FILED 10/24/2019
DOCUMENT NO. 09550-2019
FPSC- COMMISSION CLERK
State of Florida
Public Service Commission
CAPITAL C IRCLE OFFICE CENTER • 2540 SHUMARD O AK BOULEVARD
TALLAHASSEE, FLORIDA 32399-0850
-M-E-M-0-R-A-N-D-U-M-
DATE: October 24, 2019
TO: Office of Commission Clerk (Teitzman) }J' {J, Jd'f- M
FROM: Office of Industry Devet~rment and Market Analysis (Deas, Fog,;-m:m, Wendel,
Yglesias de Ayala) f'r\':}fT ~~/\...\) flMIIJ KntJ
Office of the General Co~l (Dziechciarz, Weisenfelark.Ju/ v(J .. ~ v
RE: Docket No. 20 190135-TP - Petition of North American Numbering Plan
Administrator on behalf of the Florida telecommunications industry, for approval
of relief plan for the exhaust of the 850 area code.
AGENDA: 1115119- Regular Agenda - Interested Persons May Participate
COMMISSIONERS ASSIGNED: All Commissioners
PREHEARING OFFICER: Polmann
CRITICAL DATES: The estimated exhaust date for the 850 area code is third
quarter 2021
SPECIAL INSTRUCTIONS: None
Case Background
On June 27, 20 19, 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 the Industry ' s consensus decision to implement an
all-services overlay as the area code relief plan for the 850 Numbering Plan Area (NPA).
NANPA projects that the supply of central office codes in the 850 NPA will exhaust during the .
1
third quarter of 202 1. Consequently, NANPA is requesting that the Commission approve the
recommended 13-month implementation schedule. ·
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NANPA ' s petition indicates the projected 850 area code exhaust date as first quarter 2022 ; however as of October
20 19 the forecasted exhaust date is thi rd quarter 202 1.
Docket No. 20 190 135-TP
Date: October 24, 2019
NANPA is the neutral third-party administrator that administers 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 NPA which are each identified by a three-digit NP A
code, commonly called an area code. Telephone numbers are in a 10-digit format, consisting of a
3-digit area code, a 3-digit central office code (NXX), and a 4-digit station address code (for
example 850-4 13-0000). Each N PA is divided into local serving areas called rate centers. Rate
center boundaries determine if a call is local or long distance. Originally, telephone numbers
were assigned to carriers in number blocks of 10,000. However, in an effort to conserve
numbering resources, the thousand-block number pooling system was implemented. The
thousand-block number pooling system allocates telephone numbers to carriers in blocks of
I ,000 instead of the historical 10,000. Under this system, an unused 1,000 number block can be
reclaimed and returned to inventory if it is not activated within six months of being assigned,
tmless the carrier can provide the Commission w ith a valid reason for needing an extension. Each
area code contains 792 usable prefixes containing 10,000 numbers each. Once all of the prefixes
have been assigned, a new area code is necessary.
T he 850 area code was introduced in 1997 when the 904 area code needed area code relief due to
substantial growth in demand for telephone numbers. The Commission approved a geographic
split as the form of relief for the 904 area code. The 850 area code was then assigned to the
northern portion of Florida known as the Panhandle. This area is made up of 64 rate centers and
18 counties, which include cities such as Pensacola, Panama City and Tallahassee. Also located
within the 850 area code are Eglin and Tyndall A ir Force Bases. Proactive number conservation
methods such as the imp lementation of thousand-block pooling in 2003 extended the life of the
850 area code.
In October 2018 , NANPA forecasted a need for area code relief for the 850 area code.
Subsequently, pursuant to the area code Relief Planning Guidelines, NANPA began the relief
planning process by announcing the need for relief and distributing an initial planning document
to the Industry? NANPA then hosted an Industry relief meeting on May 16, 20 19, to discuss
possible relief alternatives for the 850 area code. During the meeting, the Industry reviewed four
relief options and reached a consensus to recommend the all-services distributed overlay plan to
the Commission as the preferred method of relief for the 850 area code.
On June 27, 20 19, NANPA fi led a petition with the Commission on behalf of the Industry
requesting approval of the consensus decision. The Commission has jurisdiction to address this
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T his document included descriptions, maps, general facts and assumptions, and the projected life of two area code
re lief a lternatives, an all-services distributed overlay and an area code boundary e limination overlay involving the
386 area code. A geographic split in the 850 area code did not meet the N PA code relie f planning guide lines;
there fore, NAN PA did not recommend a geographic split for consideration. T he Industry a lso proposed two
additiona l boundary e limination overlay a lternatives.
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Docket No. 20 190 135-TP
Date: October 24, 2019
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.
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Docket No. 20 190 135-TP Issue 1
Date: October 24, 20 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 850 area code?
