
necessary, modify Centrex contracts that unnecessarily reserve a large number of
available TNs.
Tracking of Ported Out Numbers8 and Type 1 Numbers
13. Carriers should track TNs that are ported out to other
carriers and reported as assigned numbers. Carriers need to maintain updated
records identifying the carrier receiving the ported numbers and the numbers
ported.
14. Both the LECs and their Type 1 carriers should keep accurate
and updated contact names and TN inventory records. When a Type 1 carrier goes
out of business, Type 1 numbers need to be returned to the donating LEC.
Audit Conclusions
Based on the audit findings, TD reaches three conclusions. First, carriers
did not deliberately misreport their TN utilization data for the March 310
Report. Second, the audit authenticates the utilization data that carriers
submitted for the March 310 Report except for the recommended TN adjustments as
pointed out in this report. Third, the additional TNs found are not sufficient
to extend the life of the 310 area code. The backup plan for the 310 area code
should be implemented as directed in Decision 00-09-073.
1. INTRODUCTION
1.1 AUDIT SCOPE AND OBJECTIVE
The scope of the audit covered all data reported as of November 1999,
including subsequent events. The 310 audit used generally accepted audit sample
techniques to examine the validity of the data that carriers reported for the
March 310 Report by TN category: Assigned, Administrative, Reserved, Aging, and
Type 1 numbers.
1.2 AUDIT SAMPLE
The March 310 Report compiled utilization data of 55 wireline and wireless
carriers in the 310 area code. For purposes of this audit staff chose six of the
55 carriers that held the largest number of NXX codes (prefixes) in the 310 area
code. TD staff selected two Local Exchange Carriers (LEC), two Competitive Local
Exchange Carriers (CLEC), and two Wireless Carriers (WLS) to represent a broad
cross section of the telecommunications industry. The six carriers are Pacific
Bell, Verizon California Inc.(formerly GTE California Inc.), WorldCom
Techonologies Inc.(formerly MCI Metro, ATS, Inc. & WorldCom Technologies Inc.),
XO California Inc.(formerly Nextlink California Inc), Sprint Spectrum L.P. dba
Sprint PCS, and AT & T Wireless Services (formerly AB Cellular Holding, LLC).
Staff found that these six carriers jointly held 477 NXX codes or 66% of the
total NXX Codes in the 310 area code as of November 1999. The 475 NXX codes
(does not include special use codes) are distributed as follows: Pacific Bell -
247, Verizon - 141, Sprint PCS - 13, AT&T Wireless - 32, XO - 11, and Worldcom -
31. In conducting the audit, staff sampled appropriate TN blocks out of the
entire population of 4.8 million TNs based on audit resources and time
constraints. In some cases, staff audited all numbers in Assigned,
Administrative, Reserved, and Aging categories. The sampling techniques varied
among carriers. Additionally, staff examined the status of Type 1 numbers
reported by the LECs.
1.3 THE TELEPHONE NUMBER INVENTORY DATABASE SYSTEM
Each company employs complex database systems to manage their TN inventory,
the customer billing, and the actual switching of telephone calls. These
database systems vary among companies. Generally these systems change TN
inventory status each time a customer connects or disconnects. Changes appear in
the systems throughout the day, or the system is updated periodically throughout
the week. For example with Aging TNs, when a customer connects, the inventory
system shows that the TN is Assigned or unavailable. When the customer
disconnects, the inventory system must show the TN unavailable and "aging" for a
time so it will not be assigned too soon to a new customer. Similarly for
Reserved TNs, each carrier usually assigns a period of time between the day the
TN is assigned to a customer and the day it is connected for service. During
this period the TN is "reserved" in the inventory system so it will not be
assigned to another customer. At the end of the designated reserve period, if
the TN has not been connected and the customer has not requested an extension of
the reserve period, the inventory system automatically returns it to "available"
status.
To report 310 utilization data carriers used the database systems to
identify the status of working and non-working numbers. When reporting their 310
utilization data carriers provided a "snap-shot" showing their TN utilization at
a specific date and time. Prior to the issuance of the Numbering Resource
Optimization Order (NRO Order) by the FCC in March 2000 9 there were no
requirements for companies to maintain complete historical records of TN use.
Therefore, none of the carriers audited maintained records of the "snap-shot"
that was used to prepare the utilization data.
This audit relied on archived data, current customer records, and in some
instances on analytic assumptions of changes that took place between November
1999 carrier data reporting and the staff November 2000 audit. The following
sections describe staff audit findings and staff recommendations for individual
carriers. For detailed descriptions of individual carrier data source and staff
audit methodology refer to Appendix A-1.
2. PACIFIC BELL
For the March 310 Report, Pacific Bell (PB) identified 2.5 million numbers
in the 310 area code under CPCN number U1001C and OCN 9740. PB's numbers (247
NXXs) represented about 39.2 % of all TNs involved in the 310 area code
utilization study. Staff's primary focus was to determine the reliability of TN
utilization data that PB submitted for the March 310 Report. The staff examined
PB's data inventory system and found -------- available TNs that PB erroneously
identified as unavailable.
2.1 AUDIT FINDINGS
Table 2-1 shows staff audit findings that PB erroneously reported ---- TNs
(------ in Reserved and ------- in Type 110 TNs) for the March 310 Report.
Table 2-1
Pacific Bell
Summary of Audit Findings
March Report Data
Proposed
Audit Adjustments
Audited
Balance
Total TN's
TN's
Assigned (includes Intermediate)
Administrative
Reserved
Aging
Type 1 (estimate from section 8)
Available
Donated to Pool
Net Available TN
(a) Special use TNs are not included in these numbers.
Staff recommends that PB make these TNs available. Staff findings of PB's
Reserved, Aging, and Assigned numbers are discussed in detail below. Staff did
not identify any significant discrepancies in PB's Administrative TN utilization
data submission.
Reserved Telephone Numbers
Staff found PB reported ----- TNs (table 2-1) as reserved for the March 310
Report. Of these -------- TNs, PB kept approximately ------- TNs in the reserved
category over a year for PB's Centrex customers. Staff examined a sample of
blocks to test the current status of those TNs. Under PB's current reserved
number policy PB can reserve TNs for Centrex customers for up to one year with
an additional six-month extension by customer request. In compliance with FCC's
Second Numbering Resource Optimization Order,11 PB should make -------- TNs
available to customers and conform its customer agreements to the FCC's reserved
number requirements.
