March 31, 2000

Re:	Numbering Resource Optimization (CC Docket No. 99-200)

I support the steps we take in this order to implement strategies to conserve telephone numbers. I share the frustration the public is experiencing with the proliferation of new area codes. Each area code change imposes substantial costs and burdens on consumers. This order is only one step in our efforts to ensure that numbers are used efficiently. We must continue to work together with state public utility commissions, industry and consumer groups, and other interested parties to develop additional strategies to slow the rate at which new area codes are required.

I also support collecting information on number utilization from carriers so that we can ensure that numbers are being used efficiently. Nevertheless, we must recognize that reporting requirements impose a burden, especially on small, rural carriers. These carriers generally use few numbering resources, rarely seek additional numbering resources, and therefore, are not a significant cause of number exhaust problems. I am pleased that today's order recognizes the disproportionate burden of reporting requirements on small carriers by imposing fewer requirements on them. I would have preferred to exempt, from more detailed reporting, rural carriers that generally operate in areas where demand for numbers is not as great. As just one example, I would not have required rural carriers to maintain internal records of numerous subcategories of number usage. To the extent carriers consider that any of the requirements in this order impose an undue burden, I would encourage these carriers, or associations of these carriers, to seek a joint waiver.