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 561 Numbering Plan Area (NPA). The Industry reached a
consensus decision to recommend an all-services distributed overlay as the form
of relief for the 561 NPA. NANPA projects that the supply of central office
codes in the 561 NPA will exhaust during the third quarter of 2023.
Consequently, NANPA is also requesting that the Commission approve the
recommended 9-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 561 area
code was introduced in 1996 when the 407 area code needed relief due to
substantial growth in demand for telephone numbers. Since its creation the 561
area code was split once in 2002 to create the 772 area code which serves the
Treasure Coast of Florida. Currently, the 561 area code serves Palm Beach, Boca
Raton, Wellington, Boynton Beach, Jupiter, Delray Beach, Belle Glade and other
smaller communities.
On July 16,
2020, the FCC adopted an Order approving the designation of 988 as the 3-digit
abbreviated dialing code for the National Suicide Prevention Lifeline. The
Order requires all telecommunications carriers, interconnected Voice over
Internet Protocol (VoIP) providers, and one-way VoIP providers (covered
providers) to make any network changes necessary to ensure that users can dial
988 to reach the existing National Suicide Prevention Lifeline by July 16,
2022. This requires all covered providers to
implement mandatory 10-digit dialing in NPAs that have assigned 988 as an NXX,
which is the first 3-digits of a 7-digit number. Dialing the area code first
will prevent calls to numbers with the 988 NXX from being mistakenly directed
to the Suicide Prevention Lifeline. Several Florida NPA’s, including 561, were
identified as needing to transition to 10-digit dialing.
In April 2021,
NANPA forecasted that the 561 area code would exhaust during the third quarter
of 2024. However, due to an increase in requests for numbering resources in the
561 area code, on September 23, 2021, NANPA revised its forecast to reflect a
new exhaust date of third quarter 2023. NANPA convened an industry meeting on
October 12, 2021, to review and approve the draft area code relief filing. On
October 22, 2021, NANPA filed a petition with the Commission on behalf of the
Industry requesting approval of an all services distributed overlay for the 561
area code (see map Attachment A). 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 561 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 561 area code.
(Deas, Fogleman, Imig)
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
19 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.
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.
Industry
Consensus
NANPA, asserts that based on industry guidelines, only an
overlay will meet the requirements for relief of the 561 NPA, which is already scheduled
to transition to mandatory 10-digit dialing due to the implementation of the
National Suicide Prevention Lifeline.
Therefore, the Industry met on October 12, 2021, and approved an all-services
distributed overlay as the recommended form of relief for the 561 area code.
According to NANPA, the all-services distributed overlay recommended by
industry would provide a projected life of approximately 23 years.
The Industry has also recommended a 9-month implementation
schedule. Since the transition to mandatory 10-digit dialing will be in place
prior to the implementation of the new area code there will be no permissive
dialing period. Therefore, the schedule will only include the necessary network
preparation and customer education. At the completion of the network
preparation and customer education period, the new area code will be activated.
Industry asserts this schedule will allow sufficient time to implement the new
area code prior to exhaust of the 561 area code.
Proposed Dialing
Plan
If an all-services distributed overlay is approved by the
Commission, the Industry recommends the dialing plan be set forth as follows:
Local Calls 10-digit dialing (as required
by the FCC)
Toll Calls 1 + 10-digit dialing
Operator Calls 0 + 10-digit dialing
Staff Workshop
In an effort to educate and receive customer input, staff
held a virtual customer workshop on November 5, 2021. During this workshop
Commission staff and a representative from NANPA explained the area code relief
process, the relief option being considered, and customer impact. Staff also
allotted time for customers to ask questions or give comments. There was no
customer input or comment.
Conclusion
Staff reviewed the petition and analyzed the recommended
relief option. Staff notes industry guidelines stipulate that when area code
relief is required for a single NPA that is transitioning or scheduled to
transition to mandatory 10-digit dialing, only an overlay will meet the
requirements for relief. The 561 area code, as a result of the implementation
of the National Suicide Prevention Lifeline, is scheduled to complete the
transition to mandatory 10-digit dialing prior to the implementation of a relief
option. Consequently, in accordance with industry guidelines only an overlay
will meet the requirements for relief in the 561 area code. In addition, staff
notes an overlay will allow existing customers to retain their current area
code and telephone number.
Staff agrees with the Industry and recommends the
Commission approve the proposed all-services distributed overlay as the form of
relief for the 561 area code. Additionally, staff recommends Commission
approval of the proposed 9-month implementation schedule. Finally, staff
recommends the Commission approve that central office codes in the new area
code be available only when all assignable prefixes in the 561 area code have
been assigned.
Issue 2:
Should this docket be
closed?
Recommendation:
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. (Imig)
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.