Aging Telephone Numbers
Staff verified PB's internal system and found that PB reported ------- TNs
as aging for the March 310 Report and ------ for the FCC NRUF. PB's system
identifies the total TNs in aging but does not identify the numbers in aging by
class of customers (business or residential) or report the length of time (60
days for residential customers versus twelve months for business customers) that
a number is aged. PB did not maintain the data it used to develop TNs reported
in the Aging category. Staff concluded no additional audit was needed based on
PB data submitted.
Assigned Telephone Numbers
Staff found PB's reported TNs in the assigned category rose from ---------
in the March 310 Report to --------- in the NRUF utilization data. This increase
was assumed acceptable due to customer growth. Staff compared working TNs in the
end office switch with the working TNs 12 identified in the March 310 Report at
the thousand-number block level. More recent TN Bashes (see Appendix 1-A under
PB) showed working TNs to be about --- percent higher than the TNs reported in
the March 310 Report. This increase was similarly attributed to customer growth.
Additionally, staff sampled assigned TNs from TN Bashes to PB's customer billing
records and concluded that PB's billing system produced reliable information
during November 1999 reporting.
2.2 STAFF RECOMMENDATIONS
1. PB should update its internal database systems to clearly identify
the status of each TN.
2. PB should maintain historical records of its number utilization
reporting for future audit purposes.
3. PB should comply with the current FCC policy and free up ------- TNs
that were reported as reserved in the March 310 Report.
4. PB's system should be able to identify its aging TNs by business and
residential customer class and the period of time those TNs are aged.
3. VERIZON CALIFORNIA INC.
For the March 310 Report, Verizon California Inc.(Verizon), formerly GTE
California Inc., identified 1.4 milllion numbers in the 310 area code under CPCN
No. U1002C and OCN 2319. Verizon's numbers (141 NXXs) represented about 19 % of
all TNs involved in the 310 area code utilization study. Staff's primary focus
was to determine the November 1999 status of the 310 TNs held by Verizon and
reported in the utilization report as either Assigned, Administrative, or Aging.
Verizon did not report any TNs in the reserved category as they were either
classified as Assigned or Available for the utilization study.
3.1 AUDIT FINDINGS
Table 3-1 shows Verizon's utilization data that was submitted for the March
310 Report and the TN adjustment of ----------- TNs from the staff audit.
Table 3-1
Verizon
Summary of Audit Findings
March Report Data
Proposed
Audit Adjustments
Audited
Balance
Total TN's
TN's
Assigned
Administrative
Reserved
Aging
Type 1 (estimate from section 8)
Available
Transferred to PB
Donated to Pool
Net Available TN
Assigned Numbers
The TNs reported by Verizon in the assigned category of March 310 Report are
overstated by about ---- numbers. Over --------- should have been shown as
available had Verizon reported its numbers correctly.
"Reserved To Order" Classified As Assigned Numbers
Staff found that Verizon's sales representatives were allowed to reserve
numbers without any customer request on file. Once reserved, these numbers were
blocked and set aside for future use. Numbers reserved in this way were
classified as "reserved to order" and were erroneously included in "assigned"
category in the utilization report contrary to the CPUC utilization guidelines.
CPUC rules provide only for reserved numbers with service orders pending to be
included in the assigned category for the CPUC utilization study.
Staff found several numbers reserved by sales representatives and blocked
from future assignments that were never activated or working for any customer.
Staff confirmed this practice by noting the absence of subsequent order
activities for several numbers reserved by sales representatives. Moreover,
staff found there were no controls in place to ensure that these numbers were
unblocked and made available if the numbers were not activated within a
reasonable period of time.
Staff concludes that most of the numbers classified as "reserved to order"
were not at the request of specific customers, because Verizon could not provide
any third party documentation to confirm that there was any reservation made by
the end user or for how long. The only documentation Verizon could produce was
internal e-mails from the sales representative to the TNAC (see Appendix A-1
under Verizon) asking for the range of numbers to be reserved.
Staff found that about ----- numbers which should have been classified as
"reserved" and "available" instead were reported as "assigned" for the March 310
Report. As a result, Verizon did not report any numbers in its reserved
category, contrary to the utilization study guidelines. Staff found that Verizon
reported over --- numbers in the March 310 Report as Assigned with service
orders pending when Verizon did not have such service orders pending. These TNs
were not working almost 12 months after Verizon submitted its utilization study
data and should not have been reported as Assigned. Staff found that some of
these TNs had been "reserved to order" for over 10 years and are still
classified as such at the time of our audit despite the current FCC
guidelines.13
"Suspended Numbers" Reported As Assigned
Staff selected about 1,000 TNs from the sample for review that were included
in the Assigned category when the carrier's internal records showed that these
numbers were temporarily suspended because of customer non-payment. These TNs
were not working in the public switch at the time of reporting the utilization
data. Some of these TNs have been in this suspended status for over 11 years.
This finding is contrary to Verizon's stated policy of having numbers suspended
for only 10 days. After 10 days such TNs are disconnected as a requirement and
routed through the aging process for the purpose of making them Available.
Verizon should have classified these TNs as Available in accordance with CPUC
guidelines as many of these TNs had been in a suspended mode for an extremely
long time prior to the date of the utilization report.
"Temporary" Classified As Assigned
Staff found that Verizon included in the Assigned category TNs that were
classified internally in a "temporary" status pending service orders. Verizon
did not provide any information about the time frame that such numbers are held
on "reserve" status. Verizon claimed that these TNs remain in this status until
the new due date of the order or until the order is canceled. It is only then
that the TN would be returned to available status. However, staff found TNs in
reserve status since 1984. These TNs should have been classified as available
for the utilization study. Staff concludes this is a system error.
Lack of Internal Controls
Verizon assumed in reporting the utilization data that all TN ranges in the
inventory system included in the extract file with customer names were working
and therefore classified as "assigned." Staff found over ------ TNs were
erroneously reported as assigned because of the error in the inventory system
that had customer names associated with several thousands of numbers when they
were actually available. This problem was caused partly by sales representatives
obtaining ranges of numbers by providing a customer name in order to obtain the
numbers. Staff concludes that lack of internal controls contributed to the
system's failure to update the records of such customers.
