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If you need the complete document, download the WordPerfect version or Adobe Acrobat version, if available. ***************************************************************** Before the Federal Communications Commission Washington, D.C. 20554 ) In the Matter of ) ) Pennsylvania Public Utility Commission ) CC Docket No. 96-98 Petition for Expedited Waiver of) 47 C.F.R. Section 52.19 for ) Area Code 412 Relief ) ) ORDER Adopted: April 3, 1997 Released: April 4, 1997 By the Chief, Common Carrier Bureau: I. INTRODUCTION 1. On February 18, 1997, the Pennsylvania Public Utility Commission ("PaPUC") filed a Petition for Expedited Waiver of Section 52.19 of the Commission's rules to permit 7-digit dialing within area codes affected by the proposed 412 area code overlay covering Pittsburgh and the surrounding metropolitan area ("Petition" or "Petition for Waiver"). According to section 52.19(c)(3)(ii), a state commission may implement an area code overlay, subject to mandatory 10- digit local dialing by all customers between and within area codes in the geographic area covered by a new overlay code. The PaPUC asked the Commission to consider its petition on an expedited basis because the implementation date for the overlay is May 1, 1997. For the reasons discussed herein, the Petition is denied and the PaPUC must direct local exchange carriers (LECs) to institute 10-digit dialing by November 1, 1997. II. BACKGROUND 2. Section 251(e)(1) of the Communications Act of 1934 ("the Act"), as amended by the Telecommunications Act of 1996 ("1996 Act") gives the Commission "exclusive jurisdiction over those portions of the North American Numbering Plan that pertain to the United States," and allows the Commission to delegate to state commissions or other entities "all or any portion of such jurisdiction." In the Local Competition Second Report and Order, implementing a portion of Section 251 of the Act, the Commission, acknowledging that "states are uniquely situated to determine what type of area code relief is best suited to local circumstances," authorized states to continue the task of overseeing the introduction of new area codes, and to choose between area code splits or area code overlays based upon which would provide the best form of area code relief. The Commission, however, set out specific rules with respect to how area code overlays could be implemented. One of those rules, adopted to ensure that competitors, including small entities, do not face competitive disadvantages, requires "mandatory 10-digit dialing by all customers between and within area codes in the area covered by the new [overlay] code." 3. Although most of the rules contained in the Local Competition Second Report and Orderbecame effective on October 7, 1996, 30 days after the publication of the order in the Federal Register, paragraph 402 stated that "all authorizations for state commissions, Bellcore, and local administrators, including LECs, to perform certain numbering administration functions, consistent with the terms as defined in this Order, are effective immediately." Those numbering administration functions included the Commission's (i) authorization to states to continue resolving matters involving the implementation of new area codes; (ii) authorization to states to initiate area code relief planning; and (iii) interim delegation to states, incumbent LECs, and Bellcore to continue to perform any numbering administration functions they were already performing, pending transfer to the new North American Numbering Plan Administrator (NANPA). The Commission specifically stated that each state's method of implementing new area codes must be consistent with the Commission's guidelines for numbering administration, including the guidelines enumerated in the Ameritech Order and in the Local Competition Second Report and Order, which requires mandatory 10-digit dialing in the case of implementation of an all-services overlay. 4. On June 12, 1996, the PaPUC adopted an order that scheduled an all-services overlay for the 412 (Pittsburgh) Numbering Plan Area (NPA) ("412 Area Code Order"). The 412 Area Code Order, which allowed 7-digit dialing within each area code in the geographic area covered by the overlay, was entered on September 12, 1996. In the 412 Area Code Order, the PaPUC stated that "all LECs shall continue the use of seven-digit dialing within each area code to the extent technically feasible and for as long as it remains feasible. . . .[t]en-digit dialing may become permissive with the institution of the overlay code, but it should not become mandatory until necessary." The 412 Area Code Order was based upon the prediction that the NXXs within the 412 area code would all be assigned by June 30, 1997. The implementation date of the overlay is scheduled for May 1, 1997. 