...viable MTAS solution

Hugh Hamilton is right in that the use of digits 2 to 9 in the middle of the three-digit area code sequence will increase the number of numbering plan areas by some eight-fold. However, this will mean essentially subdividing, on average, the existing NPAs by eight.

The areas will become so small that virtually all calls will become long-distance. If the long-term numbering plan option to increase the area codes to four digits is implemented, then what's left of the NPAs will be further divided into tenths. Effectively, this will mean full eleven-digit dialing.

Because the multifunctional telecommunication addressing system (MTAS) does not affect telephone addresses, it is fully compatible with the public network protocol. There are no ambiguities. MTAS is a subscription system invisible to those who don't subscribe to its services.

Although MTAS will require considerable reprogramming as Hamilton noted, this is nothing compared with reprogramming for address portability (Telephony, April 6, page 28), which also will require network restructuring.

Hamilton also mentioned that MTASs will not accommodate rotary-dial phones.

This is correct. It is now almost three decades since tone dialing was introduced, and I don't see why new developments must be held hostage to old methodologies. It is not as if enormous investments were made in dial equipment that cannot be recovered. I feel the pain of those using rotary-dial equipment, but it is time to move ahead.

In "Forget the Carrot" (Telephony, April 6, page 5), Mr. Vittore draws the wrong conclusion from his apt comparison of Bell companies to children breaking family rules. The RHCs do act like Mr. Vittore's scheming child-sweet-talking regulators that do their best to avoid efficient and nondiscriminatory interconnection with competitive local exchange carriers.

The "family rules" for interconnection and unbundling apply to all incumbent local exchange carriers and are set forth in the telecom act's Sections 251 and 252. When the RHCs follow the rules, they will get the "carrot" of long-distance entry, pursuant to Section 271. There are no sticks to be brandished during the entry process for the simple reason that no RHC is forced to enter the long-distance business.

Regulators do have the opportunity-but not the mandate-to "punish" an RHC if, after entry, it fails to continue to meet any of the conditions required for entry. But RHCs treat this "maybe" just like young Mr. Vittore treated his indulgent mom's discipline: They do not perceive it as bad enough, sure enough and swift enough to compel their good behavior. Now, bad RHC behavior towards competitors is routine, including but not limited to trunk blocking, failure to turn up circuits, premature disconnects and refusal to compensate competitors for terminating traffic.

The inescapable conclusion is: We need "sticks" now, not only after RHCs get their long-distance wishes. Regulators should mete out swift justice each time an RHC (or any incumbent LEC) fails to meet its Section 251 obligations to provide service to rival local exchange carriers "at least equal in quality" to that which they provide themselves. Meeting 251's performance parity principle is the most important requirement for RHC 271 approval.

Failure on any performance parity measure should trigger immediate, large, non-negotiable fines-all the time, everywhere, starting now. Such swift justice should stop the RHCs from gaming the regulatory process. It would test whether the RHCs actually want to enter the long distance business or simply want to retain their local telecommunications stranglehold.