Case Background
In June and
October of 2019, the Florida Public Service Commission (Commission) established
two dockets to address area code relief proposals for the 850 and 813 area
codes (Docket Nos. 20190135-TP and 20190196-TP, respectively). Both proposals
were filed by the North American Numbering Plan Administrator (NANPA) on behalf
of the telecommunications industry. The proposals requested that an All-Services
Distributed Overlay (Overlay) be implemented for each of the affected areas due
to anticipated demand for telephone numbers.
The NANPA proposals
included the industry’s standard thirteen-month implementation schedule, with a
six-month permissive dialing period, for each of the area codes. The permissive
dialing period is the time period in which customers can dial either seven or
ten digits to complete a call. At the end of the permissive dialing period,
mandatory ten-digit dialing is implemented, and customers that dial only seven
digits will receive an audio message informing the customer to dial the number again
using ten digits. The permissive dialing period is typically set for six months
prior to the forecasted exhaust date for an area code. NANPA forecasted the
exhaust for the 850 and 813 area codes as third quarter of 2021 and fourth
quarter of 2022, respectively.
On November 6,
2019, the Commission approved the 850 area code Overlay and the corresponding
implementation schedules by Order No. PSC-2019-0471-FOF-TP (850 Order). On
April 10, 2020, the Commission approved the 813 area code Overlay and the
corresponding implementation schedules by Order No. PSC-2020-0098-PAA-TP (813
Order).
Following issuance
of the 850 and 813 Orders, NANPA and its telecommunications industry workgroup
developed dates by which the industry would notify affected companies and
customers of the forthcoming implementation dates, including the end date for
permissive dialing (which is the same as the start date for mandatory ten-digit
dialing). During this process, the industry workgroup co-chairs distributed several
email notifications to directory publishers, coin operated payphone providers, alarm
associations, 911 county coordinators, and Public Safety Answering Points (PSAPs).
The industry workgroup distributed three email notifications for the 850 Number
Planning Area (NPA), and the first of four notifications for the 813 NPA is scheduled
for distribution on December 17, 2020.
On October 21, 2020, staff was contacted by two alarm
companies, Smith Security System, Inc. and Panhandle Alarm & Telephone
Company, Inc., both of which offer service in the 850 NPA. The companies expressed
concern regarding their challenges to reprogram alarm equipment in the
remaining time before the transition to mandatory ten-digit dialing, which is
set to begin on February 20, 2021. The companies indicated that they are facing
impediments in accessing their equipment as a result of the COVID-19 pandemic.
On November 5, 2020, the Alarm Association of Florida,
Inc. (Alarm Association) advised that its members share similar concerns.
The Alarm Association is a statewide association that represents security,
fire, and low-voltage customers. Approximately 30 of its contractor members are
in the 850 NPA, and approximately 40 of its contractor members are in the 813
NPA. These members have thousands of customer accounts. The Alarm Association
indicated that while some equipment can and has been remotely reprogramed to
dial ten digits, other forms of equipment, such as fire alarms, emergency
elevator phones, and some medical alert monitors, must be reprogramed on-site.
The Alarm Association advised that the reduced access to
premises, especially residential, as a result of the COVID-19 pandemic, has
greatly hindered scheduling reprograming. The Alarm Association also indicated
that the Florida Fire Code (Chapter 633, Florida Statutes) requires that an
alarm system be tested after any programing changes to ensure proper system
operation, and that this process, depending on the size and location of the
system, can take days or in some cases a week or longer.
Accordingly, the Alarm Association requested a 90-day
extension of the permissive dialing period for both the 850 and 813 NPAs
(though it is more urgently needed in the 850 NPA, since the start of mandatory
dialing without an extension is set for February 20, 2021, as indicated above).
On November 9, 2020, the Florida Fire Marshals and Inspectors Association
expressed its support of the Alarm Association’s request for a 90-day extension
of the permissive dialing period, and echoed the concerns expressed by the
Alarm Association.
The Commission has jurisdiction pursuant to Sections
364.16(7) and 120.80(13)(d), Florida Statutes, and Chapter 47 of the Code of
Federal Regulations, Section 52.19.
Discussion
of Issues
Issue 1:
Should the Commission extend the end of the permissive
dialing period for the 850 area code from February 20, 2021, to May 22, 2021?
Recommendation:
Yes. The Commission should approve an extension of
the permissive dialing period for the 850 area code, as set forth in Order No.
PSC-2019-0471-FOF-TP, to May 22, 2021. (Fogleman)
Staff Analysis:
Summary of Concerns
of Alarm Industry
Not all alarm equipment can be remotely reprogramed to
dial ten digits. Specifically, the majority of fire alarm systems and emergency
elevator phones require on-site reprograming. Furthermore, some legacy consumer
medical devices also require on-site reprograming. Due to the COVID-19
pandemic, the industry has faced challenges gaining access to thousands of
buildings to perform such reprograming, resulting in a potential public safety
risk if the devices cannot be reprogramed in time. In addition, Smith Security
System, Inc. and Panhandle Alarm & Telephone Company, Inc. suggested that
insufficient public notice regarding the transition to ten-digit dialing was a compounding
factor in their reprograming challenges.
