PULP Submits More Evidence to PSC Showing that a New Area Code in 315 Region is Unnecessary

Following up on a Recommended Decision issued by Judge Howard Jack on November 26th recommending an additional overlay area code for the 315 region of upstate New York, PULP submitted a Brief on Exceptions in December outlining the reasons why area code “relief” is not necessary. We previously uncovered evidence that multiple 10,000 telephone number exchange codes had been assigned to over 50 rural communities in the 315 area code in recent years, which created a perceived impending “shortage” signaling the need for a new area code. See

• ALJ Recommends "Overlay" Telephone Area Code Requiring 11-Digit Dialing, Despite Plentiful Numbers and Exchange Codes in Central New York's 315 Area;
• 315 Area Code Number Exhaust Pushed Back Another Year: No Need to Add New Area Code Now;
• PSC Halts 315 Area Code Changes For Now, But Denies PULP Petition for More Aggressive Telephone Number Conservation and Reclamation;
• PULP Provides Further Proof That Area Code Changes Are Not Needed Now in the 315 Area;
• Bill Would Require PSC to More Closely Scrutinize Telephone Area Code Changes;
• PULP Asks PSC to Reconsider Refusal to Investigate Alternative to New Area Code in 315;
• PSC Denies Request for Open Inquiry and Continues with 315 Area Code Changes;
• PSC Puts 315 Area Code Changes on Hold Pending Investigation;
• PULP Asks PSC to Investigate Need for New Telephone Area Codes in the 315 Region;
• PSC Considering "Area Code Relief" For 315 -- Where Did All The Numbers Go?

In our Brief on Exceptions, we pointed out that the rush of requests for exchange codes had abated and that there is no need to inconvenience the public and businesses with a new area code, which, among other things, would require everyone to use 10 or 11 digit dialing -- even to call across the street. The Brief also cited to the November 2008 North American Numbering Plan Administrator (“NANPA”) monthly Code Assignment Report stating that the number of exchange codes requested in the 315 area code for the first 11 months of 2008 stood at four (eight requested and four returned) with 97 exchange codes remaining available for use.

On March 16th, 2009, PULP filed a Supplement to its Brief with new information indicating that since that time, according to the December 2008, January 2009, and February 2009 NANPA monthly Code Assignment Reports, a total of zero new exchange codes were assigned in the 315 area code. In addition, during January 2009, one exchange code was returned. As a result, since the time PULP’s Brief was submitted, there has been a total of negative one exchange codes assigned in the 315 area code, and 98 exchange codes still remain available.

This new evidence confirms that the rapid rate of exchange code depletion prior to reform of the exchange code allocation methodology has ended, and the usage of the remaining exchange codes has slowed dramatically. At this time, we believe that there is no need to burden all telephone customers in the 315 area with a new overlay code, 10-digit (or 11-digit) dialing, and the attendant cost and inconvenience. Further, when NANPA updates its nationwide area code exhaust dates in April 2009, the exhaust date for the 315 area code may be pushed back for a fourth time since the PSC proceeding was initiated.

Accordingly, PULP reiterated its position that there is no need to implement any new area codes in the 315 area.

Lou Manuta