5. Numbering Plan Areas ("NPAs") are known commonly as area codes. The second three digits of a telephone number are known as the NXX code or Central Office code ("CO code"). Typically there are 792 NXX codes available for assignment in an area code (every possible combination of three digits excluding numbers beginning with a 0 or a 1 and numbers ending with 11). Each NXX code has approximately 10,000 numbers available for assignment to individual customers. NXX codes are assigned to particular rate centers in an area code; carriers base charges for telephone calls on the distance between the rate center from which a call originates and the rate center at which the call terminates. A carrier with a particular NXX can only serve customers associated with the rate center to which the NXX is assigned. In the United States, twelve regional NXX code administrators make NXX code assignments. The dominant local exchange carrier, in this instance Bell Atlantic-Pennsylvania (Bell Atlantic), serves as the NXX code administrator for area code 412. Thus, under this arrangement, all telecommunications providers in the 412 area code requiring NXX codes must request them from Bell Atlantic. III. PLEADINGS 6. In its Petition, the PaPUC contends that the Commission should waive its 10-digit dialing requirement because: (1) the implementation of interim and long-term number portability resolves any anti-competitive effects that could result from permissive 7-digit dialing in an NPA overlay; (2) local dialing conditions suggest that competitive LECs, as a group, have been assigned 202, or 27%, of the NXX codes in the 412 NPA; and (3) competitive LECs and other competitors will control approximately 260 NXXs by June 30, 1997. This, the PaPUC asserts, would obviate any anti-competitive consequences that might flow from 7-digit dialing because competitive LECs would be able to assign numbers in the 412 NPA to customers. 7. Bell Atlantic, supporting the PaPUC's Petition for Waiver, states that carriers have been implementing the arrangements ordered by the PaPUC and that it would be impossible to implement an overlay with 10-digit dialing under the current schedule. Through Bell Atlantic's advertising, consumers have been receiving information about dialing calls after the new area code opens, and will be confused if the plan is changed. Bell Atlantic asserts that the problems identified with overlays implemented with 7-digit dialing do not exist in the 412 NPA because approximately 260 NXX codes will have been assigned in the existing NPA to competitive LECs and wireless carriers, undercutting the assumption that those providers will not be able to obtain numbers in that NPA. Bell Atlantic states that number portability will allow those carriers' customers to keep their existing 412 numbers when they switch from another service provider. BANM, a provider of wireless service, also states that granting the waiver is in the public interest because, if the PaPUC did not receive a waiver and were to order a geographic area code split, this action could delay area code relief and prevent new customers from obtaining service. A split would force cellular customers and companies in the new area code to reprogram all cellular telephones, further impairing implementation of NPA relief in Pittsburgh. 8. Several Pennsylvania state senators submitted letters stating that they favor competition in the telecommunications market, but do not believe that making customers in the 412 area code surrender the ease and familiarity of 7-digit dialing is necessary to promote competition. The senators further state that the conditions in the 412 NPA justify a waiver. Several small incumbent LECs filed similar letters, stating that there are only about 40 NXX codes left in the 412 NPA, and urging that the Petition be granted quickly to permit network preparations and customer education. 9. Several commenters opposing the waiver assert that the PaPUC has failed to show special circumstances to support its request. Aerial Communications, Inc., the subsidiary of which, APT Pittsburgh, is a licensee for broadband Personal Communications Services ("PCS") in the Pittsburgh MSA ("APT Pittsburgh"), states that the dialing disparity resulting from the retention of 7-digit dialing in the area covered by the overlay would favor incumbent LECs and incumbent cellular carriers in violation of sections 332(a)(3) and 253(a) of the Act. Regarding number portability, some commenters argue that interim number portability will provide inferior service to customers of competitive LECs, and therefore will not ameliorate the anti-competitive effects of 7-digit dialing. APT Pittsburgh notes that long-term number portability will not be deployed in the Pittsburgh area in time to reduce the anti-competitive effects of the 412 overlay because long-term number portability is not scheduled to occur in the Pittsburgh area until April 1998 for wireline and June 1999 for wireless carriers. AT&T contends that number portability does not ameliorate the anti-competitive effects of overlays because incumbent LECs will have a significant quantity of numbers in the old NPA, while competitive LECs will assign numbers chiefly from the new NPA. Also, APT Pittsburgh states that there must be adequate customer awareness for number portability to ameliorate the anti-competitive effects of overlays. Incumbent LECs and wireless providers, however, have little incentive to provide that education. 