PULP Submits New Evidence to PSC Showing No Need for Area Code Changes Now in Central NY 315 Area

On April 28, 2009, PULP submitted a Further Supplemental Brief on Exceptions with the New York State Public Service Commission (“PSC”) regarding the Recommended Decision issued in November 2008 calling for an overlay area code to be added in the current 315 area. PULP previously submitted a Brief on Exceptions outlining the reasons why area code “relief” is not necessary and filed a Supplemental Brief in March with updated data from the North American Numbering Plan Administrator (“NANPA”).

PULP previously uncovered evidence that multiple 10,000 telephone number exchange (NXX) codes had been assigned to over 50 rural communities in the 315 area code in recent years, which created a perceived impending “shortage” signaling the need for a new area code. See:PULP Submits More Evidence to PSC Showing that a New Area Code in 315 Region is Unnecessary, which contains a list of prior posts on this topic.

In the Further Supplemental Brief, PULP noted that after we filed the Supplemental Brief, NANPA issued two documents which further support PULP’s position that it is premature to enact any area code changes in the 315 NPA.

First, NANPA’s March 2009 monthly Code Assignment Report states that the number of NXX codes requested in the 315 NPA for the first three months of 2009 stood at zero with one returned. As a result, when combined with NXX code usage for the latter part of 2008, there has been a total of negative one NXX codes assigned in the 315 NPA since October 2008 and 99 NXX codes remain available.

This changed factual circumstance is buttressed by NANPA’s release of its semi-annual “NPA Exhaust Analysis” on April 24th. This document indicates that since the previous semi-annual report was released in October 2008, the life of the 315 NPA has been extended yet another full year – from the first quarter 2012 to the first quarter 2013. The listing for the 315 NPA also includes a notation indicating that the code is now facing “reduced historical and projected demand.” This extension marks the fourth consecutive semi-annual NPA Exhaust Analysis to push the date of the 315 NPA exhaust further out. In fact, since this proceeding commenced, two and a half years have been added to the life of the code. (Stated another way, on December 20, 2007, when the Commission instituted this case, NANPA’s projected 315 NPA exhaust date was the third quarter 2010, or about 34 months. Now, after the passage of 15 months, the exhaust date is 43 months in the future).

Based on the current code usage trends, the next NANPA exhaust analysis could push the date out even further, even if no new measures are taken by the Commission to reclaim scores of little-used NXX codes currently stranded in rural areas, as PULP recommended. As a result of these updated findings, PULP reiterated its position that there is no need to implement any new area code changes now in the 315 area.

Lou Manuta

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