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PA Bulletin, Doc. No. 16-2057


Petition for Approval of Numbering Plan Area Relief Planning for the 215/267 NPA

[46 Pa.B. 7500]
[Saturday, November 26, 2016]

Public Meeting held
November 9, 2016

Commissioners Present: Gladys M. Brown, Chairperson; Andrew G. Place, Vice Chairperson; John F. Coleman, Jr.; Robert F. Powelson; David W. Sweet

Petition for Approval of Numbering Plan Area Relief Planning for the 215/267 NPA;
Docket No. P-2016-2560129


By the Commission:

 On August 5, 2016, the North American Numbering Plan Administrator (NANPA),1 NeuStar, Inc., in its role as the neutral third party NPA Relief Planner for Pennsylvania, acting on behalf of the Pennsylvania telecommunications industry (industry), filed a petition with the Commission requesting approval of its plan to alleviate numbering exhaust for the 215/267 Numbering Plan Area (''NPA'' or ''area code''). According to the petition, the industry reached a consensus2 to implement an all services distributed overlay for the geographic area covered by the 215/267 NPA, which would create a new area code to service the area.

 The Federal Communications Commission (FCC), which has plenary jurisdiction over numbering issues in the United States,3 mandates that states must implement timely area code relief, i.e., add a new area code, when the area codes within their boundaries are about to exhaust their supply of NXX codes.4 The Commission, therefore, is now faced with the decision of deciding when a new area code must be added and in what form that area code should be added. As stated earlier, the industry's Petition recommends an overlay as the necessary remedy to the 215/267 NPA exhaustion.


I. FCC Requirements Regarding Area Code Relief

 The proliferation of new area codes is not the result of the unavailability of numbers for end-users. When there are no more NXX codes available to assign to telephone companies, then new area codes need to be opened. Thus, new area codes are needed when existing area codes exhaust their supply of NXX codes.5 The system for allocating numbering resources was designed in 1947 to accommodate a monopoly system. In recent years, however, a combination of several factors has created an unprecedented demand for NXX codes leading to the exhaustion of existing area codes and the proliferation of new area codes to fill the void.

 According to FCC regulations, new area codes can be introduced to relieve the shortage of NXX codes in an area code through the use of any of the following three methods:

 1. A geographic area code split, which occurs when the geographic area served by an area code is split into two or more geographical parts;

 2. An area code boundary realignment, which occurs when the boundary lines between two adjacent area codes are shifted to allow the transfer of some numbers from one area code to the other;

 3. An area code overlay, which occurs when a new area code is introduced to serve the same geographic area as an existing area code.

See 47 C.F.R. § 52.19(c)(1)—(3).

 Although the NANPA notifies the industry when an area code needs relief planning and conducts the relief planning meeting, it is a neutral third party that does not express an opinion on any proposed relief alternative. Additionally, the industry is encouraged to participate in the creation of the relief alternatives and is free to present any plans during the relief planning meeting.

II. NANPA's NPA Relief Planning for the 215/267 NPA

 A. The Relief Planning Meeting for the 215/267 NPA

 Between 1940 and 1990, Pennsylvania had a total of only four area codes (412, 814, 717 and 215). The 215 area code is one of Pennsylvania's original four area codes. In June 1999, the 267 overlay NPA was activated and placed into service to relieve the 215 NPA. Today, Pennsylvania has ten active area codes (215, 610,6 267, 484,7 717, 570,8 412, 724,9 87810 and 814).

 The April 2016 NRUF (Number Resource Utilization Forecast) and NPA Exhaust Analysis (2016 NRUF Report) indicated that the 215/267 NPA will exhaust during the second quarter of 2019.11 Based upon the projected exhaust date, NANPA notified the Commission and the Industry on May 26, 2016, that NPA relief needed to be addressed. The Industry met via conference call on June 28, 2016, to discuss various relief alternatives. Pursuant to the NPA Relief Planning Guidelines, NANPA distributed an Initial Planning Document (IPD) to the Industry prior to the relief planning meeting. The IPD contained a meeting aid, CO Code assignment information, thousand block pooling statistics and an illustrative map of the overlay.12 A draft relief Petition was also included in the industry notice. NANPA cites to the NPA Relief Planning Guidelines to support its practice of requesting an overlay where an existing overlay is in place.