Staff verified TNs shown as available in Verizon's raw data obtained from
the inventory system and reflected in the extract file from the MARK system (see
Appendix A-1 under Verizon) were erroneously classified and reported as assigned
for the March 310 Report purposes. The staff was unable to confirm that about
----- TNs that the company indicated needed to be back-billed were actually
assigned to customers. Staff found no records in Verizon's database to establish
that such numbers were assigned to these customers. Staff could not find billing
records for these numbers either. However, after further research, staff found
some of these numbers were actually working in the switch but that the billing
system failed to bill the customers for such numbers. 14
Staff was not able to confirm pertinent information on ported out numbers.
Ported out numbers were classified as Assigned to avoid double counting of
Available numbers. During the reporting period there was no requirement by the
FCC or CPUC that carriers identify the receiving carriers of ported out numbers.
The staff could not perform any reliable audit work for such numbers to verify
the claims made by the native service provider. This problem was further
compounded by the lack of an audit trail for such ported out numbers.
At the time of the audit, Verizon did not have adequate internal controls
and procedures to ensure that it complies with current FCC and CPUC requirements
for future utilization reporting and can efficiently manage all telephone
numbers at its disposal. Staff found that Verizon did not perform periodic
reconciliations between its various stand-alone systems, TN inventory system,
the customer profile database, and billing records.
Staff concluded that Verizon had too many status categories for its TN
inventory system, which caused problems in categorizing its TNs for the
utilization report. Staff noted that the company had about 17 various categories
for TN status compared to about 7 required for the March 310 Report or 6
required by the FCC. While 17 categories of TNs may be useful internally, staff
concludes that this large number of categories is confusing and prone to errors.
For example Verizon has a category called "other". This same "other" category
can be interpreted to mean about 7 different CPUC categories.
3.2 STAFF RECOMMENDATIONS FOR ASSIGNED NUMBERS
1. Verizon should institute appropriate procedures to control TN
reservations made by its sales representatives. Verizon should institute
follow-up procedures or feedback to ensure that sales representatives are not
hoarding ranges of numbers with the hope of finding a customer.
2. Verizon should conduct a thorough review of its TN inventory system
since staff found Verizon erroneously blocked out TNs for customers that did not
exist or TNs that were erroneously shown as Assigned to regular customers. All
such hundred number ranges should be reclassified Available.
3. Verizon should periodically perform a comprehensive reconciliation of
its TN inventory system with other systems such as the switch, customer profile
database, and the pending order database to identify errors in its system for
corrective action.
4. For future utilization studies, Verizon should refrain from using the
assumption that all ranges associated with a customer name are validly working
and assigned TNs for customers. Verizon should put controls and procedures in
place to strengthen internal controls over the AAIS inventory system (see
Appendix 1-A under Verizon) and use of customer names for blocking out ranges of
numbers.
5. Verizon should ensure that when a customer is disconnected
permanently from the system, the inventory system and the switch receive the
"final out" orders so that the two systems are updated immediately.
6. Verizon needs to institute procedures to ensure that all TNs included
as part of "assigned with service orders pending" are in compliance with the
current FCC and CPUC requirements for assigned numbers.
7. The CPUC should consider creating another sub category within the
Assigned category for numbers ported out numbers, as this would enable carriers
to report this type of useful information. The CPUC should also consider
requiring carriers receiving ported out numbers to file a separate report
similar to the Type 1 filing for the numbers they have received from other
carriers. This informational filing could be used in the future to audit numbers
reported as "ported out" by the industry.
8. Verizon should align its inventory status categories with the FCC
requirements to avoid errors caused by its excessive status categories.
Administrative Numbers
Staff found that Verizon overstated the reported Administrative numbers by
about ---------- TNs. -- of these TNs were actually available for assignment of
which ---- 1000 blocks were uncontaminated and should have been donated to the
pool. The remaining numbers were customers' numbers erroneously reported as
Administrative numbers.
Staff found Verizon reported about ------- 1,000 uncontaminated blocks as
Administrative numbers that should have been reported as available numbers
because none of these blocks was used by Verizon for any administrative purpose.
These -- (Appendix A-2) numbers in uncontaminated thousand blocks should be
donated to the 310 number pool.
Staff found that Verizon reported -- thousand blocks as active TNs although
banks of hundred numbers were still not working or activated. Approximately
------ TNs were erroneously reported in the March 310 Report as working
administrative numbers. Verizon did not provide the staff any justification for
reporting available numbers as Administrative, neither did Verizon provide staff
with any future growth or expansion plans to justify having several inactivated
thousand blocks set aside.
Staff found TNs classified as Administrative numbers were instead Assigned
to customers contrary to the definitions in the March 310 Report guidelines.
This appears to be an internal error that was a result of system inability to
properly separate customer numbers from Administrative numbers.
3.3 STAFF RECOMMENDATIONS FOR ADMINISTRATIVE NUMBERS
1. Verizon should not contaminate any of the uncontaminated 1,000 blocks
it erroneously included in the Administrative category. These blocks should be
donated to the pool immediately.
2. Verizon should free up the ---- non-working additional numbers
classified as Administrative numbers. These sequential ranges of numbers should
be made available for assignment to customers.
3. Verizon should conduct an internal audit to determine the status of
all numbers classified in its records as Administrative. Verizon's internal
audit should confirm that such numbers as Administrative numbers and not
customer numbers. All customers numbers should be reported as part of Assigned
numbers.
Reserved Numbers
By placing Reserved numbers in the assigned category, Verizon reserved
numbers and overstated Assigned numbers. About -------------- numbers were
misplaced.
Staff found Verizon held reserved numbers in its internal records for
excessively long periods of time prior to the CPUC utilization report study.
Subsequently, these numbers are still classified as Reserved "for general
purpose". Keeping over -- numbers in "perpetual reserve" for over 5 years when
those numbers are actually available, meant that the numbers assigned by Verizon
in general would not comply with the sequential numbering requirement. Verizon
is also not complying with the current FCC requirement that service providers
"shall assign all available numbers within an opened thousand blocks".
Staff found that Verizon attempted to justify this "perpetual reserve" by
claiming that these TNs form the 6-month inventory it is allowed to keep. While
this is true, Verizon failed to consider its effect on sequential assignment,
and the current requirement that all service providers shall assign 100% of
available TNs within an opened thousand block. In addition, the new FCC rules
require that "Numbers held for specific end users or customers for more than 180
days shall not be classified as Reserved numbers." There are no specific end
users for hundreds of numbers classified as reserved in Verizon's inventory
system as the numbers are only classified as "reserved for general purpose".
(see Appendix A-3 Table).
