Staff at the Department of Public Service (the administrative arm of the New York Public Service Commission) drafted a report on February 27th regarding the need for "area code relief" for the 315 Number Plan Area ("NPA"). The Staff Report was officially released by the Public Service Commission ("Commission") with a Notice inviting public comment on March 3rd, followed by a press release on March 6th. The press release asserts that
The 315 area code that has served central New York since the early 1950s is running out of assignable telephone numbers, and implementation of a new area code is required.The DPS Report proposes several options to ensure that central and northern New York State does not run out of numbers. That is, various area code split scenarios (taking the existing area code and breaking it into two areas with one keeping 315) and an overlay option (where current customers all keep their telephone number, but new customers would receive a telephone number from the new area code and everyone within the existing 315 NPA would need to dial 11 digits in order to call anyone else) have been proposed. Interested parties were asked to select which option they prefer, the Commission would consider the Staff Report and comments, and an Order would be issued directing how the number shortage should be resolved. Comments are due on March 26th, with replies due April 4th.
Very straight forward. The Commission is using a process that has been successfully employed numerous times around the state. In recent years, Long Island was split, the Catskills were broken away from Westchester County, a new code was added to New York City, and Buffalo and Rochester were given their own NPA codes. As expensive and inconvenient as it is for consumers and as difficult and expensive as it is for the telephone companies to implement, we all take part to make sure we don't run out of telephone numbers. That could cause dire economic consequences if the North American Numbering Plan ever became exhausted.
What's Unique About 315?
However, the situation in the 315 NPA raises many issues not seen in these other more populous areas so that selecting a relief path (the aforementioned proposed splits or overlay) should not even be on the table. The consideration of splits or an overlay should be brought to a complete halt and a full investigation started. The costs and inconvenience to residential and business customers are real -- cell phones will need to be reprogrammed, calls across the street will require 11 digit dialing, business cards and letterhead stationery will need to be reordered, etc. -- and are unnecessary based on the information available.
The underlying, preliminary question that needs to be answered before the expense, difficulty, and inconvenience of area code relief begins is this: Where did the all the numbers go?
Let's start with some facts and figures about the 315 NPA. It consists of all of Onondaga, Wayne, Madison, Oswego, Herkimer, Lewis, Jefferson, and Oneida Counties, most of St. Lawrence and Cayuga, about half of Yates and Seneca, and pieces of Cortland, Chenango, Hamilton, Fulton, Ontario, and Otsego Counties. Beautiful country, but with the exception of Syracuse, Utica, and Watertown, not known as a major population center. In fact, the 2000 U.S. Census states that there are only about 1.4 million people living in the area, with about 620,000 households.
According to the North American Numbering Plan Administrator, the group responsible for the telephone numbering scheme for the United States, Canada, and the Caribbean, there are nearly seven million telephone numbers designated for the 315 NPA. There are 697 central office codes, or exchange codes, in 315, of which, 671 have been assigned to carriers to distribute the telephone numbers to customers.
According to the Staff Report, there are 792 central office codes in 315, a count which must include codes that have not even been identified for usage yet. Of these 792 central office codes, the Report states that approximately 656 of these have already been assigned, leaving only 136 codes left. With 10,000 numbers per central office code (NXX-0000 through NXX-9999), that's 1,360,000 telephone numbers remaining. While that may sound like a lot, considering that it can take time to make the area code relief effective, it's not too early to start.
That is, it would be time to declare the 315 area code in jeopardy if these numbers were accurate -- and true. By using the Staff's math to this point, the assumption is that the 1.4 million residents (including infants and children too young to have their own cell phone) and the 620,000 households have taken 6,560,000 telephone numbers. Of course they have not. Most, if not all, of these 656 codes have not been exhausted and many, many, many numbers remain available.
We know this because the Staff Report continues by stating
Of the approximate 8 million assignable seven-digit telephone numbers in the 315 area code, approximately 2.7 million are currently in use.So, why is the Commission proposing to disrupt everyone's life in the 315 NPA when only 34 percent of the numbers are in use and 66 percent are still available?
How can 83 percent (656 of 792) of the central office codes be assigned, yet only 34 percent (2.7 million of eight million) of the telephone numbers contained in those codes be in use?
PULP believes it is time for a full investigation of this unexplained anomaly.
Numbering Relief Authority in New York
The state Commission was granted authority to oversee numbering resource management by the FCC in 1999 and began to implement what is known as thousands block pooling in 2000. Under thousands block pooling, instead of a carrier receiving an entire central office code of 10,000 numbers for a single location (of which they may only need a few hundred), they would receive just 1,000 and the entire code could be shared by up to 10 different carriers. Unused "thousands blocks" would be placed in a pool for other carriers to request when they reach 75 percent saturation of their own block. By mandating thousands block pooling throughout the state and requiring unused blocks to be placed in the pool, New York has been able to stave off area code relief for a significant number of years, most notably in 518 which almost ran out of numbers in 2002. Thousands block pooling has been a success for both consumers and the carriers.
Now we have a situation in the 315 NPA which defies logic. An area with enough telephone numbers to give each man, woman, and child nearly six telephone numbers should not require area code relief.
Let's look at the numbers.
Central office codes can only be used in their designated rate center. In a city such as Syracuse, multiple central office codes can be used throughout the city (which is its own rate center), but its suburbs have their own rate centers with their own central office code or codes. A small town like Georgetown, on the other hand, also is its own rate center, so the single code assigned there can only be used in Georgetown, even though there are less than 1,000 people living there and they have 10,000 telephone numbers available to them.
Examining the Mystery
In a footnote, Staff states its belief that low-growth rate centers (i.e., rural areas like Georgetown) under-utilize their codes, which has led to the shortage. There are about 50 single central office code rate centers like Georgetown in the 315 NPA. If each of them "wasted" 90 percent of their telephone numbers, this would only account for 450,000 of the "lost" telephone numbers. Staff does go on in its Report to recognize that thousands block pooling "has helped to alleviate some of this problem," but there is only so much pooling can accomplish in a rural community with only one service provider. That said, mathematically, rural areas are not the main culprit in this mystery.
Since the comparatively few unused numbers in rural areas can not be the basis for this purported shortage, it must apparently be a problem in the cities. Even though it is true that a central office code or thousands block in Georgetown, New York can not be used in the growth areas of 315, such as the city of Syracuse, Syracuse has 143 active codes of its own (1,430,000 telephone numbers) for a city of 150,000 people. That's nearly 10 telephone numbers for every man, woman, and child in Syracuse. In contrast, currently the 1.4 million residents of 315 use 2.7 million lines for home and business, roughly two telephone numbers per person. Utica has 46 of its own codes (460,000 telephone numbers) and has a population of 61,000. Additional "unassigned" codes, with 10,000 unused numbers in each, are available in each city as well.
So, the problem isn't that the "lost" rural codes are needed in the cities and can't be used. On top of that, the cities have numerous untapped numbering resources. Something strange is going on with the telephone numbers in the 315 NPA which has not been seen in any of the other area code relief projects around the state. Before the Commission goes down the road to determine how the residents and businesses in 315 should be inconvenienced, we need to go back to step one: whether any "area code relief" is really necessary. A full investigation needs to be launched to find the cause of this artificial shortage and resolve it before a split or overlay is ordered in 315 (the only topics the Commission is seeking comments on) and before this mystery has an opportunity to expand to other regions of the state.