Thursday, July 31, 2008

PULP Provides Further Proof That Area Code Changes Are Not Needed Now in the 315 Area

In December, 2007 the PSC launched a proceeding to bring “relief” to the 315 area code that serves Syracuse and all or part of eighteen counties in northern and central New York. The Commission Order claimed that its 1999 “numbering resource conservation measures, such as thousand number pooling . . . [had] extended the life of the 315 area code and made immediate relief unnecessary,” but that now 315 is finally “running out” of exchange codes (the three numbers dialed after the area code), and so it is necessary to implement a new area code within the area currently using 315. Typically the solution is a geographic split of the existing area into two area codes, or an overlay to serve new numbers. Either method involves costs and inconvenience to telephone consumers.

The 315 Number Plan Area (“NPA”) is one of the least populous regions of New York State (outside of Syracuse and Utica), so it seemed rather odd that an additional area code would be necessary. Upon investigation by PULP, it was discovered that multiple new NXX codes were assigned in 78 rural rate centers which had historically only had one exchange or NXX code (a block with 10,000 telephone numbers, NXX-0000 through NXX-9999), to those areas in the past few years, even though less than 1,000 people lived in each of these locations. As a result, many NXX exchanges were unnecessarily committed to rural areas. See PSC Considering "Area Code Relief" For 315 -- Where Did All The Numbers Go?

PULP filed a Motion with the Commission to investigate the situation publicly (see PULP Asks PSC to Investigate Need for New Telephone Area Codes in the 315 Region), but the motion was denied by the PSC in April. See PSC Denies Request for Open Inquiry and Continues with 315 Area Code Changes.

The PSC’s decision denying PULP's motion defensively said that existing number allocation procedures had been properly followed by its staff and that even though these methods may have “stranded” thousands of telephone numbers in rural areas, no mistakes were made. It did not address alternative ways to solve the problem without creating a new area code that were suggested by PULP in its motion.

It wasn’t until very recently, the PSC maintained, that telephone numbers could be given out 1,000 at a time (a “thousands block”) which is the most effective way to conserve numbers, as opposed to 10,000 at a time. The Commission had not sought FCC permission to implement thousand block pooling in the rural areas of the 315 area code until 2005, and did not actually implement this number conservation measure until months after the FCC granted its request. As a result, when competitive telephone companies asked for numbers in tiny localities with populations of less than five thousand, many NXX codes of 10,000 numbers were unnecessarily allocated.

On April 25, 2008, PULP filed a request for reconsideration and clarification of the PSC decision, stating that the Commission has the authority to reclaim telephone numbers in order to facilitate conservation and to make them available where needed. See PULP Asks PSC to Reconsider Refusal to Investigate Alternative to New Area Code in 315. We also argued that additional time exists to further investigate and resolve these issues because of new evidence not previously available indicating there has been a very significant slowing of NXX code and thousands blocks requests by providers. We requested that the Commission appoint an Administrative Law Judge to conduct evidentiary proceedings to investigate the reclamation of NXX codes and determine how many thousands blocks and NXX codes can be emptied and returned from the 315 NPA. To date, the Commission has not acted on PULP’s Petition.

On July 29, 2008 PULP supplemented its Petition with additional new evidence showing that while 16 or 17 NXX codes had been allocated in each of the past few years in the 315 NPA, since October 2007, only one net new NXX code has been allocated and 102 NXX codes still remain available.

At the current rate of NXX code exhaustion, it would be fifty years before the 102 remaining codes are used, even without freeing up barely used 10,000 number NXX exchanges allocated to the rural areas before the Commission began to issue numbers to telephone company requesters in blocks of 1,000.

PULP urged the Commission not to implement an area code split or overlay now, and not to burden people and businesses in the 315 area with an area code change under these circumstances.

Instead, we urged the Commission to continue the proceeding to investigate whether the number “shortage” can be remedied with far less disruption to customers by emptying and reallocating improvidently issued NXX codes as new codes are needed.

The much slowed rate of exhaustion, coupled with decontamination of slightly used NXX codes to free them for reallocation could stave off number exhaustion and area code changes in the 315 area for many years.

The Legislature ended its session without acting on proposed legislation that would require closer PSC scrutiny of the need for area code changes.

The next move belongs to the Commission.

Lou Manuta

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