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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
National Association of State Utility Consumer Advocates
8380 Colesville Road, Suite 101, Silver Spring, MD 20910
Phone: (301) 589-6313 Fax: 589-6380
e-mail: nasuca@nasuca.org |