KEITH R. McCALL, MEMBER COMMITTEES 313 SOUTH OFFICE BUILDING i HOUSE BOX 202020 TRANSPORTATION, DEMOCRATIC CHAIRMAN HARRISBURG, PENNSYLVANIA 17120-2020 PHONE: (717) 783-1375 POLICY COMMllTEE FAX: (717) 772-1231 NORTHEAST DELEGATION STATE TRANSPORTATION COMMISSION 301 E. BERTSCH STREET RAIL FREIGHT ADVISORY COMMIVEE LANSFORD, PENNSYLVANIA 18232 RAILROAD SYSTEM CHANGES TASK FORCE PHONE: (570) 645-7585 PA PEDALCYCLE AND PEDESTRIAN FAX: (570) 645-9526 ADVISORY COMMllTEE puce of $bPreeentatifiee PA AVIATION ADVISORY COMMllTEE 800 MAHONING STREET, SUITE 2 LEHIGHTON, PENNSYLVANIA 18235-1246 COMMONWEALTH OF PENNSYLVANIA PHONE: (610) 377-6363 HARRISBURG FAX: (610) 377-5675

TESTIMONY OF State Representative KEITH R. McCALL 122~~Legislative District

Good Morning.

My name is Bob Mustin and I'm here on behalf of State Representative

Keith R. McCall, who represents the 122"~District, which includes all of Carbon

County and the borough of White Haven in Luzerne County. Representative

McCall sends his apologies for not being able to be here today. He asked me to

welcome you to Carbon County.

Area code proliferation has become a real issue for a number of regions

across the country, including Pennsylvania, most notably the Pittsburgh and the

Philadelphia areas, which have seen the highest number of new area codes, since

1994. These additional area codes are a nuisance for most individuals and

businesses, which are now required to dial 10-digit telephone numbers to reach

parties that are located only miles or less from their home or business. With

overlays, it could mean dialing a 10-digit number to reach a second line or fax

machine in your own home or office.

@ PRINTEDON RECYCLED PAPER Pennsylvania's 12 million residents are served by 12 area codes, representing 67.5 million telephone numbers. That's more than 5.5 telephone numbers per resident. In all honesty there is little or no need to add new area codes.

To explain the situation, you must first understand the history of telephone numbering in the United States.

Telephone numbers in the U.S. are based on the North American Numbering

Plan and consist of a three-digit area code followed by a three-digit NXX code or central office code and a four-digit number. AT&T developed the current method used to assign numbers in 1947. Each NXX code contains 10,000 number combinations for 10,000 telephone lines. Each group is allocated to the Incumbent

Local Exchange Carrier (ILEC) and all Competitive Local Exchange Carrier

(CLEC) in a specific geographic area.

The system was effective until 1996, when Congress passed legislation to allow competition among telephone carriers. This competition resulted in the proliferation of CLEC's and new requests for telephone numbers in overlapping areas.

Unfortunately, with deregulation no changes were made to the 10,000 number allocation rule, no matter how many lines a CLEC actually needed. To ensure enough new numbers, the Federal Communications Commission (FCC) gave state public utility commissions across the country the authority to introduce new area codes. This is why area codes are being added on an almost annual basis.

In actuality, there are as many as 7.5 million usable telephone numbers in each area code and as few as half of those numbers are assigned before a new area code is introduced. In June 1999, two new area codes were introduced to

Pennsylvania: 267 in the 215 area code geographic area and 484 in the 610 geographic area. The 878 area code was introduced in the 412 and 724 geographic areas on July 12'~of this year. Earlier this year, the PUC was able to suspend activation of overlay codes of 835 in 6101484 and 445 in 2151267.

During 1999-2000 session of the General Assembly, the House as a collective body adopted a resolution, which Representative McCall sponsored. The resolution urged the FCC to mandate certain telephone number conservation methods and overhaul the system used to allocate telephone numbers.

In July of 2000, the FCC granted the PUC permission following the submission of a petition to take steps to reduce the allocation of numbers in the major metropolitan areas of Pennsylvania to blocks of 1,000. In June of this year

Representative McCall and all of his colleagues who represent districts wholly or partially within the 570 area code petitioned the FCC to delegate additional authority to the PUC to implement telephone number conservation measures in the

570 area code. Specifically, the members of the House of Representatives from the geographic area covering the 570 area code requested that the FCC grant additional authority to the PUC to implement mandatory thousands-block number pooling in the 570 area code. It is believed that the PUC is also looking at pursuing this approach with carriers on a voluntary basis in both the 570 and 717 area codes.