10. TCG states that the PaPUC's information concerning NXX distribution in the old NPA is misleading because it does not indicate that many of the NXXs were distributed to wireless carriers, and it does not account for the fact that the 412 NXXs are confined to geographically specific rate centers. APT Pittsburgh states that new wireless entrants may not have fully deployed their networks by June 30, 1997, and may not be able to request a 412 NXX by that time. Further, APT Pittsburgh asserts that incumbent LECs and incumbent wireless providers can warehouse numbers in the 412 NPA and can reuse numbers returned to them when customers move or change carriers. AT&T contends that in its filing the PaPUC has not provided information such as the number of competitive LECs and other carriers seeking or projected to seek NXX codes in the 412 NPA, what rate the competitors will enter the market, or how quickly they are predicted to gain market share. Further, AT&T notes that incumbent LECs will control over two-thirds of the NXX codes in the old NPA, with Bell Atlantic controlling the bulk of NXX resources. In contrast, a number of competitive LECs will share the 260 NXXs allocated to competitive LECs, and no competitive LEC will have parity with Bell Atlantic. 11. TCG states that the PaPUC knew that its order did not comply with the Commission's requirements for overlays when the order became effective, but waited seven months to request a waiver. TCG also states that the PaPUC's delay does not constitute good cause for granting the waiver, because the PaPUC has had notice of the Commission's 10-digit dialing requirement since August 8, 1996. Parties opposing the waiver are not persuaded by Bell Atlantic's concern that it will have to educate consumers about 10-digit dialing and state that the latter's concern illustrates that, if these burdens are imposed only on new entrants' customers, the new entrants will suffer anti- competitive effects because Bell Atlantic's customers will be able to dial seven digits to make calls within the old NPA. 12. In response to BANM's argument that denial of the waiver could result in adoption of a geographic split that necessitates the reprogramming of wireless telephones, commenters argue that the PaPUC is unlikely to revisit the issue of a split and that, if it did implement a split, the impact of reprogramming would affect all wireless carriers equally. Without 10-digit dialing, however, there would be an anti-competitive burden on new entrants that Bell Atlantic would not bear. Commenters also note that granting the waiver could lead to similar requests from other states, causing a strain on the Commission's resources and time. WorldCom Inc. (WorldCom) asserts that the waiver could harm the development of local competition because, if they know a waiver is possible, incumbent LECs may create artificial numbering shortages to obtain extraordinary approval of an anti-competitive overlay plan. 13. In its Reply Comments, the PaPUC contends that the record upon which it based its decision indicated that customers preferred to retain 7-digit dialing, and that 10-digit dialing will cause permanent inconvenience to customers. The PaPUC argues that interim and permanent number portability and the numbers of NXXs available to competitive LECs in the 412 area code diminish the harm to competition of the overlay with 7-digit dialing and constitute special conditions justifying a waiver of the 10-digit dialing requirement. The PaPUC states that it has approved applications of approximately 15 competitive LECs, not all of which intend to provide service on a statewide basis and some of which will initially offer service on a resale basis and therefore will not need separate NXX codes. The PaPUC states that it is aware of six approved facilities-based providers that may offer service in the Pittsburgh area, only two of which (MCI and TCG) have requested NXXs in the 412 area code. Because NXX code assignment procedures require that requests for codes be made within six months of the date the competitive LEC needs the codes, the PaPUC states that it does not anticipate that any facilities-based competitive LECs other than MCI and TCG will operate in the Pittsburgh area before the fourth quarter of 1997. Therefore, the PaPUC argues, permanent number portability may be available before most competitors are offering service to customers. IV. DISCUSSION A. In General 14. Under Section 1.3 of the Commission's rules, the Commission may exercise its discretion to waive a rule where there is "good cause" to do so. That discretion, however, "does not contemplate that an agency must or should tolerate evisceration of a rule by waivers." Rather, petitioners generally face a "high hurdle" to show that a waiver is justified. A waiver of the rules is appropriate if special circumstances warrant a deviation from the general rule and such deviation will serve the public interest. Examples of special circumstances the Commission may consider include hardship imposed by the rule's enforcement, equity, or more effective implementation of overall policy on an individual basis. Further, a decision to grant a waiver must be based on articulated, reasonable standards that are predictable, workable, and not susceptible to discriminatory application. 