 B. Industry's Consensus to Recommend an Overlay

 At the June 28th meeting, the participants discussed the attributes of the all services distributed overlay plan, as the preferred method of relief for the 215/267 NPA: a new NPA code should be assigned to the same geographic area as the existing 215/276 NPA and is projected to last approximately 24 years. All existing customers would retain their 215/267 area code and would not have to change their telephone numbers. CO codes in the new overlay NPA will be assigned upon request upon the effective date of the new NPA code. All local, calls within and between the 215/267 NPA and the new NPA would continue to be dialed using 10-digits.13 The current dialing plan would continue with the implementation of the new overlay relief plan. The following table illustrates the recommended dialing plan:

Type of Call Call Terminating to Dialing Plan
Local & Toll Calls Within and between NPAs 215, 267 & new NPA 10 digits (NPA-NXX-XXXX)*
Local & Toll Calls Originating in NPAs 215, 267 and new NPA and terminating in other NPAs 1+10 digits (1+NPA-NXX-XXXX)
Operator Services
(Credit card, collect, third party)
HNPA or FNPA 0+10 digits (0+NPA-NXX-XXXX)
* 1+10 digit dialing for all HNPA and FNPA calls permissible at each service provider's discretion.

 When the 215/267 NPA exhausts, all Central Office (CO) code assignments will be made from the new overlay area code. Industry participants also reached consensus to recommend to the Commission a nine-month schedule for implementation of the overlay with relief in place six months prior to the forecasted exhaust.11 12 13 14 The recommended schedule is as follows:

Recommended Implementation Schedule for All Services Distributed Overlay

Event Timeframe
Customer Education and Network Preparation Period* 9 months
Earliest Activation of CO codes in the new NPA At the completion of customer education and network preparation period
* There is no requirement for a permissive dialing period because mandatory 10 or 1+10-digit dialing is already in place.

 The Industry states that adhering to the proposed timeframe will avoid the denial or delay of service to telecommunications providers' customers due to the unavailability of CO codes.

III. Discussion

 The FCC has adamantly maintained that state commissions cannot engage in number conservation measures to the exclusion of, or as a substitute for, timely area code relief.15 Therefore, when Pennsylvania's area codes are about to exhaust their supply of NXX codes, the Commission must implement timely area code relief, i.e., add a new area code. When faced with the need to implement new area codes, the Commission must decide two very important issues. First, the Commission must decide how to implement the new area code (i.e., a geographic split or an overlay). Second, the Commission must determine when the new area code needs to be implemented. As discussed earlier, because of the existing overlay in the 215/267 area code, only one method of area code relief has been recommended as appropriate. That is the overlay.

 Because an overlay is currently in existence in the 215/267 area code, we will not recommend public input hearings. The purpose of public input hearings is to get the public's input to assist the Commission in making the decision on which area code relief to implement. Currently, customers residing in the 215/267 geographic region already use 10-digit dialing for local and long distance calls. Therefore, they are familiar with how it works. It would not be appropriate in this instance to introduce an area code split in this geographic region. Instead, the Commission directs the Bureau of Communications to work with the industry, media and Law Bureau to hold Consumer Education Forum(s) to be held closer to the roll out date of the new area code. At that time, customers will be able to ask questions that they have regarding the overlay of the new area code. The location(s) and time(s) for the Consumer Education Forum(s) will be established by the Office of Communications in conjunction with the Industry and the Law Bureau.

A. Form of Area Code Relief for the 215/267 NPA

 According to the FCC, state commissions must add new area codes when the existing area codes exhaust or are about to exhaust all their NXX codes. Consequently, the critical element for deciding when to add new area codes is knowing when the area code will exhaust all of its NXX codes. State commissions have no involvement in predicting or projecting the exhaust dates for area codes. The FCC has delegated this responsibility to the NANPA.