Staff found that some of the Reserved numbers reported as Assigned were only
covered by contracts approved under Advice Letters and did not have a pending
service order. Furthermore, some of the Advice Letters stipulated that the
service provider could reclaim such numbers if the customers do not utilize 70%
of the code capacity within three years. The staff review revealed that in some
cases 70% of the code capacity was not utilized and uncontaminated thousand
blocks were not activated within 3 - 5 years.
These numbers also were not activated at the time of the utilization report
and should either have been classified as Available or Reserved. However, such
numbers were erroneously shown as Assigned in the utilization report. Verizon
failed to comply with the guidelines for the utilization study by failing to
institute procedures to confirm and document reservations to the end user. In
addition to having the number reserved, Verizon should also have placed some
restrictions on the duration and quantity of those reserved numbers.
3.4 STAFF RECOMMENDATIONS FOR RESERVED NUMBERS
1. Verizon needs to implement procedures to ensure that it complies with
the FCC requirements for reserved numbers. Verizon should make sure that ranges
of numbers classified as Reserved are assigned to an end user.
2. Verizon should implement procedures to ensure that it adheres to the
current FCC requirement of 180 days for reserved numbers.
Aging Numbers
Staff traced the reported numbers in the Aging number category to the raw
data file used in the preparation of the utilization report. Staff found no
significant differences between what was reported and what was in the data file.
4. WORLDCOM TECHNOLOGIES INC.
For the March 310 Report, MCI/WorldCom (WorldCom), formerly MCI and
Worldcom, identified 0.3 million numbers in the 310 area code under CPCN numbers
U5253C and U5378C, and OCN numbers 7229 and 7240. WorldCom's numbers (31 NXXs)
represented about 4.2 % of all TNs involved in the 310 area code utilization
study. Staff's primary focus was to determine the reliability of TN utilization
data that Worldcom Technologies Inc. (WorldCom) submitted for the March 310
Report. The staff audit concludes that Worldcom should make ----- TNs available.
4.1 AUDIT FINDINGS
The Table 4-1 shows the utilization data as reported. Staff findings show
WorldCom should have reported ----- TNs as available in November 1999.
Staff's audit found that the sampled TNs for the formerly MCI could all be
validated in the current system. This led staff to the opinion that the assigned
numbers reported in MCI's 310 Utilization Study are reasonably accurate.
Administrative Numbers
Staff found that the Administrative TNs reported by WorldCom did not meet
the definition of Administrative TNs for the March 310 Report or the FCC NRUF
Report. WorldCom should only report the actual number of TNs used in the
administrative category and not set aside TNs for administrative purpose when
they are not being used. Staff found over ----- unused TNs that are kept in
Administrative status and should be changed from Administrative to Available
status.
Reserved Numbers
Staff found that the databases used to report number utilization for the
March 310 Report contained over --- Reserved TNs in the 1000-1999 range in ---
of ----- NXX codes. Staff found these TNs were reported in the reserved category
as "Number Administration." Normally, the TNIS and NRM systems (see Appendix A-1
under WorldCom for database systems) automatically change reserved TNs to
available status after 60 days. However, the normal reservation functions would
not return the expired TNs to available status after 60 days due to TNs listed
as "Number Administration." Staff was told that WorldCom would return all its
reserved numbers under "Number Administration" to Available or Assigned as
appropriate. The correction of the "Number Administration" could result in over
----- TNs being changed to available status. Staff recommends that TD follow up
on WorldCom's Reserved TN status and WorldCom should report the results of
corrected TN status.
Staff found WorldCom's NRM system (see Appendix A 1 under WorldCom) turned
off the function that returned TNs from reserved to available status between
August 1999 to October 1999 that could have possibly overstated WorldCom's
Reserved TNs. Consequently, it is possible that some of the -- TNs reported as
Reserved in the March 310 Report were overstated. Since the March 310 Report
data submission, WorldCom has corrected the function and ------- TNs are
reported as Available. Staff recommends that WorldCom periodically review its
internal systems to ensure that the systems function properly.
4.2 STAFF RECOMMENDATIONS
1. WorldCom should only report actual TNs used in the Administrative
category and should not "reserve" Administrative numbers. This should reduce the
reported Administrative TNs by over --------------.
2. WorldCom should complete the clean up of its reserved TNs and report
the results to the CPUC. This could result in over ---- TNs being added to the
pool of Available TNs.
3. WorldCom should periodically review its internal systems to ensure
that the systems contain accurate data of TN use.
5. XO CALIFORNIA INC.
For the March 310 Report, XO California, Inc. (XO), formerly Nextlink
California Inc., identified 0.1 numbers in the 310 area code under CPCN number
U5553C and OCN 7262. XO's numbers (11 NXXs) represented about 1.5% of all TNs
involved in the 310 area code utilization study. Staff's primary focus was to
determine the reliability of TN utilization data that XO submitted for the March
310 Report. Staff audit concludes that XO accurately reported its utilization
data in November 1999.
5.1 AUDIT FINDINGS
Table 5-1 contains the numbers reported in the 310 Utilization Study.
Table 5-1 shows that the staff audit does not propose any adjustments to
XO's reported utilization data submitted in November 1999.
Staff analyzed XO's relatively small number of TNs in the 310 area code and
found XO donated ------------- TNs to the 310 number pool. Staff found a
----------difference between the utilization data that was submitted for the
March 310 Report and the utilization data used during the audit. Staff concludes
much of the difference due to ---- TNs reported as Reserved that should have
been reported as Assigned. Additionally staff concludes that the remainder of
the differences could have been human error in compiling the data for March 310
Report as well as time difference in data compiling between the March 310 Report
and the audit.
Staff found that XO had a large number of Available TNs in November 1999,
but XO donated most of these TNs to the pool in February 2000. XO increased its
Assigned TNs more than --- times in the seven months between the March 310
Report and the FCC NRUF Report, largely due to
----------------------------------------------------.
The difference in Reserved, Administrative, and Aging TNs that were reported
for the March 310 Report and the FCC NRUF Report were relatively small. Staff
verification concludes that XO had appropriately reported these numbers.
5.2 STAFF RECOMMENDATIONS
1. XO should ensure that its new reporting system reports Reserved TNs
properly.
6. SPRINT SPECTRUM PCS
For the March 310 Report, Sprint Spectrum (Sprint) identified 0.1 numbers in
the 310 area code under CPCN number U3064C and OCN numbers 6691 and 8941.
Sprint's numbers (13 NXXs) represented about 1.8 % of all TNs involved in the
310 area code utilization study. Staff's primary focus was to determine the
reliability of TN utilization data that Sprint submitted for the March 310
Report. Staff audit concludes that Sprint reported accurate utilization data.