15. In the Local Competition Second Report and Order, the Commission required mandatory 10-digit dialing for all local calls in areas served by overlays to ensure that local dialing disparity does not deter competition. The Commission explained that competing exchange service providers, most of which would be new entrants to the market, would have to assign to their customers numbers in the new area code while incumbent LECs would be able to assign to their customers numbers in the old area code. The competitive LECs' customers in the new overlay code would have to dial 10 digits much more often than the incumbent LEC's customers in the old area code, thereby making it less attractive for customers to switch to competitive LECs. 16. The PaPUC presents several arguments to show special circumstances justifying waiver of the Commission's 10-digit local dialing requirement in conjunction with the implementation of an area code overlay. These include arguments: (1) that number portability will resolve the anti- competitive effects of an NPA overlay that allows 7-digit dialing; (2) that NXX distribution in the 412 NPA will ameliorate the anti-competitive effects of 7-digit dialing; (3) that the convenience of allowing 7-digit dialing within local area codes justifies the waiver; and (4) that the short time remaining for overlay implementation justifies the waiver. We have reviewed these arguments carefully and, for the reasons set forth below, find that, whether taken individually or together, they fail to show good cause for waiving the 10-digit dialing requirement. In addition, the PaPUC has not shown that the deviation from the rule requiring 10-digit dialing it requests would serve the public interest. In fact, a waiver of the 10-digit dialing requirement would undermine the pro- competitive national policies embodied in the 1996 Act and underlying the Commission's 10-digit dialing requirement for area code overlays. B. Number Portability Argument 17. In the past, a customer would have been forced to relinquish his old telephone number if he changed his local service provider. When fully implemented, number portability will allow customers to keep their telephone numbers when they change local service carriers. For this reason, number portability will alleviate some anti-competitive effects of an overlay because a customer will be able to change service providers without having to change his or her area code; changing providers will thus become less inconvenient. Businesses changing service providers will not have to change stationery, business cards, and other advertising materials; individuals will not have to inform those calling them frequently of a number change. The PaPUC states that number portability without a 10-digit dialing requirement ameliorates the anti-competitive dialing disparities caused by an overlay, and therefore eliminates the need for that requirement. Neither interim nor long-term number portability, however, will eliminate any of the dialing disparities that are caused by area code overlays. Admittedly, customers will be able to keep their telephone numbers when they change local service carriers, and would, without 10-digit dialing, be able to continue dialing seven digits to make calls within the old NPA. For an area code overlay without 10-digit dialing, however, there will always be a dialing disparity between customers in the old code and customers in the new code. As a consequence, the advent of number portability will not, and does not, constitute a special circumstance that would justify granting the PaPUC's requested waiver. 18. Interim number portability, as stated above, does not eliminate the dialing disparity inherent in an overlay implemented without mandatory 10-digit dialing. Contrary to the PaPUC's assertion, technical drawbacks inherent in implementing interim number portability prevent interim number portability from overcoming the anti-competitive aspects of a NPA overlay with 7-digit dialing. Interim number portability uses call forwarding services such as remote call forwarding ("RCF"), a technology that creates a slight dialing delay for customers as their calls are forwarded from the old number to the new number. In addition, customers receiving interim number portability through RCF lose certain local area signalling services, such as caller ID. Competitive LECs can only offer these services if the customer is willing to surrender his or her old telephone number, placing the competitive LECs at a disadvantage. Also, the transmission quality of calls for customers using RCF may be degraded. Thus, even though it allows a caller to retain his or her 7- digit number when the caller changes carriers, interim number portability does not create a level playing field between incumbent LECs and competitive LECs. 19. Although the Commission recognized in the Local Competition Second Report and Order that long-term number portability would "reduce the anti-competitive impact of overlays," long-term number portability does not address the anti-competitive impacts of overlays addressed by the 10-digit dialing requirement we imposed. Long-term number portability will reduce some anti-competitive effects of overlays by allowing existing incumbent LEC customers to retain their telephone numbers, including the area code, if they change to a competitive LEC. Nonetheless, dialing disparity would still exist between the old NPA and the new NPA that would be detrimental to competitive LECs seeking to compete with Bell Atlantic. New customers in the area and existing customers who obtain additional lines would not "port" numbers from the old NPA. Because Bell Atlantic is likely to have more numbers in the old NPA than competitive LECs, it will be better able to assure its new customers the convenience of 7-digit dialing for the majority of their local calls if the waiver is granted. Admittedly competitive LECs have NXXs in some rate