Case Background
On October 28,
2019, the North American Numbering Plan Administrator (NANPA), on behalf of
Florida’s telecommunications industry (Industry) filed a petition with the
Florida Public Service Commission (Commission) for approval of its area code
relief plan for the 813 Numbering Plan Area (NPA). The Industry reached a
consensus decision to recommend an all-services distributed overlay as the form
of relief for the 813 NPA. NANPA projects that the supply of central office
codes in the 813 NPA will exhaust during the third quarter of 2022.
Consequently, NANPA is also requesting that the Commission approve the
recommended 13-month implementation schedule.
NANPA is the
neutral third-party administrator of the North American Numbering Plan, which
is the area code system shared by the United States, Canada, Bermuda, and 17
Caribbean countries. NANPA’s responsibilities include assigning area codes and
prefixes, and tracking numbering usage to ensure effective and efficient
utilization. NANPA is also responsible for forecasting the exhaust of
geographic area codes and area code relief planning. NANPA publishes its
forecasted exhaust of all area codes on a semi-annual basis. This forecast is used to determine when to start the area code relief process. The area served by NANPA is divided into NPAs, which are each identified by a three-digit NPA code, commonly called an area code.
The 813 area code was introduced in 1953 when the 305 area code needed relief due to substantial growth in demand for telephone numbers. It was the second
area code assigned in Florida. Originally, the 813 area code was assigned to 16
counties stretching from Pasco county to the inland portion of Monroe county.
Prior to the implementation of number conservation methods in 2002, the area
served by the 813 area code was split twice, which created the 941 and 727 area
codes. Currently, the
813 area code serves all of Hillsborough county, the City of Oldsmar in
Pinellas county, and the central and southeastern portions of Pasco county.
In April 2019, NANPA forecasted a need for area code relief for the 813 area code. Subsequently, pursuant to the area code Relief Planning Guidelines, NANPA began the planning process by announcing the need for relief and distributing an initial planning document to the Industry. NANPA then hosted an Industry meeting on September 16, 2019, to discuss possible relief alternatives for the 813 area code. During the meeting, the Industry reviewed five relief options and reached a consensus to recommend the all-services distributed overlay plan to the Commission as the preferred method of relief for the 813 area code. On October 28, 2019, NANPA filed a petition with the Commission on behalf of the Industry requesting approval of the consensus decision. The Commission has jurisdiction to address this issue pursuant to Section
364.16(7) and 120.80(13)(d), Florida Statutes, and
47 Code of Federal Regulations (C.F.R.) § 52.19.
Discussion
of Issues
Issue 1:
Should the Commission approve the
Industry’s
consensus recommendation of an all-services distributed overlay as the area code relief plan for the 813 area code?
Recommendation:
Yes, the
Commission should approve the Industry’s consensus recommendation of an all-services distributed overlay as the area code relief plan for
the 813 area code. (Deas, Fogleman,
Weisenfeld, Passidomo)
Staff Analysis:
Area code relief responsibilities have been delegated to the states by the Federal Communication Commission (FCC) pursuant to 47 C.F.R.
§ 52.19. In Florida, the Commission is responsible for determining the appropriate form of area code relief
when telephone numbers exhaust within an area code. There are a number of methods available to address area code exhaust issues; however, the two most commonly used methods are a geographic split or an overlay.
Geographic Split
The geographic split method divides the exhausting NPA into two, leaving the existing area code to serve one NPA and assigning a new area code to serve the other NPA. This method generally acknowledges jurisdictional or natural boundaries, but for technical
reasons and number optimization considerations, the
actual boundaries must conform to existing rate center boundaries. Under this method, customers on both sides of the split would retain seven digit dialing; however, it would require one half of the customers to change their area code. The last split implemented in Florida was 18 years ago. Industry guidelines specify that in the case of a
geographic split, the difference in area code life expectancies between the split areas should be 10 years or less.
According
to NANPA, a geographic split in the 813 area code
would result in an exhaust life that exceeds this 10 year limit between the two areas. Therefore, no split alternative was included in NANPA' s petition.
Overlay
The overlay method adds a new area code to the same geographic area served by the area code requiring relief. This results in the assignment of more than one area code to the same NPA. Current customers keep their existing area code and number; however, new customers or customers adding additional lines would receive the new area code.
Once an overlay
is implemented, the FCC requires 10-digit dialing for all local calls within the NPA. There are four potential implementation strategies for an overlay, which are as follows:
a) All-Services Distributed Overlay - The distributed overlay strategy may be considered in situations when growth in telephone numbers is expected to be more or less evenly distributed throughout the existing NPA. The new area code is added to the same geographic
area as the code
requiring relief and shares exactly the same geographic boundaries.
b) Concentrated
Growth Overlay - A concentrated growth overlay may be considered in situations
when the majority of need for the new telephone numbers
is expected to
be concentrated in one section of the existing NPA. For example, a fast
growing metropolitan
area and a sparsely populated rural area could exist within the same NPA. The
overlay area
code would
be assigned initially to the section of the NPA experiencing the fastest growth, and new phone numbers in that section would be assigned from the new area
code. As more relief is required, the geographic area served by
multiple area codes could expand to the rest of the NPA.
c) Boundary Elimination
Overlay - With a boundary elimination overlay, the NPA requiring
relief is adjacent
to an NPA with available numbering resources. The boundary
between these NPAs is eliminated, and spare telephone numbers from
the adjacent area code are assigned within the NPA boundary where relief is required.
d) Multiple Overlay - The multiple overlay strategy
may be considered where relief is required in
an NPA served by two or more area codes. The new area code would be assigned
to overlay the
multiple existing area codes serving the entire geographic area. This
essentially functions the same as an all-services distributed overlay.