6.1 AUDIT FINDINGS
Table 6-1 shows that total TNs by category as reported by Sprint for the March
310
Report were accurate and no adjustments to TN utilization data are required.
Staff found that Sprint has an automatic 90-day aging interval, unless
superseded by a state order that establishes a shorter period. However, Sprint
used a 60-day period for Aging TNs at the time of the March 310 Report. CPUC
staff was informed that if necessary Sprint will manually release a TN before
the aging cycle is completed.
Staff examined Sprint's reserved TN policy. At the time of the March 310
Report Sprint had no policy with regard to the release of reserved TNs. Sprint
has since implemented a manual review process to ensure that reserved TNs do not
remain more than 45 days in reserve.15 Sprint should review its reporting
procedure to ensure that the aging TNs are reported correctly.
Staff found exceptions of less than --------- for the Assigned TNs in the
audit sample. Therefore, staff concluded that Sprint's TN management system
reports the Assigned TNs accurately.
6.2 STAFF RECOMMENDATIONS
1. Sprint should automate the entire TN reporting system to eliminate
the potential of human error in its reports.
2. Sprint should also review its reporting procedures to ensure that the
aging TNs are reported correctly.
7. AT&T WIRELESS SERVICES
For the March 310 Report, AT & T Wireless Services (AWS), formerly AB
Cellular Holding (AB) LLC, identified 0.3 numbers in the 310 area code under
CPCN number U3009C and OCN 6228. AB's numbers (32 NXXs) represented about 4.4 %
of all TNs involved in the 310 area code utilization study. Staff's primary
focus was to determine the reliability of TN utilization data that AWS submitted
for the March 310 Report. Staff audit concludes that AWS reported accurate
utilization data.
7.1 AUDIT FINDINGS
Table 7-1 shows the usage patterns reported by AWS in March 310 Report.
Staff concludes that the 310 audit does not propose any TN adjustments of AWS
reported utilization data in November 1999.
Table 7 - 1
AT&T Wireless Services
March 310 Report Data with Audit Adjustments
March Report
Proposed
Data
Audit
Adjustments
Total TN's
TN's
Assigned
Administrative
Reserved
Aging
Available
Donated to Pool
Net Available after Donations
Staff found that AWS did not reserve TNs for end-users but reserved TNs that
were assigned to resellers, at the reseller's request. AWS's MacroCell system
(for details see Appendix A-1 under AWS data source) can track the reserved
status of reseller's TNs but reported reseller's TNs as Reserved and not
Assigned. Reseller's TNs should have been reported as Assigned and not as
Reserved. AWS stated that all reseller TNs would be reported as Assigned in the
future. AWS ------ reported --- TNs in the Reserved category, so staff did not
pursue this audit any further.
Staff found that --- of the ---- Administrative TNs that AWS reported were
for Temporary Location Directory Numbers (TLDNs). A TLDN number is used to
register a wireless phone that roams out of its assigned area code. AWS used a
formula to determine the number of TLDNs based on the number of roamers in the
area covered by a switch. Staff found out that one set of TLDNs are kept for
each switch. AB used one switch for the 310 area code.
AWS could not identify the exact date when March 310 Report data was
extracted from AB MacroCell system. Further, AWS informed the CPUC staff that
the people who did the work were not available to assist with the audit. So the
staff focused on the TN status as of November 30, 1999. Staff found that AWS
reported ----% more TNs to be Available as of November 1999 for the March 310
Report. Staff believes this difference to be reasonable for three reasons.
First, wireless companies have a high customer turnover or "churn" rate, so some
data relating to customers who dropped between November 1999 and April 2000
might have been lost in the conversion from the AB billing system to the AWS
billing system. Second, the uncertainty regarding the exact date the 310
utilization data was extracted can cause timing differences. Third, the 310
utilization data could have included manual errors in compiling the data. Staff
concludes that the difference between the March 310 Report data and the data at
the time of audit is less than ---- percent and the TNs reported in the March
310 Report were accurate.
7.2 STAFF RECOMMENDATIONS
1. AWS should maintain a back up copy of its reports in compliance with
the new FCC guidelines. The back up should include the date of the data used in
the reports. All back up data should be available in one location so that it can
be accessed and identified even if the employee who prepares the data is no
longer available.
8. Type 1 Numbers
Staff examined the status of unreported Type 1 numbers to follow up on those
Type 1 carriers who did not submit utilization data for the March 310 Report.
Staff found --- unused Type 1 TNs that were mistakenly reported as Assigned. The
audit was unable to resolve the status of 234,000 unresolved Type 1 TNs held by
Type 1 carriers that failed to report. Staff recommends penalties and sanctions
be imposed on these carriers in order to resolve the status of all Type 1 TNs.
8.1 TYPE 1 NUMBER ARRANGEMENTS
The Type 1 interconnection is a connection between a mobile/wireless service
provider and a wireline LEC for the purpose of originating and terminating
traffic or for access to end user services (i.e. Directory Assistance, Operator
Services, 911 etc).16 Type 1 interconnections are provided under an FCC section
251 and 252 interconnection agreement. Under a section 251/252 agreement an LEC
that receives numbers from NANPA (North American Numbering Administration)
provides TNs to smaller wireless carriers such as paging and cellular companies.
Since smaller wireless carriers do not individually require a whole NXX code
(10,000 numbers) to provide service to their customers, they obtain numbers in
blocks of 100 from the LECs.
Many Type 1 carriers such as paging companies argued that they are not
regulated by the CPUC and need not respond to the CPUC data requests. However,
the CPUC is delegated a grant of authority by the FCC to adopt statewide rules
requiring carriers to efficiently manage TNs because the FCC has deemed TNs a
public resource. For purposes of exercising the delegated authority over
numbers, the CPUC subsequently has authority over paging companies.
Accurate reporting of Type 1 utilization data by LECs and Type 1 carriers is
imperative because 310 is in number pooling. Even though excess TNs wireless
carriers hold are not eligible for number pooling, Type 1 TNs held by wireless
carriers are eligible for number pooling since any excess Type 1 TNs will be
returned to the originating wireline carrier.