Recommendation: Yes, the Commission shou ld approve the Industry's consensus
recommendation of an all-services distributed overl ay as the area code relief plan for the 850
area code. (Deas, Fogleman, Wendel , Yglesias de Ayala, Dziechciarz, Weisenfeld)
Staff Analysis: Area code relief responsibilities have been delegated to the states by the
Federal Communication Commission (FCC) pursuant to 47 C.P.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 deal
with 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 exhausti ng NPA into two geographic areas, leaving the
existing area code to serve one NP A and assigning a new area code to serve the remaining 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 bow1daries. 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 17 years ago.
Industry guidelines specify that in the case of a geographic split, a difference in area code life
expectancies between two areas should be 10 years or less. 3 According to NANPA, a geographic
split in the 850 NPA would result in an exhaust life that exceeds this 10 year limit between the
two areas. Therefore, no split alternative was included in NANPA' s petition.
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 nwnber; 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 NP A. 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
3
NPA Code Relief Planning & Notification Guidelines ATIS-030006 1 - Section 5.0 (g).
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Docket No. 20190135-TP Issue 1
Date: October 24,2019
geographic area as the area 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 the new telephone numbers are expected to be
concentrated in one section of the existing NPA. For example, a fast growing
metropolitan area and a sparse ly populated rural area could exist within the same NP A.
The overlay area code would be assigned initially to the section of the NP A
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. This method is not
appropriate for the 850 NPA because there are multiple concentrated rate centers through
out the geographic area.
c) Boundary Elimination Overlay - With a boundary elimination overlay, the NPA
requiring relief is adjacent to an NP A with available numbering resources. The
boundary between these NPAs is eliminated, and spare telephone numbers from the
adjacent area code are assigned within the original NP A boundary where relief is
required. This solution. has the advantage of not requiring a new area code, but it would
not provide long-term relief for the 850 NP A.
d) Multiple Overlay - The multiple overlay strategy may be considered where relief is
required in an NP A 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.
The 850 NPA does not currently have multiple area codes; therefore, this option was
not applicable.
On May 16, 2019, NANPA held an Industry meeting in order to reach a consensus on a relief
plan for the 850 NPA. The following four relief plans were considered.
Alternative #1 -All-Services Distributed Overlay (see map in Attachment A)
A new area code would be assigned to the same geographic area occupied by the existing 850
area code. One of the advantages to this alternative is that existing customers wou ld be able to
retain their current telephone numbers, and it provides for easier customer education and
minimizes customer confusion. Also, this alternative is easier to implement from a technical
perspective. The projected life of this method would be approximately 41 years, which is the
longest of all the alternatives. However, 10-digit local dialing would be required by all customers
within the NPA.
Alternative #2- NPA Boundary Elimination Overlay (see map in Attachment B)
The boundary between the existing 850 and 386 NPAs would be eliminated and the two area
codes would be assigned to the same geographic area. This alternative would allow customers
assigned to both the 850 and 386 area codes to retain their telephone numbers and would
eliminate the need for a new area code. Eliminating the boundary between these NP As would
result in a projected life of approximately 19 years before additional relief would be required.
However, it would require ten-digit dialing for customers within the now combined NPAs. The
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Docket No. 20190135-TP Issue 1
Date: October 24, 2019
forecasted exhaust of the 386 area code is more than 30 years; therefore, this alternative would
result in premature 10-digit dialing for customers in the 3 86 NP A.
Alternative #3- NPA Boundary Elimination Overlay (see map in Attachment C)
The boundary between the existing 850, 386, and 904 NPAs would be eliminated, and all three
area codes would be assigned to the same geographic area. Customers would retain their current
telephone numbers; however, ten-digit dialing would be required. At exhaust of the 850 area
code, all future telephone number assignments would be made from the 3 86 and 904 area codes.
Eliminating the boundary between these NPAs would result in a projected life of approximately
18 years before additional relief would be required.
Alternative #4- NP A Boundary Elimination Overlay (see map in Attachment D)
The boundary between the existing 850, 386, 904, and 352 NPAs would be eliminated.
Customers would retain their current telephone numbers; however, ten-d igit dialing would be
required. At exhaust of the 850 area code all future telephone number assignments will be
assigned from the 386, 904, and 352 area codes. Eliminating the boundary between these four
NPAs would result in a projected life of approximately 18 years before additional relief would be
required.
After review of the four alternatives and the related information, the Industry reached a
consensus recommending Alternative No. 1, an all-services distributed overlay, as the relief plan
for the 850 NP A. The Industry decided against the boundary elimination overlay alternatives for
the following reasons: 1) the boundary elimination alternatives would force premature 10-digit
dialing in the area codes that currently are not in need of relief; 2) the all-services distributed
overlay provides a longer projected life for the overlay area; and 3) the boundary elimination
overlay alternatives would pose complex customer education processes in multiple NPAs, which
likely would lead to increased customer confusion.