centers in the 412 NPA, and consequently may be able to assign numbers in the 412 NPA to some customers. In some cases, Bell Atlantic also may have to assign numbers in the new NPA in particular rate centers because it will have no 412 numbers available. Overall, however, it is more likely that the incumbent LEC will be able to assign a number in the old NPA because the incumbent LEC will have more NXX numbers in more rate centers in the 412 NPA than competitive LECs will have. As a consequence, for the new customers' lines and the existing customers' second lines in the new NPA, there will continue to be a dialing disparity for calls to the 412 NPA. Thus, in the absence of mandatory 10-digit dialing, a customer could find it less attractive to obtain service from a competitive LEC solely because Bell Atlantic and other incumbent LECs will have access to a larger pool of NXXs in the old NPA. 20. The PaPUC states that the overlay code is to be opened May 1, 1997. Because implementation of long-term number portability in Pittsburgh may not occur until late June 1998, it would probably be a minimum of a year between the opening of the overlay code and the availability of long-term number portability. This delay significantly reduces any immediate pro- competitive, ameliorative, effects that long-term number portability might otherwise have on the use of 7-digit dialing proposed by the PaPUC. C. NXX Code Distribution Argument 21. The PaPUC also states that local dialing disparity will not occur in the Pittsburgh overlay because the Bell Atlantic Code Administrator has told the PaPUC that by June 30, 1997, approximately 260 NXXs (and the corresponding 2.6 million numbers) will be available to competitive LECs and other providers in the 412 NPA. These facts do not show special circumstances justifying a waiver of the 10-digit dialing requirement because, in spite of the availability of NXX codes to them, competitive LECs will still face a competitive disadvantage in assigning numbers from the old NPA. Assuming that the 2.6 million number figure is correct, the corresponding 260 NXXs to which those numbers are attached will be divided among the competitive LECs and wireless providers. Bell Atlantic and the other incumbent LECs will continue to have a competitive advantage under the PaPUC overlay plan. Bell Atlantic, in particular, has more NXXs, and may, therefore, be more likely to have numbers available to offer customers in the 412 area code. As of December 31, 1996, Bell Atlantic had 382 NXXs (51% of those available) in the 412 code. More importantly, Bell Atlantic is more likely to have NXXs in each rate center, whereas individual competitive LECs may only have NXXs in a few rate centers, and consequently may only be able to serve customers in limited geographic areas within the 412 area code, even though these competitive LECs may have many unassigned line numbers within their particular NXXs. Moreover, it is unlikely that the competitive LECs will be able to obtain NXX codes in all rate centers of the 412 NPA. Thus, as competitive LECs expand their service areas, they will have to obtain NXXs from the overlay area code, and dialing disparity between incumbent LECs and competitive LECs will continue. We also note that, until transfer of NXX code assignment functions to a neutral NANPA is achieved, Bell Atlantic will continue to assign NXX codes to competitive LECs and itself. 22. For all-services area code overlays, in addition to mandatory 10-digit dialing between and within the area codes to be overlaid by the new code, the Local Competition Second Report and Order requires the availability of at least one NXX code for every existing telecommunications carrier authorized to provide service in the area in which the new overlay area code will be introduced 90 days before that introduction. For the reasons set forth in paragraph 21, a competitive LEC's current possession of NXXs in the 412 code is not sufficient to constitute special circumstances that would justify granting the requested waiver of the 10-digit dialing requirement. D. Customer Confusion Argument 23. The PaPUC, various consumers, and Pennsylvania state senators assert that 10-digit dialing will create customer confusion. This argument fails to show special circumstances justifying a waiver of the 10-digit dialing requirement because the "confusion" that arises from area code relief plans is a nationwide issue, affecting people throughout this country any time area code relief is necessary. It is not an occurrence that is unique to the 412 area code. The implementation of any new area code, whether it is implemented through an overlay, a geographic split, or a rearrangement of existing area code boundaries, is initially confusing not only to customers in the affected area but also to those who call them from outside that area. The retention of 7-digit dialing may alleviate confusion for some customers because they could dial seven digits for calls in the old NPA, which, at least initially, will constitute the majority of their calls. As the PaPUC itself recognizes, however, any relief resulting from the retention of 7-digit dialing would be, at best, temporary. As more area codes are depleted and need to be relieved, 10-digit dialing for local calls will become inevitable. E. Insufficient Compliance Time Argument 24. Finally, the PaPUC asserts that there is