Area Code Relief Public Hearing
810/586 Area Code Overlay
Overlay Proposal
Thursday, November 9, 2000
INTRODUCTION
Good afternoon, my name is Brooks Patterson. I am here today as Oakland County Executive to support the Flint Area Chamber of Commerce in their opposition to the proposed 810/586 area code overlay plan.
I appear here for two reasons: first, Oakland County agrees with the recommendations set forth in the Flint Area Chamber's presentation and asks that the MPSC adopt them.
Secondly, if our friends in the Flint area are forced into an expensive, confusing area code overlay program, can Oakland County be far behind? I think not. We know that the 248 area code is facing an overlay as well.
So to the point: I am here to let the Michigan Public Service Commission (MPSC) know that Oakland County believes that immediate, decisive MPSC action implementing several well considered telephone numbering resource optimization strategies, strategies not requiring new area code assignments, should become the Commission's top priority.
BACKGROUND
Some may ask, "Why is the elected Executive of Oakland County concerned about area code overlay proposals?"
Oakland County is interested because the citizens and businesses of Oakland County, including an overwhelming majority of our Automation Alley businesses, have learned that the so-called "relief" offered by the introduction of a new area code, whether by geographic split or by overlay, is too costly, too disruptive and too temporary to provide meaningful relief.
Oakland speaks from hard won experience. On December l, 1993, Oakland's residents and businesses were "relieved" from threatened area code 313 number exhaustion by implementation of the 810 area code.
All too shortly thereafter, May 10, 1997, they again needed to be "relieved," this time from threatened 810 area code number exhaustion. Relief was suppose to be accomplished by the forced implementation of our current 248 area code.
Now, like our neighbors in the 810 area code, our residents and businesses are again facing costly and disruptive "area code relief" action. This time, the proposed relief is offered in the form of a forced implementation of a new "all services" overlay area code in the 248 Numbering Plan Area (NPA).
Oakland County's all-too recent repetitive experiences with "area code relief" has taught our residents and businesses that the "relief" offered by the assignment of a new area code is illusory.
Instead of addressing and solving the fundamental, underlying causes of the number depletion crisis, implementation of a new area code simply hides it. Our new area code assignments have proven themselves to be convenient window dressings, ones concealing from public scrutiny the real danger facing our national telecommunications system: the total exhaustion of the nation's telephone numbering resources.
THE CRISIS: TOTAL NUMBER EXHAUST
The Federal Communications Commission (FCC), and numerous other telecommunications experts have identified and discussed what I have labeled "the real danger."
For some time, it has been clear that, absent prompt remedial action by state and federal regulatory agencies, total North American Numbering Plan (NAPA) number exhaustion -the running out of area codes available for assignment -will occur within this decade, perhaps even as early as 2007.
The literature indicates that if this numbering exhaust is allowed to occur, a fundamental restructuring of the North American dialing format will be required. The dialing format restructuring being discussed by the industry involves the adding of one or more numbers to the existing 10-digit dialing format.
The FCC has estimated that such dialing format restructuring would cost the US economy $150 BILLION, or more. (New switches, new software, even home alarms would have to be replaced.)
As responsible officials, we cannot allow the $150 BILLION bill to become due. Especially when responsible independent experts have shown that the need for a $150 billion number restructuring can be completely avoided by the prompt implementation of less costly numbering resource optimization strategies.
Oakland County believes that the Michigan Public Service Commission should draw the line. Do not authorize the addition of a new area code in the 810 area or any place else. Instead, demand service providers adopt more effective, longer lasting reform.
SOME FACTS TO CONSIDER
Let's briefly review some pertinent facts:
-Michigan's 9 current area codes provide plenty of numbers. Each area code has 7.92 million numbers. 9 x 7.92 million = 64.8 million numbers.
-Michigan's population is estimated at approximately 10 million.
-Obviously, with the potential for 64 million number assignments from service providers to customers, something no one alleges to have occurred, the problem can't be a lack of numbers. The issue is, where have they gone?