 The NANPA projects exhaust dates for area codes by averaging the past rate of assignment of NXX codes and using that to estimate the future rate at which NXX codes will be assigned. Because these variables are so fluid, projecting accurate exhaust dates is difficult. Thus, with constantly changing information such as this, it is difficult to determine when Pennsylvania's area codes will exhaust and thereby require the addition of new area codes to ensure that all telecommunications carriers have numbering resources.

 Once NANPA has determined that area code relief is necessary, state commissions are faced with the task of deciding what form that relief should take. As stated earlier, because of the current overlay in the 215/267 NPA, the Commission was only presented with the option of another overlay for area code relief. The Commission therefore will not seek comments on any alternatives to the recommended relief submitted by the NANPA.

 Pennsylvania has experienced both area code splits and overlays. There have been a total of five overlays since 1999 (484, 267 and 878 have been implemented and 835 and 445 were activated but later rescinded). Prior to 1999, three geographic splits have been implemented (610, 570 and 724). There are benefits and disadvantages to either method.

 With the imposition of an overlay, existing land-based telephone customers are not likely to have to change telephone numbers. Therefore, customers will not need to change their advertising and stationery. However, the FCC requires that ten digits be used to dial all numbers in the overlaid area when an overlay is implemented. Thus, seven-digit dialing is no longer permissible or valid. New NXX numbers from the new area code are assigned to carriers that do not have numbers available in a given rate center. Therefore, the first three digits of a ten-digit telephone number around the corner or down the block might be from the new area code. Eventually, a single customer might have two different area codes for telephone lines serving his or her home or place of business if the existing carrier has run out of numbers in an NXX assigned to the old area code. Local calling areas will not change regardless of the new area code.

 Customers in the 215/267 NPA are familiar with the purpose and mechanics of an overlay, having experienced it before. Nonetheless, the Commission will direct the Office of Communications to hold public information session(s) in conjunction with the industry, Law Bureau and media to ensure that the public is aware that a new area code will be implemented in their calling area.

 B. Implementation Schedule and Activation of the Relief Plan Chosen for the 215/267 NPA

 While a state commission may not utilize numbering optimization measures in lieu of implementing timely area code relief, a state commission may minimize the consumer impact of traditional area code relief by not implementing new area codes sooner than necessary. Subsequent to filing the Petition, on September 9, 2016, NANPA notified the Commission of a revised projected exhaust date for the 215/267 NPA. NANPA estimates that the forecasted exhaust date has been modified and accelerated to the second quarter of 2018. NANPA states that this revised date reflects an increase in the actual and forecasted code demand.

 The current overlay relief plan proposed by the industry allows nine months for full implementation of the new NPA. According to this timeline, nine months is an adequate amount of time for customer education and network preparation since mandatory 10 or 1+10-digit dialing is already in place in the 215/267 NPA. Moreover, the Commission's experience with area code overlays is that they can be fully implemented within six months. Consequently, the Commission agrees that the nine-month timeline is reasonable for implementation of an overlay for the 215/267 NPA.

 As stated in the Petition, the CO codes in the new overlay NPA will be assigned upon request upon the effective date of the new NPA code. At exhaust of the 215/267 NPAs, all future code assignments will be made in the new overlay NPA code.


 The policy of the Commission is to ensure that numbering resources are made available on an equitable, efficient and timely basis in Pennsylvania while ensuring that the impact of proliferating new area codes on consumers is as minimal as possible. In this instance, the Commission notes that an overlay is the least disruptive method of resolving the 215/267 NPA exhaust issue. As mentioned earlier, we direct the Office of Communications to work in conjunction with the industry, media and Law Bureau in holding Consumer Education Forum(s) to ensure that the public is aware that a new area code will be implemented in their calling area. This will allow customers to get answers to any questions they may have; Therefore,

It Is Ordered That:

 1. The Petition for Approval of Numbering Plan Area Relief Planning for the 215/267 NPA filed by the North American Numbering Plan Administrator is hereby granted.

 2. The industry consensus recommendation set forth in the petition for an all services distributed overlay relief plan for the 215/267 NPA is hereby approved.

