NATIONAL ASSOCIATION OF STATE UTILITY CONSUMER ADVOCATES
R E S O L U T I O N
Supporting the Reformation of the Current Telecommunications Numbering System in Order to Avoid the Exhaust of the
North American Numbering Plan
WHEREAS, telephone numbers in the United States are based on the North America
Numbering Plan and consist of a three-digit area code (“NPA”), followed by a three-digit NXX code or central office code and a four-digit XXXX line or station number; and
WHEREAS, the combination of 10 digit numbers that comprise the numbering resource are limited and efficient allocation and utilization of this resource is necessary to promote social and economic welfare; and
WHEREAS, to date, the burden of inefficient number utilization and assignment has been borne by the public; and
WHEREAS, the NPA-NXX formula currently used to assigned telephone numbers was
developed by AT&T in 1947; and
WHEREAS, the current telecommunications numbering system has had difficulty in accommodating growth in the number of telecommunications services and competing companies that wish to provide these services in many geographic areas; and
WHEREAS, the proliferation of competitive local exchange carriers nationwide and the antiquated process used to assign and utilize NXX codes has resulted in a rapid depletion of available NXX codes nationwide and requires the creation of new area codes in many regions; and
WHEREAS, the North American Numbering Plan Administrator provided information to the North American Numbering Council in February, 1999, that indicates an exhaust of the North American Numbering Plan on or about the year 2007; and
WHEREAS, data provided by the North American Numbering Plan Administrator in
April, 1999, demonstrates that the historical trend of area code demand shows that between approximately 1947 and 1994, the demand is fairly consistent at a linear growth rate of slightly greater than one area code per year but, since 1994, the growth rate has increased significantly to over 27 area codes per year; and
WHEREAS, given the revised April, 1999 data, the North American Numbering Plan Administrator indicates that, if the above trend continues, a simple projection using regression analysis demonstrates a total North American Numbering Plan exhaust somewhere between 2004 and 2011; and
WHEREAS, given that NANP exhaust may be substantially delayed to as 2092 with Thousands Block pooling for all carriers and reclamation of unused numbers; and
WHEREAS, although there are approximately 7.5 million usable telephone numbers in each area code, as few as half that number for each area code are assigned before a new area code is introduced; and
WHEREAS, the current North American Numbering Plan theoretically has 5.4 billion telephone numbers available which is approximately 46 telephone numbers per household in the United States and Canada or 23 telephone numbers for every person over the age of 15; and
WHEREAS, given the above numbers, even at a very poor utilization rate of 25%, the North American Numbering Plan would allow 11.5 telephone numbers per household or 6 telephone numbers for every person over the age of 15; and
WHEREAS, the National Association of State Utility Consumer Advocates submits that there is enough evidence to conclude that expansion of the North American Numbering Plan to allow for additional digits (from 10 digit to 12 digit dialing within the North American Numbering Plan Area) will burden society with extremely high costs and inconveniences which the Federal Communications Commission reports estimates of between $50 and $150 billion; and
WHEREAS, there has been a 7-14% increase in area codes per year since 1995; and
WHEREAS, under current allocation methods, there are only 410 available geographic area codes after non-assignable and reserved area codes are removed; and
WHEREAS, many of the numbering changes being considered will require the dialing of additional digits for local telephone calls; and
WHEREAS, the shortage of numbering resources creates a hardship for consumers, who
wish to purchase these services, as well as competitive local exchange carriers, and other telecommunications carriers; and
WHEREAS, it is essential that the concerns of consumers must be considered in any determination as to how numbering resources should be used by the telecommunications industry; and
WHEREAS, the introduction of new area codes, as the only solution to telephone number depletion, is not responsive to the needs of consumers and creates inconveniences and additional costs for consumers and the telecommunications industry; and
WHEREAS, action must be taken promptly so as to prevent the continued proliferation of area codes and to decrease the detrimental impact that area code changes have on consumers; and
WHEREAS, certain carriers, such as wireless carriers, have unique characteristics, and placing such carriers in separate area codes would preserve preexisting area codes for a longer period of time; and