STRANDED NUMBERS
The telecommunications industry and the experts who study the industry know where the numbers are. They are "stranded" in the hands of the service providers.
According to an illuminating report issued for the Ad Hoc Telecommunications Users Committee by Economics and Technology, Inc.(ETI), the root cause of the numbering crisis is the unprecedented growth in unusable, unassignable, "stranded" telephone numbers. (See, Where Have All The Numbers Gone?, Second Edition, [June 2000], Economics and Technology, Inc., One Washington Mall, Boston, Massachusetts, 02108.)
ETI's report demonstrates that stranded numbers exist because area codes have been divided by service providers into numerous geographically minute rate centers.
According to ETI, the unprecedented growth in stranded numbers results from the fact that, under historic practice, the new competitive local exchange carriers (CLEC's) and other non-incumbent local exchange carriers (non-ILEC's) have been required to accept numbers in blocks of 10,000 in each rate center in which they want to provide service.
This practice has been required even if the CLEC had only a few customers in the rate area.
Once a number block of 10,000 is issued, all numbers in that block stay with the CLEC, regardless of fill or utilization rates. Those within the assigned block that remain unassigned to customers are "stranded."
Let's consider these facts in relation to the 810 area code.
According to the NPA Rate Center Map attached to the "Updated Initial Planning Document" provided my office by the MPSC staff, the 810 NPA has 56 rate centers.
Historic North American Numbering Plan (NANP) assignment practices combined with the continued use by service providers of multiple rate center billing models have required service providers to use a separate NXX or central office code for each rate center.
This means that, until now, a provider wishing to serve the entire 810 service area needed 56, 10,000 number blocks of NXX or central office codes. The 10,000 block NXX assignment practice meant that an area-wide provider needed and was assigned 560,000 numbers(56 x 10,000).
This 560,000 number assignment happened even if the provider had only a few customers in each rate area. All customer-unassigned numbers from those blocks are now "stranded."
This archaic practice must end. In their June 2000 report, the ETI authors demonstrate that if the number of rate centers is substantially reduced, and the currently stranded numbers reclaimed and issued, the nation's numbering crisis would end.
It is my understanding that, except for the providers themselves, no one really knows how many stranded numbers are in the hands of each service provider. But the number is clearly staggering.
According to the literature, given 800 NANP-NPA codes, 6.4 billion numbers are theoretically available for customer assignment. Only about 300 million, less than five percent, are currently in use.
We need to find, reclaim, and utilize these numbers.
I understand that both the FCC and the MPSC have recently taken steps to find and reclaim these stranded numbers. I commend those efforts.
In closing, let me reiterate: Oakland County believes that aggressive numbering resource optimization efforts should supplant new area code assignments as the preferred means of addressing the numbering exhaust crisis.
RECOMMENDATIONS
1. Stop the chaotic and confusing overlay. Instead, focus on numbering resource optimization.
2. Promptly adopt and implement the recommendations of Economics and Technology, Inc., as set forth in the report prepared for the Ad Hoc Telecommunications Users Committee, dated June 2000, and titled: WHERE HAVE ALL THE NUMBERS GONE?, Rescuing the North American Numbering Plan from Mismanagement and Premature Exhaust,(Second Edition).
3. Before authorizing any new area code, implement these proven numbering optimization measures:
A. Thousands-block number pooling.
B. Area Code Reclamation.
C. Conduct regular audits of utilization.
D. Consolidate rate centers.
E. Implement individual telephone number pooling.
I note that the MPSC's November 2, 2000 order is an excellent start toward these goals. But if 810, 248 and 313 number exhaustion is really imminent, I respectfully submit that the time line set forth in the November 2, 2000 order should be shortened.
Finally, if time and commerce really require adoption of a new area code, and if single service based overlays remain unlawful, Oakland County joins the Flint Chamber in recommending that new area codes be added by geographic split.
It is our belief that geographic splits would be less confusing and therefore better serves our residents, businesses and communities.