During the September 16, 2019 Industry meeting hosted by
NANPA, the following five relief plans were considered.
Alternative No.
1 - All-Services
Distributed
Overlay (see map in Attachment A)
A new area code would be assigned to the same geographic area occupied by the existing 813 area code. Customers would
retain their current telephone numbers; however, 10-digit dialing would be
required by all customers within the NPA. At the exhaust of the 813 area code,
all future assignments will be made from the new area code. The projected life of this method would be approximately 37 years.
Alternative No.
2 - NPA Boundary Elimination Overlay (see map in Attachment B)
The boundary between the existing 813
and 727 area codes would be eliminated and both area codes
would be assigned to the combined geographic area. This alternative
would allow customers assigned the 813 and 727 area codes to
retain their telephone numbers and would eliminate the need for a new area code. However, it would require 10-digit dialing for
all customers within the combined NPA. The projected life of this method would be approximately 11
years.
Alternative No.
3 - NPA Boundary Elimination Overlay (see map in Attachment C)
The boundary between the existing 813
and 863 area codes would be eliminated and both area codes
would be assigned to the combined
geographic
area. This
alternative would allow customers assigned the
813 and 863 area codes to retain their telephone numbers and would eliminate the
need for a new
area code.
However, it
would require
10-digit dialing for all customers within the combined NPA. The projected life of this method would be approximately 17 years.
Alternative No.
4 - NPA Boundary Elimination Overlay (see map in Attachment D)
The boundary between the existing 813
and 941 area codes would be eliminated and both area codes
would be assigned to the combined
geographic
area. This
alternative would allow customers assigned the
813 and 941 area codes to retain their telephone numbers and would eliminate the
need for a new
area code.
However, it
would require
10-digit dialing for all customers within the combined NPA. The projected life of this method would be approximately 16 years.
Alternative No.
5 - Overlay of a New Area Code Over the Boundary Elimination (see map in Attachment E)
The boundary between the 813
and 727 area codes would be eliminated and a new area code would be assigned to
the combined geographic area. This alternative would allow customers assigned the 813 and 727 area
codes to retain their telephone numbers. However, it would require 10-digit
dialing for all customers within the NPA. At the exhaust of the
813 and 727 area codes all future
assignments would be made from the new area code. The projected life of this method would be approximately 41
years.
Industry Consensus
After review of the five alternatives the Industry reached a consensus recommending alternative No. 1, an all-services distributed overlay, as the recommended form
of relief for
the 813
NPA. The Industry decided against the
boundary elimination overlay alternatives because
they would impact a larger quantity of customers with 10-digit dialing than the
all-services overlay. In addition, the Industry asserted that the boundary
elimination alternatives would involve a more complex customer education
process and lead to increased customer confusion.
Proposed Dialing Plan
If
an all-services overlay is approved by the Commission, the Industry recommends
the dialing plan be set forth as follows:
Ř Local Calls 10-digit
dialing (as required by the FCC)
Ř Toll Calls 1
+ 10-digit dialing
Ř Operator Calls 0
+ 10-digit dialing
Proposed Implementation Schedule
The Industry has also recommended a 13-month
implementation schedule. This schedule includes six-months for network preparation, followed by a six-month permissive
10-digit dialing and customer education period. New codes are not activated until one month after the mandatory 10-digit dialing period. However, the
Industry notes that the new area code would not be assigned until all
assignable prefixes in the 813 area code have been assigned. During the permissive dialing period, calls within the 813 area code can be completed using either 7-digits or 10-digits. The purpose of the permissive dialing period is to facilitate transition from
7-digit to 10-digit
dialing by educating customers on the impending changes without impacting the calls. Following the six month permissive dialing period, mandatory 10-digit
dialing will
be required. If
the required 10-digits are not dialed, the caller will receive a recorded message advising them that the area code is required to complete the call. This schedule will allow the Industry sufficient time to implement the new
area code prior to the exhaustion of 813.
Staff Workshops
In an effort to educate and receive customer input, staff held customer workshops on February 6, 2020, in Tampa, FL, and February 7, 2020, in St.
Petersburg, FL. During these workshops Commission staff and a representative
from NANPA explained the area code relief process, the relief options being considered, and the customer impact. Staff also allotted time for customers to ask questions or give comments. There were no customers nor
customer comments at either workshop; however, since that time, the Commission has
received one customer comment favoring alternative No. 1.
Conclusion
Staff reviewed the petition
and analyzed all of the alternatives. Staff considered which alternative would
provide the longest length of time before needing relief and the impact on
customers. Alternative No. 5 provides the longest projected exhaust date;
however, staff notes that all of the alternatives being considered share the
same impact on customers. Customers would be required to dial 10-digits for all
local calls. All things considered, alternative No. 5 provides the longest
projected length of time, but would also negatively impact more customers by
imposing 10-digit dialing for customers who otherwise would not be affected for
another 28 years or more.
Staff agrees with the Industry
that the more favorable approach is to minimize the number of customers that
would be impacted by 10-digit dialing. Therefore,
staff recommends the Commission
approve the Industry’s proposed
all-services distributed overlay as the form of relief for the 813 area
code. Additionally, staff recommends Commission approval of the proposed 13-month implementation schedule that includes a six-month
customer permissive dialing period. Finally, staff recommends the Commission
approve that central office codes in the new area code be available only when
all assignable prefixes in the 813 area code have been assigned.