insufficient time for carriers to accomplish the technical and central office changes required to support 10-digit dialing within the area to be served by the overlay code before May 1, 1997, the date on which that code is to be opened. Although the PaPUC adopted the 412 Area Code Order on June 20, 1996, it should have been aware of the Commission's 10-digit dialing requirement before its entry of the 412 Area Code Order on September 12, 1996. Indeed, the PaPUC filed a Petition for Reconsideration of the 10-digit dialing requirement on October 7, 1996, but it did not file its Petition for Expedited Waiver until two and a half months before the implementation date for the overlay. Under these circumstances, the short time remaining for overlay implementation does not, in and of itself, constitute grounds for a waiver of the 10-digit dialing requirement. 25. Bell Atlantic and several smaller incumbent LECs have also argued that insufficient time remains before May 1, 1997 to adjust their networks for 10-digit dialing. Further, the PaPUC asserts that sufficient time must be allowed for customer education. Bell Atlantic and other commenters have stated that customer "education" has begun, and they have already informed 412 area customers that they may retain 7-digit dialing in the 412 area code. Based on the current schedule for area code relief, we will allow carriers until November 1, 1997 to make all required modifications to switches, perform all other necessary technical tasks, and educate consumers about 10-digit dialing. This will provide approximately seven months from adoption of this order for these tasks to be completed. Mandatory 10-digit dialing must be in place by November 1, 1997 for the overlay relief plan. F. Summary 26. In summary, we find that the PaPUC has not shown good cause for granting a waiver of the 10-digit dialing requirement. The requested waiver, if granted, would create a dialing disparity in the area to be affected by the overlay. This disparity would create hardship for new entrants entering the Pittsburgh market and would undermine the pro-competitive objectives underlying the Commission's 10-digit dialing requirement for area code overlays. Such results would not be in the public interest because customers ultimately would pay the price for the lack of competition in the telecommunications marketplace. In addition, neither the PaPUC nor the supporting commenters demonstrated special circumstances that warrant a deviation from the general rule, nor that the deviation requested by the PaPUC will serve the public interest. Because it has failed to meet the criteria for a waiver articulated in WAIT Radio and Northeast Cellular, the PaPUC's Petition for Expedited Waiver is denied. V. ORDERING CLAUSES 27. Accordingly, IT IS ORDERED, pursuant to Sections 0.91, 0.291 and 1.3 of the Commission's rules, 47 C.F.R.  0.91, 0.291 and 1.3, that the Petition for Expedited Waiver of Section 52.19 of the Commission's rules, 47 C.F.R.  52.19, filed by the Pennsylvania Public Utilities Commission, IS DENIED. 28. IT IS FURTHER ORDERED, pursuant to the authority contained in Sections 4(i) and 251(e)(1) of the Communications Act of 1934, as amended, 47 U.S.C.  154(i) and  251(e)(1), and pursuant to Sections 0.91 and 0.291 of the Commission's rules, 47 C.F.R.  0.91, 0.291, that, if an area code overlay is implemented in the 412 NPA on or after May 1, 1997, carriers operating within the area served by the proposed overlay must modify switches, perform other necessary technical tasks, and educate consumers about 10-digit dialing by November 1, 1997. 29. IT IS FURTHER ORDERED, pursuant to Section 0.91 and 0.291 of the Commission's rules, 47 C.F.R.  0.91 and 0.291, that the MOTION FOR LEAVE TO FILE LATE-FILED REPLY COMMENTS filed by the Pennsylvania Public Utilities Commission IS GRANTED. 30. IT IS FURTHER ORDERED, pursuant to Section 408 of the Communications Act of 1934, as amended, 47 U.S.C.  408, that this Order shall be effective immediately upon release. FEDERAL COMMUNICATIONS COMMISSION Regina M. Keeney Chief, Common Carrier Bureau APPENDIX Parties Filing Comments Aerial Communications, Inc. and its subsidiary APT Pittsburgh Limited Partnership Allegheny Intermediate Unit Allegheny Media AT&T Corporation Bell Atlantic NYNEX Mobile, Inc. Senator Albert V. Belan (Senate of Pennsylvania) Bentleyville Telephone Company Senator Leonard J. Bodack (Senate of Pennsylvania) Citizens Telephone Company of Kecksburg Senator Melissa A. Hart (Senate of Pennsylvania) Hickory Telephone Company Senator Richard A. Kasunic (Senate of Pennsylvania) Mariana Scenery Hill Telephone Company The Honorable Frank Mascara (U.S. House of Representatives) MCI Telecommunications Corporation North Pittsburgh Telephone Company Sprint Corporation Richard A. Stafford c/o Pennsylvania Economy League Senator Patrick J. Stapleton (Senate of Pennsylvania) Senator J. Barry Stout (Senate of Pennsylvania) Teleport Communications Group Inc. Three Rivers Area Labor Management Committee Senator Jack Wagner (Senate of Pennsylvania) WorldCom, Inc. B.J. Leber, Executive Director Communications and Outreach WQED Pittsburgh Parties Filing Reply Comments Aerial Communications, Inc. and its subsidiary APT Pittsburgh Limited Partnership AT&T Corporation MCI Telecommunications Corporation Pennsylvania Public Utilities Commission Teleport Communications Group Inc. U S West