8.2 AUDIT FINDINGS
As indicated in the March 310 Report, many Type 1 carriers did not submit
data to the CPUC, leaving 240,000 TNs or about 47% of the Type 1 utilization
data unaccounted for. Figure 8-1 (next page) shows the breakdowns of all
Assigned to non-reported Type-1 numbers for each LEC in 310 area code. Figure
8-1 also includes data reported by PacWest, a LEC in 310 area code17. Appendices
A-5 and A-6 show the Type 1 TN distribution of PB and Verizon by rate centers in
the 310 area code. Of the Type 1 TNs assigned, staff found that % of PB and % of
Verizon's Type 1 numbers were reported.
Staff identified ------- unused Type 1 numbers that PB erroneously reported
as unavailable. PB has confirmed that it was not billing these Type 1 carriers
and those TNs were erroneously reported. PB could not identify at the time of
audit how many of the ------- TNs it will donate but informed the staff that PB
will donate all eligible thousand blocks to the 310 number pool.
Staff found Verizon did not erroneously report available Type 1 TNs as
unavailable. Staff found 39 delinquent Type 1 carriers. (for a list, see
Appendix A-6).
Source: March 310 Report data
8.3 STAFF RECOMMENDATIONS
1. Delinquent wireless carriers holding Type 1 numbers who still have
not reported on their number utilization should immediately submit TN
utilization data. These carriers should also be required to return any excess
available TNs to the originating LECs. The Type 1 wireless carriers that fail to
respond to this final data requests should be subject to CPUC directed penalties
and sanctions.
2. LECs providing Type 1 numbers need to keep accurate information
records of Type 1 carriers including contact names and addresses, TN inventory,
and business status. When a Type 1 carrier goes out of business it must report
its status to the originating LEC and return all of its TNs to the originating
LECs.
3. When LECs receive returned Type 1 numbers, they should review the
effect of those additional available numbers on their six month inventory and
donate any excess eligible thousands blocks to the Pooling Administrator or
NANPA as applicable.
APPENDICES
A-1 CARRIER DATA SOURCE AND AUDIT METHODOLOGY
PACIFIC BELL
Data Source and Number Inventory Systems
Staff investigation of the TN tracking systems found that PB uses three
different but interconnecting systems: (a) the end-office switch database, (b)
the TN inventory management, and (c) the customer billing. The end-office switch
database maintains all active (connected with a dial tone) TNs. The TN inventory
management system tracks the status of all available TNs. The billing system
tracks customer billings. PB compiled the utilization data manually from its
three internal systems for its report to the CPUC in November 1999.
PB's three TN inventory systems often did not match to reflect accurate TN
status. For example, if a TN (310) 123 4567 appeared as assigned in the billing
system the same TN (310) 123 4567 appeared as available in its inventory
management system. Due to discrepancies found in its internal systems, PB
contracted (between August 1999 and October 2000) with an outside vendor to
reconcile PB's three TN inventory systems mismatch (TN Bashes). TN Bashes
reconciled TN inventory management and billing systems against PB's end-office
switch system.
Audit Methodology
PB did not maintain a backup copy used to develop the utilization data
submitted to CPUC. Additionally the PB employees responsible for compiling the
310 utilization data were no longer available during the audit. The staff used
two comparison methods to conduct PB's TN audit.
Method (1) Comparison of PB reported TNs in 310 utilization data
(November 1999) to the TNs reported in the FCC NRUF18 utilization data (June
2000). Staff analyzed TNs in the assigned, administrative, reserved, aging, and
Type 1 TNs that PB reported for the March 310 Report and the NRUF Report. In
comparing the utilization data for the March 310 Report with the NRUF
utilization data, the staff took into consideration differences in reporting
requirements and reporting dates for these two reports.
Method (2) Comparison of PB reported TNs for the March 310
Report (November 1999) to TNs found in completed TN Bashes from PB's internal
database systems (August 1999 to October 2000). Staff compared data from the TN
Bashes with the March 310 Report data to look for significant differences. The
TN Bashes provided data on sixteen switches and seventy-two percent of PB's
Assigned TNs. The TN Bashes showed the Assigned, Intermediate, and
Administrative TNs as working numbers and the Reserved, Aging, and Available TNs
as not working numbers. At the time of March 310 Report data submission
(November 1999), PB could not reconcile all the errors in its systems through TN
Bashes. Based on its investigation, staff concluded PB's end office switch
system was more reliable than the other two systems.
VERIZON
Data Source and Number Inventory Systems
The staff found that Verizon's utilization data was filed by its Telephone
Number Administration Center, (TNAC) based in Lewisville, Texas. The TNAC
handles the provisioning, activation, and maintenance of Verizon's TNs
nationwide and performs activities related to Local Number Portability and
Number Pooling.
Verizon prepared its November 1999 utilization data using the Mechanized
Assignment & Record Keeping (MARK), a mainframe based system for its TN
inventory administration. However, in April of 2000, Verizon changed that
system, to a web-based client server application called the Activation,
Assignment & Inventory System (AAIS). The new AAIS maintains information for all
telephone numbers, switch data, outside plant facility and terminal information.
The staff verified that Verizon's MARK system maintained 17 different
categories of TNs. Verizon reclassified those 17 categories of TNs into
respective thousand blocks to conform to the CPUC defined TN categories for the
March 310 Report. Staff tested the source data from the MARK system via an
extracted file. The extracted file contained each TN range by quantity and not
by individual phone numbers. The extracted file also contained the customer
names and telephone numbers for certain classes of business customers with
Direct Inward Dial (DID) and Centrex services. Additionally the extracted file
also provided information on Verizon's administrative numbers.
Audit Methodology
The staff was able to associate some customer names with actual TNs in
Verizon's telephone number inventory system. Staff found TN ranges with names
mostly for large business customers. TN ranges (consecutive TNs in a block of
numbers) that did not have names were for residential, small businesses and
other customers. The staff then grouped TNs with customer names to select an
audit sample.
Staff found that Verizon's MARK system updated TNs in "real time" to store
current data and did not keep historic data. As a result Verizon could not
provide any record to the staff to verify the status of the TNs reported in the
November 1999 utilization data. The staff used a combination of current and
archived data in verifying the status of the TNs as of November 1999. The staff
conducted detailed analysis that included reviewing the current inventory
system, customer profiles, billing, and some telephone number history archived.
In addition, staff requested and obtained input work sheets created from the
extract file for the months of December 1999, January, September, and October
2000 and prepared a comparative analysis for these months covering all the 1000
number blocks in the 310 area code assigned to Verizon. Staff focused on the
changes that had occurred in the assigned category between the date of the
utilization report and the staff audit. This analysis helped determine which
thousand blocks needed additional review during the audit.