Representative McCall applauds the efforts of the Public Utility

Commission in reclaiming unused numbers. The PUC is actively ordering the return of numbers in the various area code regions to free up telephone numbers in all of the area code regions and allow them to be used more efficiently. The PUC returns

these unused numbers to the North American Numbering Plan Administrator

(NANPA), which is responsible for distributing area codes. NANPA could then

reassign the numbers to another carrier. Representative McCall is greatly relieved

by the FCC's recent decision to adopt telephone number utilization standards for

carriers. The Federal utilization standards will require carriers to use at least 60%,

which increases to 75% over the next 3 years, of the telephone numbers in their

inventories before they can request more numbers in their service territories. These

steps should help slow down the need for additional area codes supply and demand

of telephone numbers and avoid the continual need for a new area code in any of the regions of Pennsylvania.

Emphasis must be placed on efficient utilization and management of numbering resources. This can only be accomplished by securing accurate data on the number of telephone numbers in the inventories of telecommunications carriers

and entities that make use of numbering resources. Both wire line and wireless carriers and other entities that make use of numbering resources should be required to report telephone number utilization data to the PUC.

The utilization reports should be designed to include data on all telephone numbers, including assigned numbers, available numbers, administrative numbers,

reserved numbers, intermediate numbers, and residential and business numbers. A

clear understanding of how telephone numbers are utilized and managed by

carriers in an area code is the only way the Commission will be able to ascertain

whether a specific area code is running out of telephone numbers and if area code relief is needed. The Commission should develop procedures to better manage the assignment of NXX cod Cs. Under no circumstances should NXX codes be permanently assigned to an entity that has not established a customer base in Pennsylvania.3 The fact that a company is certificated and has an approved interconnection agreement with a local exchange carrier should not be the criteria for receiving NXX codes.

The Commission should also develop rules to govern the assignment of NXX codes required to be made available to carriers under the FCC's area code overlay rules. Such rules should endeavor to ensure that the NXX codes assigned to carriers pursuant to FCC overlay rules are only assigned to new and existing certificated facilities based CLEC9s.

Representative McCall urged the Commission in his testimony before a PUC

Administrative Law Judge at a public input hearing in Wilkes-Barre last December on the possibility of an overlay of the 570 area code to investigate and study

Individual Telephone Number (ITN) pooling, Unassigned Number Porting (UNP), and NXX code sharing as additional tools for conserving telephone numbers, especially since the FCC has not discounted individual telephone number pooling and unassigned number porting as conservation measures.

Individual telephone number pooling is a number conservation measure in which carriers receive telephone numbers from a Pooling Administrator using Local

Number Portability one at a time, rather than in blocks of 10,000 or 1,000.

Unassigned number porting and NXX code sharing describe the transfer of telephone numbers from one company to another. Like individual telephone number pooling, unassigned number porting and NXX code sharing requires deployment of Local Number Portability. The Commission should encourage carriers to voluntarily participate in Unassigned Number Porting and NXX code sharing if there are no public safety or network reliability concerns.

Representative McCall wrote a letter last year to William Kennard, former chairman of the FCC in which he stated, "legislators and not regulators have been placed in the position of explaining new area codes and listening to constituent discontent over regulatory policies that cost and inconvenience them, rather than help." Representative McCall has pledged to work with other legislators, the

Commission, and consumer advocates to develop and implement measures to address the telephone numbering crisis in Pennsylvania.

In conclusion, Representative McCall feels that the overlays or splitting of existing area codes are an easy short-term fix to a long-term problem, which if left unchecked, will eventually lead to the demise of our telephone system. He strongly suggests that the Commission develop and implement number conservation strategies, including statewide thousand-block number pooling, individual number pooling, individual number porting and NXX code sharing. If the Commission continues to use area code relief as its primary tool for resolving the numbering crisis and continues its slow pace toward implementation of conservation measures, people and businesses in Pennsylvania will continue to be forced to endure the costs, inconvenience, confusion, and anticompetitive effects of new area codes; facts which are not in the public interest but wholly in the economic interest of telephone companies and other entities that use telephone numbers.