Smith Security System, Inc., Panhandle Alarm &
Telephone Company, Inc., the Alarm Association, and the Florida Fire Marshals
and Inspectors Association have requested an extension of the permissive
dialing period to provide additional time to reprogram alarms throughout the 850
area code. While Smith Security System, Inc. did not specify a requested time
frame, Panhandle Alarm & Telephone Company, Inc. requested an extension of
twelve months. The Alarm Association and the Florida Fire Marshals and
Inspectors Association requested an extension of 90 days.
NANPA Area Code
Exhaust Forecast
In October 2020, NANPA issued its semi-annual exhaust
analysis which continues to forecast exhaust of the 850 area code in the third
quarter of 2021. As of October 30, 2020, there are 16 available Central Office
(CO) codes for assignment. While each CO code has 10,000 consecutive telephone
numbers, a code can only be assigned to one rate center.
There are a total of 64 rate centers in the 850 area code,
of which 63 are optional pooling rate centers, and one is excluded from
pooling. The Pooling Administrator has a total of 712 available blocks of 1,000
telephone numbers for assignment. There are available blocks in all rate
centers with the exception of the MUNSON and SNEADS rate centers.
NANPA is forecasting demand for two CO codes in the next
six months. Due to the limited number of CO codes in the 850 area code, NANPA
notes that it may be necessary to ration code assignments if the implementation
of the new area code is delayed. Specifically, if the demand for CO codes
exceeds the supply prior to final implementation of the new area code,
“Jeopardy” could be declared by NANPA for an NPA. When Jeopardy is declared,
Interim Jeopardy Procedures are put in place and become effective immediately.
The Interim Jeopardy procedures state that pooling and non-pooled CO code
applications must be submitted through a lottery process, and CO code
allocations initially are set at three per month. NANPA is required to convene
the industry no later than three weeks after the Jeopardy declaration in order
to reach consensus on the final Jeopardy procedures.
850 Outreach
Efforts
In order to educate and receive customer input, staff held
a customer workshop on September 6,
2019, in Tallahassee. During this workshop, Commission staff and
representatives from NANPA gave presentations explaining 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 customer comments during the workshop; however, staff did receive one
customer comment after the workshop in favor of the Overlay alternative.
NANPA and the industry workgroup developed customer
education and notification dates after the 850 Order was approved. Part of this
process included the distribution of three additional email notifications sent
to directory publishers, coin operated payphone providers, alarm associations,
911 county coordinators and PSAPs. The emails were sent in April, July, and
October for the 850 NPA. This process has been used in prior Overlays that
resulted in the transition to ten-digit dialing. Two contacts at the Alarm
Association were included in these emails. Customer notifications for the
general public were sent by all telecommunications companies in August, just
prior to the beginning of the permissive dialing period beginning August 22,
2020. The Commission also issued its own news release on August 7, 2020.
Industry
Workgroup Proposal
Staff advised the industry workgroup for the 850 area code
relief implementation of the concerns raised by the alarm industry. If the
Commission decides to extend the permissive dialing period for the 850 area
code, the industry workgroup has proposed the following timelines for the
Commission’s consideration. As noted in the Commission’s 850 Order, CO codes in
the new 448 area code are available only when all assignable CO codes in the
850 area code are assigned.
|
850/448 NPA
|
Current
Date
|
Revised
Date
|
|
End of
permissive dialing and start of mandatory 10-digit dialing
|
February 20, 2021
|
May 22, 2021
|
|
Earliest
new 448 NPA central office code activation / in service date
|
March 20, 2021
|
June 22, 2021
|
|
Earliest
date central office codes in the new 448 overlay area may be ordered through
NANPA.
|
January 13, 2021
|
April 17, 2021
|
In order for telecommunications carriers to begin incorporating
the changes listed above, NANPA must issue a planning letter regarding the
actions of the Commission. NANPA’s “NPA Code Relief Planning and Notifications
Guidelines” states that it will post the planning letter within ten business
days of the final written order. Thus, NANPA will not issue a planning letter
without a Final Order from the Commission, unless it is specifically directed
to do so.
Conclusion
In light of the barriers the alarm industry has faced in
reprograming alarm equipment due to COVID-19, staff recommends approval of the
schedule proposed by the industry workgroup. Staff believes that extending the end
of the permissive dialing period from February 20, 2021, to May 22, 2021, strikes
a reasonable balance between providing additional time to the alarm industry to
update equipment and ensure public safety with the need to mitigate the risk of
exhausting telephone numbers in the 850 NPA. Also, in order to facilitate this
schedule, staff recommends the Commission direct NANPA to issue the planning
letter within ten business days of the issuance of the Proposed Agency Action (PAA)
Order.
Issue 2:
Should the Commission extend the end of the permissive
dialing period for the 813 area code from October 16, 2021, to January 22, 2022?