A. Business Customers
The staff stratified the data sample to minimize higher risks of reporting
error that could result in a minimum of 20 to a maximum of 1000 numbers being
misclassified in the utilization data submitted. Verizon automatically
classified DID/Centrex service TN ranges (20 to maximum of 1000) that had
customer names in the extract file as working and assigned for the purposes of
utilization data reporting
During the audit, staff reviewed 100% of all customers with ranges of
sequential TNs of more than 100 and randomly selected samples with 20 - 100
sequential numbers. Staff reviewed about ----------- TNs out of a total of
approximately ---- numbers. Staff examined the customer profile database for all
the business customers selected for review and confirmed the current status of
TNs and the initial service dates. For those customers with initial service
dates subsequent to November 1999 or for which a change, such as transfer,
disconnect, or new service occurred after November 1999, staff further audited
the billing records and the telephone number archive to obtain the history of
that particular number or range of numbers in order to determine the status as
of November 1999.
B. Small Business/ Non DID/ Residential Customers
The staff randomly selected approximately -- 1000 number blocks from the
remaining TN ranges of Small Business/ Non DID/ Residential customers to verify
the accuracy of these blocks reported in the utilization data. In order to do
this staff obtained the AAIS status detail and last activity detail for each of
the selected thousand blocks for review.
Staff reviewed the customer profile to verify the initial service dates for
those numbers that staff was unable to confirm from November 1999 AAIS detail.
If there was no switch activity from the initial service dates or the last
activity was prior to November 1999, then the current status is the same as the
one reported in the utilization report. In addition, the staff performed audit
procedures for those numbers reviewed with initial service dates subsequent to
November 1999 or for which a change, such as transfer, disconnect, new service
etc. occurred after November 1999. Finally staff accessed the telephone number
archives to obtain the history of a particular number in order to determine the
status as of November 1999.
In addition to the ------- TNs selected above, staff obtained another 600
AAIS extract data files in Excel spreadsheets for about ------------ numbers.
These files were part of the ranges that did not have any associated customer
names. Staff was able to confirm the November 1999 status based on 50% of the
sampled data
WORLDCOM
Data Source and Number Inventory Systems
Staff found that before the utilization data submission MCI Metro, ATS, Inc.
(MCI) and Worldcom Technologies Inc. (WC Tech.) merged as Worldcom. In November
1999 when the March 310 Report was prepared, WorldCom had two TN inventory
management systems, one each from MCI and WC Tech. MCI used a system called
Number Resource Management (NRM) and WC Tech. used a system called Telephone
Number Inventory System (TNIS). In June 2000 all TN management for MCI and
WorldCom was consolidated into the MCI NRM system. To prepare utilization data
for the March 310 Report, WorldCom extracted data from the TNIS and NRM systems
and then manually input that data into the Excel spreadsheets that were
submitted to the CPUC.
Audit Methodology
Staff used two approaches to test the accuracy of the utilization data
submitted in the March 310 Report. First, staff selected random samples from the
Worldcom database to test the reliability of the system and to verify the number
of assigned TNs reported. Because Worldcom's two systems were merged into the
MCI system in June 2000, the TN tracking was done all in the formerly MCI's NRM
system at the time of the audit. Secondly, staff compared the March 310 Report
utilization data to the FCC NRUF Report19 to investigate Administrative and
Reserved numbers. The FCC NRUF Report was pulled from the NRM system seven
months after data was submitted to the CPUC in November 1999, and after the TNIS
and NRM systems had been merged. The inventory management systems are
administered from offices in Vienna, Virginia, so the comparison tests were done
on site.
XO CALIFORNIA
Data Source and Number Inventory Systems
Staff determined that the XO California Inc. (XO - formerly Nextlink
California Inc.) 310 utilization data was assembled manually using information
pulled from three sources. The data was retrieved from (a) its Saville Telephone
Number Inventory system (Saville TNI), (b) the telephone billing history tables,
also contained in Saville (Saville Billing History), and (c) a line detail
report that was generated from its ---- switches that serve the 310 NPA. XO did
not maintain a back up copy of data used to compile the March 310 Report.
Staff verified that XO has implemented a new automated reporting system that
will maintain a back up of information in accordance with FCC guidelines in the
future. This system is designed to pull data from both the Saville systems and
the end office switch to compile future utilization data reports.
Audit Methodology
Staff selected random samples of utilization data that XO submitted for the
March 310 Report and traced those numbers to XO's Saville system. Since XO did
not maintain any backup work papers for the audit, staff performed a reliability
test by investigating actual TNs in XO's current system. Staff also compared
data that XO submitted for the FCC NRUF Report to the utilization data submitted
for the March 310 Report.
SPRINT
Data Source and Number Inventory Systems
Sprint Spectrum PCS dba Sprint PCS (Sprint) is a wireless telephone company.
Staff learned that Sprint updated its TN inventory management system each night
and made changes during the day. Further, staff found that Sprint's systems did
not maintain the data used to compile utilization data for the March 310 Report.
Staff reviewed two automated reports Sprint used from its TN inventory
management system. Those reports were combined manually and were manually input
into the spreadsheet for the March 310 Report. Sprint has one system that
controls its TNs. The TNs must be active in the billing system or the customer
will not receive dial tone. Sprint's billing system keeps historical data on
current customers, including the date the service became effective.
Audit Methodology
Staff selected a TN sample of thousand number blocks and downloaded the data
into an Excel spreadsheet. Staff compared the data in the spreadsheet to the
record shown in March 310 Report and traced those TNs to Sprint's billing
system.
AT & T WIRELESS
Data Source and Number Inventory Systems
Staff noted that AWS is the successor to AB Cellular Holding LLC (AB).
During the data submission for the March 310 Report, AB used its own billing
system called MacroCell. AB prepared the utilization data using a data dump from
its MacroCell billing system. The utilization data was manually compiled and in
some cases required manual determination of TN status.
Staff found that AWS' billing system is also called MacroCell. AB's
MacroCell system was merged into the AWS MacroCell system between March and
April 2000. Staff was told that AWS has automated its reporting system and will
submit future utilization data through its automated system.
Audit Methodology
Staff looked at AWS' MacroCell system that tracks the status of a TN
including historical data for three months. Staff also obtained a twelve-month
history for TNs that were currently in use.
Staff compared the available TNs in the AWS system with the TNs reported as
available for the March 310 Report. Staff selected a random sample of numbers as
assigned, administrative, aging, or reserved in sample blocks for the comparison
and looked at the activities on TNs during the last 12 months.