WHEREAS, all numbering conservation measures would be of little value if carriers or customers were able to warehouse, or reserve, telephone numbers which is possible if there are no effective controls on the process by which telephone numbers can be reserved; and
WHEREAS, NANP reform will avoid or substantial delay the substantial costs required to revise the NANP in later years; and
WHEREAS, lack of the enforcement of accurate and mandatory auditing procedures, or the ability to accurately establish how many numbers a carrier actually has, has further led to the proliferation of area codes as carriers have not maximized the use of existing area codes before a new area code is implemented; and
WHEREAS, many consumers have expressed their discontent that area codes have proliferated with little apparent management or control while the costs to consumers as a result of the lack of effective controls in terms of the additional of new area codes or the implementation of 10 digit dialing, are enormous;
THEREFORE, BE IT RESOLVED, that the National Association of State Utility
Consumer Advocates (NASUCA) supports the reform of the telecommunications numbering system prior to its exhaust in such a way that NXX codes may be used more efficiently, through various methods including number pooling, in order to serve the needs of consumers and avoid early exhaust of the North American Numbering Plan; and
BE IT FURTHER RESOLVED, that the NASUCA calls upon the telecommunications industry and regulatory agencies to gather and consider the requirements and convenience of consumers, and to give these factors great weight as the reform of the telecommunications numbering system proceeds; and
BE IT FURTHER RESOLVED, that the telecommunications industry must deal with the serious area code problem that exists in an expeditious and thorough manner in order to complete national pooling and other solutions as soon as possible, as the longer the area code crisis is left unresolved, the greater jeopardy the North American Numbering Plan is placed in and the higher the cost becomes to consumers; and
BE FURTHER RESOLVED, that NASUCA hereby urges the Federal Communications Commission to expeditiously adopt measures which would mandate the more economical and efficient use of telephone numbers, prior to the exhaust of the North American Numbering Plan, by various measures, including but not limited to Thousands Block Pooling, Unassigned Number Porting, Rate Center Consolidation, Minimum Fill Requirements prior to assignment and opening of new number blocks and on a basis which gives states more control over the implementation of these measures, within general Federal Communications Commission guidelines, so that states can move quickly to implement these measures without the delays associated with proceedings before the Federal Communications Commission; and
BE IT FURTHER RESOLVED, that certain carriers, such as wireless carriers, should be placed in separate area codes; and
BE FURTHER RESOLVED, that the cost for NANP reform should be borne by the industry, recovery should not be guaranteed, and be directed imposed upon consumers; and
BE IT FURTHER RESOLVED, that NASUCA submits that states should not be forced to individually petition and wait for the Federal Communications Commission to act before any number optimization actions are permitted; and
BE IT FURTHER RESOLVED, that to improve telephone number utilization, enhance competition in the telecommunications industry and lessen the burden on state public utility commissions and the public for area code relief, NASUCA urges the Federal Communications Commission to work with the telecommunications industry, the North American Numbering Plan Administrator, consumer representatives and state public utility commissions to reform the way telephone numbers are allocated by eliminating the NPA-NXX reservation formula and implement measures for the allocation of telephone numbers in blocks of 1,000 or less, and
BE IT FURTHER RESOLVED, that NASUCA authorizes its Executive Committee to develop specific positions and to take appropriate actions consistent with the terms of this resolution. The Executive Committee shall notify the membership of any action taken pursuant to this resolution.
Approved by NASUCA:
June, 1999, Baltimore, Maryland
Submitted by:
NASUCA Telecommunications Committee
Michael J. Travieso, MD, Chairman
Alice Hyde, IA
Angela Acree, D.C.
B. Robert Piller, PULP NY
Carl Wolf Billek, Esq., NJ
Charlie Beck, FL
Douglas W. Elfner, NY
Elliott Elam, SC
Garth Morrisette, MN
Gene Lafitte, WV
Heikki Leesment, NJ
Karen Hardie, OH
Kelly McQueen, AR
Kevin Anderson, NC
Laurie Pappas, TX
Letitia Wiggins McKoy, D.C.
Martha S. Hogerty, MO
Michael McNamara, CA
Mike Eckert, IN
Phil Bullock, UT
Philip McClelland, PA
Regina Costa, TURN CA
Richard Weiner, NM
Simon ffitch, WA
Steve Welch, NV
Theresa Czarski, MD
Thorvald Nelson, CO
Timothy Seat, IN
Wayne Jortner, ME
William Homeyer, NH
William Vallee, Jr., CT