Recommendation:
Yes. The Commission should approve an extension of
the permissive dialing period for the 813 area code, as set forth in Order No. PSC-2020-0098-PAA-TP,
to January 22, 2022. (Fogleman)
Staff Analysis:
Summary of Concerns
of Alarm Industry
As noted in Issue 1, the majority of fire alarm systems
and emergency elevator phones require on-site reprograming of equipment from
seven-digit dialing to ten-digit dialing. Due to the COVID-19 pandemic, the
Alarm Association has requested that the Commission extend the permissive
dialing period to provide for additional time for such reprograming.
NANPA Area Code
Exhaust Forecast / 988 National Suicide Prevention Lifeline
When the Commission considered area code relief for the
813 area code, NANPA had forecasted the exhaust by third quarter of 2021. In
October 2020, NANPA issued its semi-annual exhaust analysis forecast, and
updated the exhaust of the 813 area code to the fourth quarter of 2022. Thus,
the expected exhaust for the 813 area code was pushed out more than a year. However,
the area code exhaust is no longer the sole issue forcing the transition to ten-digit
dialing in this area code.
In July 2020, the Federal Communications Commission
adopted rules to establish 988 as the new nationwide three-digit phone number
to connect those in crises with suicide prevention and mental health crisis
counselors. The rules require all phone service providers to direct all 988
calls to the existing National Suicide Prevention Lifeline by July 16, 2022. To
ensure that calls to 988 reach the National Suicide Prevention Lifeline, all
providers will be required to implement ten-digit dialing in areas that use
both seven-digit dialing and use 988 as the first three numbers in seven-digit
phone numbers.
Because 988 is an active prefix in the 813 area code, the
813 NPA will be required to transition to ten-digit dialing. The implementation
schedule related to establishing the 988 National Suicide Prevention Lifeline
requires the transition to ten-digit dialing before the new exhaust date for
the 813 area code. Thus,
the Commission has a limited time to extend the permissive dialing period in
the 813 area code, since permissive dialing cannot be extended to the
forecasted exhaust (fourth quarter of 2022) due to the implementation of the
National Suicide Prevention Lifeline.
813 Outreach
Efforts
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. While there were no customers at
either workshop, staff did receive one
comment afterwards in favor of the Overlay option.
NANPA and the industry workgroup are working to develop
customer education and notification dates. Part of this process includes the
distribution of four additional email notifications sent to directory publishers,
coin operated payphone providers, alarm associations, 911 county coordinators,
and PSAPs for the 813 NPA. As previously indicated, this process has been used
in prior Overlays that resulted in the transition to ten-digit dialing. These
emails are scheduled to be sent on December 17, 2020, March 5, 2021, June 16,
2021, and September 3, 2021. The first customer notification for the general
public is scheduled to be sent by all telecommunications companies in March
2021, just prior to the beginning of the permissive dialing period on April 17,
2021.
Industry
Workgroup Proposal
Staff advised the industry workgroup for the 813 area code
relief implementation of the concerns identified by the alarm industry. If the
Commission decides to extend the permissive dialing period for the 813 area
code, the industry workgroup has proposed the following timelines for the
Commission’s consideration. As noted in the 813 Order, CO codes in the new 656 area
code are available only when all assignable CO codes in the 813 area code are
assigned.
|
813/656 NPA
|
Current Date
|
Revised Date
|
|
Start of
permissive 10-digit dialing
|
April 17, 2021
|
No Change
|
|
End of
permissive dialing and start of mandatory 10-digit dialing
|
October 16, 2021
|
January 22, 2022
|
|
Earliest
new 656 NPA central office code activation / in service date
|
November 16, 2021
|
February 22, 2022
|
|
Earliest
date central office codes in the new 656 overlay area may be ordered through
NANPA.
|
September 11, 2021
|
December 18, 2021
|
In order for telecommunications carriers to begin
incorporating the changes listed above, NANPA must issue a planning letter
regarding the actions of the Commission. NANPA’s “NPA Code Relief Planning and
Notifications Guidelines” states that it will post the planning letter within
ten business days of the final written order. Thus, NANPA will not issue a
planning letter without a Final Order from the Commission, unless it is
specifically directed to do so.
Conclusion
In light of the barriers the alarm industry has faced in
reprograming alarm equipment due to COVID-19, staff recommends approval of the
schedule proposed by the industry workgroup. While the forecasted exhaust date
for 813 has been extended, the implementation of the national suicide
prevention number limits the amount of time permissive dialing can be extended.
Staff believes that extending the end of the permissive dialing period from
October 16, 2021, to January 22, 2022, strikes a reasonable balance between
providing additional time to the alarm industry to update equipment, ensuring
public safety, mitigating the risk of exhausting telephone numbers in the 813
NPA, and the implementation of the national suicide prevention number. Also, in
order to facilitate this schedule, staff recommends that the Commission direct NANPA
to issue the planning letter within ten business days of the issuance of the
PAA Order.
Issue 3:
Should this docket be closed?
Recommendation:
Yes. If no person whose substantial interests are
affected by the proposed agency action files a protest within 21 days of the
issuance of the Proposed Agency Action Order, this docket should be closed upon
the issuance of a Consummating Order. (Dziechciarz, Passidomo)
Staff Analysis:
At the conclusion of the protest period, if no
protest is filed, this docket should be closed upon the issuance of a
Consummating Order.