Staff spent less audit resources to verify Administrative and Reserved TNs
for reasons discussed in the Audit Findings section. Staff did not focus on
Aging TNs as AWS internal data would have changed status in the period between
data submission and data audit.
TYPE 1 NUMBERS
Audit Methodology
For the purpose of this audit staff chose to verify Type 1 numbers held by
two LECs, Pac Bell and Verizon. Staff identified Type 1 wireless carriers by
their NXX-prefix range based on non-reported data in the March 310 Report. Staff
followed up with delinquent Type 1 carriers, requiring them to return any
available numbers that are in excess of Type 1 carriers' inventory. Staff
contacted delinquent Type 1 carriers via letters, e-mails, and telephone calls
requiring them to resolve discrepancies and report complete information on their
utilization data to CPUC.
A-2 AUDIT FINDINGS OF VERIZON'S UNCONTAMINATED THOUSAND BLOCKS
Uncontaminated Ranges
Quantity.
Available Numbers
Ranges
Classified as Administrative
TOTAL
A-3 VERIZON: INVENTORY STATUS OF TELEPHONE NUMBERS BY NUMBER OF YEARS
Less Than
No of Years & Telephone Numbers In Status
Total
Inventory Status of Numbers
I Year
1-3 Yrs.
3-4 Yrs.
4-5 Yrs.
> 5 Yrs.
Reserved- General Purpose
Reserved To Order
Suspended
Temporary
Soft Dial Tone
Total Telephone Numbers
The above inventory excludes Business Customers, as the staff could not
determine the period of time they have been reserved.
A-4 DISTRIBUTION OF ALL TYPE 1 NUMBERS IN THE 310 AREA CODE
TYPE 1 NUMBER SUMMARY
Service Providers
Total Type 1 Assignment
Reported Numbers
Non-Reported Numbers
Pacific Bell
Verizon
PacWest
A-5 PACIFIC BELL TYPE 1 TN SUMMARY (BY RATE CENTER) REPORTED FOR THE MARCH
310 REPORT
RATE CENTER
ASSIGNMENTS
REPORTED
RATE
CMTN GRDN
CULVER CITY
EL SEGUNDO
HAWTHORNE
INGLEWOOD
LOMITA
SAN PEDRO
TORRANCE
TOTAL
A-6 VERIZON TYPE 1 TN SUMMARY (BY RATE CENTER) REPORTED FOR THE MARCH 310
REPORT
RATE CENTER
ASSIGNMENTS
REPORTED
RATE
LAKEWOOD
REDONDO
SANTA MONICA MAR VISTA
SANTA MONICA
WEST ANGELES
TOTAL
A-7 LIST OF DELINQUENT TYPE 1 CARRIERS
The following lists Pacific Bell, Verizon, and Pac West's T1 wireless carriers
(39) that have provided incomplete or no utilization data as of to date (this
list is as of December 2000, an update from the November 1999 status).
1. Access Paging 21. Network Services
2. Advanced Paging 22. Pacwest
3. Advantage Cellular 23. Page First Comm
4. Airtouch Cellular 24. Page Prompt
5. Airtouch Paging 25. Page U Paging
6. Action Paging 26. Pagemart
7. Beepers and More 27.Pagenet
8. Cellular Services 28. Paging Dimensions
9. CTS 29. Paging Services
10. Conxus 30. Paging Systems
11. Digitcom 31. Pronet
12. GTE Paging (now Verizon Paging) 32. Radio Call
13. Hyde Park Beepers 33. Satellite Paging
14. Hye Page 34. Southwest Paging
15. ICS 35. Touch-tel Paging
16. JPS/Onemain 36. TSR Wireless
17. LA Cellular 37. US Communications
18. Metrocall 38. US Wireless
19. Metromedia 39. Westlink
20. Mobilecom
1 Report on the 310 Area Code (March 310 Report), Telecommunications Division,
California Public Utilities Commission March 16, 2000. For the March 310 Report
carriers submitted data in November 1999. 2 Pacific Bell, Verizon California
Inc.(formerly GTE California Inc.), WorldCom Technologies Inc.(formerly MCI
Metro, ATS, Inc. and WorldCom Technologies Inc.), XO California Inc. (formerly
Nextlink California Inc.), Sprint Spectrum L.P. dba Sprint PCS, and AT & T
Wireless Services (formerly AB Cellular Holding, LLC.). 3 Audit adjustments of
214,000 TNs are as follows: Pacific Bell - Verizon - , and Worldcom - The totals
are rounded up figures. 4 Assigned TNs: Any working TNs, non-working TNs held by
wireless companies assigned to customer equipment, and service orders for TNs
that have been pending less than or equal to 30 days. 5 Administrative TNs:
Working TNs used for internal business purposes, test numbers, E911 numbers 6
Reserved TNs: TNs for which service order is pending for customers over 31 days.
7 Type 1 TNs: TNs that Local Exchange Carriers resell to a wireless carrier. 8
Ported Out TNs: TNs that are ported out to other carriers and reported as
Assigned. 9 FCC 00-104, CC Docket 99-200, Released March 31, 2000. 10 For Type 1
TN discussion see section 8.
11 The 45-day reserve period at the time of audit was subsequently changed to
180 days. FCC Docket No. CC 99-200 Released: December 7, 2000.
12 All Assigned, Intermediate and Administrative TNs in the 310 Utilization
Study were considered working numbers for comparison with the TN Bashes. 13 The
45 day reserve period at the time of audit was subsequently changed to 180 days
FCC NRO 12/7/00. 14 Verizon asserts that some of these customers would be
back-billed since the audit reveals that customers have not been billed when
customers initiated service. According to Verizon, some of these customers have
had service for over 10 years. However Verizon failed to explain to staff why
this billing error occurred. 15 The 45-day maximum reserve requirement has been
increased to 180 days by FCC's 2nd NRO Order, December 7, 2000. 16 For a
detailed description see Attachment A, of the CPUC ALJ Ruling regarding 310 NPA
Code Utilization Study Parameters, Nov 3, 1999. 17 See Appendix A-4 for details
of all Type 1 numbers assigned by three LECs in the 310 area code. 18 The FCC
required all carriers to provide utilization data for its Numbering Resource
Utilization/Forecast (NRUF) Report, August 2000. 19 Number Resource
Utilization/Forecast Report data was reported as of June 30, 2000.