Overlay Dialing Plan
If any of the four alternatives are approved by the Commission, the dialing plan will be as
follows:
• Local Calls Will require 10-digit dialing (as required by the FCC)
• To ll Calls 1+ 10-digit dialing
• Operator Calls 0+ 10-digit dialing (credit card, collect, third party)
Proposed Implementation Schedule
The Industry has recommended a 13-month implementation schedule. This schedule includes
six-months for network preparation, followed by a six-month permissive 10-digit dialing and
customer education period. New codes are not activated until one month after the mandatory 10-
digit dialing period. During the permissive dialing period, calls within the 850 area code can be
completed using either 7-digits or 10-digits. The purpose of the permissive dialing period is to
faci litate transition from 7-digit to 10-digit dialing by educating customers on the impending
changes without impacting the calls. Following the six month permissive dialing period,
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Docket No. 20190135-TP Issue 1
Date: October 24, 20 19
mandatory 10-digit dialing will be required. If the required 10-digits are not dialed, the caller
will receive a recorded message advising them that the area code is required to complete the call.
This schedule will allow the Industry sufficient time to implement the new area code prior to
exhaust of 850.
Discussion
In order to educate and receive customer input, staff held a customer workshop on September 6,
2019, in Tallahassee, Florida. During this workshop there were presentations by Commission
staff and representatives from NANPA 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 has since received one customer comment which was in favor of the all-services overlay
alternative.
Staff notes that all four alternatives have similar advantages and disadvantages for customers.
Basically, customers wo uld be able to keep their telephone numbers; however, they will be
required to dial 10-digits for all local calls. Staff believes the most significant customer impact
will be the imposition of 10-digit dialing for customers who otherwise would not be affected for
another 30 years or more. Therefore, staff agrees with the Industry that reducing the number of
customers that would be impacted by 10-digit dialing is the more favorable approach.
Upon analysis of number utilization information, staff notes that in recent implementation of area
code relief, once the new area code was available carriers immediately began to submit requests
for numbers in the new area code. This practice has lead to numbers remaining available in the
exhausting area code after the projected exhaust date. Based upon staffs analysis, it appears
carriers are prematurely requesting these numbers in order to obtain a specific range of numbers
(i.e. vanity numbers). Staff believes this is an ineffi cient use of numbering resources and
recommends that numbers in the new area code not be assigned until all remaining 850 area code
prefixes have been assigned.
Conclusion
Staff agrees with the Industry that the boundary elimination alternatives would force premature
10-digit dialing in the area codes that currently are not in need of relief. Further, the boundary
elimination alternatives would require complex customer education processes that would cause
customer confusion. In addition, the projected life of a boundary elimination alternative would
be shorter than the all-services overlay. Therefore, staff recommends that the Commission
approve the Industry's proposed all-services distributed overlay as the relief plan for the 850 area
code. Additionally, staff recommends Commission approval of the proposed thirteen-month
implementation schedule, which includes a six-month customer pennissive dialing period.
Finally, staff recommends the Commission order that telephone numbers, specifically central
office codes in the new area code, be available for assignment only when all assignable prefixes
in the 850 area code have been assigned.
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Docket No. 20190135 -TP Issue 2
Date: October 24, 2019
Issue 2: Should this docket be closed?
Recommendation: Yes, staff recommends that this docket should be closed. (Dziechciarz,
Weisenfeld)
Staff Analysis: Upon issuance of the Order and conclusion of the protest period this docket
should be closed.
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Docket No. 20190 135-TP Attaclunent A
Date: October 24, 20 19
Alternative #1 - ALL-
SERVICES DISTRIBUTED
OVERLAY-
• Customers would retain
their current telephone
numbers
• Ten-digit local dialing
would be required Within
the two area codes
• The projected Iife would
be approximately 41
years
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Docket No. 20 190 135-TP Attachment B
Date: October 24, 2019
Alternative #2 -850/386
Area Code BOUNDARY
ELIMINATION
OVERLAY-
• 850 and 386 customers
would retain their current
telephone numbers
• Ten-digit dialing would be
required for all calls
within the 850 and 386
area codes
• The projected life would
be approximately 19
years
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Docket No. 20 190135-TP Attachment C
Date: October 24, 2019
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Alternative #3 - 850/386/904
AREA CODE BOUNDARY
ELIMINATION OVERLAY-
• 850, 386, and 904
customers would retain
their current telephone
numbers.
• Ten-digit dialing would be
required for all calls within
the 850, 386, and 904
area codes
• The projected life would
be approximately 18
years
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Docket No. 20 190 135-TP Attachment D
Date: October 24, 2019
Alternative # 4 -
850/386/904/352 AREA
CODE BOUNDARY
ELIMINATION
OVERLAY-
• Customers in the 850, 386,
904, and 352 area code
would retain their current
telephone numbers
• Ten-digit dialing would be
required for all calls within
the 850 , 386 , 904, and 352
area codes
• The projected life would be
approximately 18 years
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