 3. The Office of Communications is directed to educate the public about this change through public forums and other tools, at the appropriate time prior to the implementation of the area code.

 4. The Office of Communications will handle the publishing of notices about the consumer education forums.

 5. A copy of the press release regarding the Consumer Education Forum(s) shall be posted on the Commission's website at

 6. A copy of this order shall be published both in the Pennsylvania Bulletin and on the Commission's website.

 7. A copy of this Order shall be served on the Office of Consumer Advocate, the Office of Small Business Advocate and Wayne Milby and Kimberly Wheeler Miller of the North American Numbering Plan Administrator.

 8. A copy of this order shall be served upon the Office of Communications.


[Pa.B. Doc. No. 16-2057. Filed for public inspection November 23, 2016, 9:00 a.m.]


1  The NANPA is the entity that allocates numbering resources and monitors the viability of area codes to determine when all of the numbers available in the area code are nearing exhaust. The Industry Numbering Committee Guidelines provide that when an area code is nearing exhaust, the NANPA, which then becomes the NPA Relief Planner, convenes a meeting of the industry to discuss relief alternatives. NPA Code Relief Planning & Notification Guidelines, INC97-0404-016, reissued Nov. 8, 1999, at Section 5.5. If the industry reaches a consensus, then its consensus plan is filed with the Commission and the Commission has an opportunity to take action at that point. NPA Code Relief Planning & Notification Guidelines, INC97-0404-016, reissued Nov. 8, 1999, at Section 5.6.

2  A consensus is established when substantial agreement has been reached. Substantial agreement means more than a simple majority, but not necessarily unanimity. CLC Principles and Procedures, May 1998, at Section 6.8.8.

3  47 U.S.C. § 251(e)(1).

4  See In the Matter of Petition for Declaratory Ruling and Request for Expedited Action on the July 15, 1997 Order of the Pennsylvania Public Utility Commission Regarding Area Codes 412, 610, 215, 717; Implementation of the Local Competition Provisions of the Telecommunications Act of 1996, Memorandum Opinion and Order and Order on Reconsideration, 13 FCC Rcd 190029 (1998).

5  Telephone numbers consist of 10 digits. The first three digits make up the area code, and the second three digits make up the NXX code. Each NXX code contains 10,000 numbers and each area code contains approximately 792 NXX codes.

6  In 1994, the original 215 NPA in southeastern Pennsylvania was geographically split and the 610 NPA was introduced.

7  By Order entered May 21, 1998 at Docket No. P-00961061, the Commission directed that the 215 and 610 NPAs, or area codes, in the southeastern portion of this Commonwealth receive individual overlay NPAs so as to address the prevailing NXX code shortage problem. The 215 NPA received the 267 overlay NPA and the 610 NPA received the 484 overlay NPA.

8  The 570 NPA was a geographic split of the 717 NPA and was activated on April 8, 1999. On July 15, 2010, the Commission approved an all services overlay at P-2009-2117193, as the relief method for the 570 NPA. The new 272 NPA served the same geographic area as the 570 NPA and was activated on October 21, 2013.

9  By Order entered July 15, 1997, at P-00961027, the Commission directed that the original 412 NPA in western Pennsylvania be geographically split with the new 724 NPA. The Pittsburgh metropolitan area would retain the 412 NPA with the surrounding communities transferring to the new 724 NPA. The new 724 NPA was activated on February 1, 1998.

10  The 412 NPA was declared to be in jeopardy on October of 1999, by the NANPA. On January 19, 2000, an industry consensus was reached to institute an all services multiple overlay. Therefore, on August 17, 2001, the 878 NPA was activated and overlays both the 412 and the 724 geographic areas.

11  The 2016 NRUF Report can be accessed on the NANPA website at

12  Attached as Exhibit B to the Petition.

13  47 C.F.R. § 52.19(c)(3)(ii).

14  The recommended relief should be in place six months prior to the forecasted exhaust. NPA Relief Planning Guidelines at Section 7.2.

15  In the Matter of Numbering Resource Optimization, CC Docket Nos. 99-200, 96-98, NSD File No. L-99-101 (2000).

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