STATE OF MAINE PUBLIC UTILITIES COMMISSION April 9, 2020 Docket No. 2020-00026 MAINE PUBLIC UTILITIES COMMISSION Inquiry into Preservation of the 207 Area Code NOTICE OF INQUIRY BARTLETT, Chair; WILLIAMSON and DAVIS, Commissioners I. SUMMARY Through this Notice, the Commission initiates an Inquiry to obtain information and viewpoints from interested persons regarding possible actions to extend the viability of the 207 Area Code. II. BACKGROUND In North America, telephone numbers are a sequence of ten digits, broken up into two sets of three numbers and one set of four numbers as in, for example, the Commission's telephone number: 207-287-3831. The first three-digit set is technically known as the Numbering Plan Area but is known colloquially as the "area code." This is the 207 in the Commission's telephone number. The area code is used to direct calls to a large geographic area and contains approximately 8,000,000 usable telephone numbers. The second three-digit set is technically called the "NXX Code" but is colloquially known as the "exchange"; this would be the 287 in the Commission's telephone number. The exchange is used to direct a call to a smaller geographic area within an area code.1 Each exchange contains approximately 10,000 usable telephone numbers which are broken up into 10 "blocks" of 1,000 numbers each. Each block of 1,000 is used to set the the last four digits of 1,000 telephone numbers. For example, the telephone numbers in a given exchange ending in 0000-0999 are a part of the 0block, the numbers ending in 1000-1999 are part of the 1-block, and so on. The set of four digits at the end of a telephone number is the called the "line number" and is used to direct a call to a specific telephone within a given exchange. This is the 3831 in the Commission's telephone number. Control of North America's telephone number supply is vested in the North American Numbering Plan Administrator, or NANPA, which in turn is a contractor hired by the FCC’s North American Numbering Council. NANPA maintains a "pool" of unused area codes, exchanges, and blocks of line numbers. This pool of numbers is overseen by the National Pooling Administrator, which is currently a company called Somos. 1 Exchange boundaries do not always match up with municipal or other political boundaries. Exchanges match up to "rate centers" which are actually billing areas that may cross municipal boundaries. Notice of Inquiry -2- Docket No. 2020-00026 Maine is one of a dwindling number of states with one state-wide area code, and the 207 area code is an integral part of Maine's identity. Unfortunately, according to area code exhaust projections from October 2019 released by NANPA, the 207 Area Code could be exhausted by the Third Quarter of 2024.2 Exhaustion is driven by at least three factors: first, there is the actual assigned and in-service usage of telephone numbers in an area code; second, there are numbers which are in the inventory of a service provider but are not in service because they are essentially "spares" held by the service provider based on forecasts they have generated of their expected need for numbers; or third, there are disconnected customer numbers which need to “age” a minimum amount of time before they can be re-assigned to a new customer. The forecasted need for numbers by a service provider plays into the specific problem raised by this Inquiry.3 To a lesser extent, the decline in wireline customers for local telephone service has also added to the quantity of now-unassigned numbers that might become available if current service providers who still hold them as “spares” were to return them to the pool for reassignment to a different service provider.4 NANPA considers an area code to be "exhausted" when, based on current usage and forecasted demand, the area code is around three years from having insufficient numbers left in the pool. As discussed below, the current program for assignment of exchanges and blocks can bring about exhaustion earlier than would otherwise be necessary. As an illustration of the early exhaustion problem, NANPA's recent report puts the actual utilization of numbering resources within Maine’s 207 area code at about 37%, but NANPA also forecasts that 207 is in imminent danger of exhaustion. How can this be? One factor is the anticipated need for future numbers. Another factor has to do with the way that numbers are assigned by Somos and its predecessor. Currently, when a provider needs line numbers in a given exchange—as discussed above, an exchange is assigned to a geographic area within an area code—the provider is given a 1,000 line number block in that exchange. If the provider utilizes more than 100 of those numbers, that block is considered "contaminated" and the block is then reserved 2 https://www.nationalnanpa.com/reports/2019-2_NPA_Exhaust_Projections_Final.pdf. An area code is "exhausted" when NANPA estimates, 3 This also includes would-be service providers as some providers who have requested and received large blocks of unassigned numbers are not currently service providers to customers in Maine. 4 However, these numbers being recycled from disconnected customers are usually not sequential, rather, they may be randomly distributed in the blocks of 1,000 numbers, creating what is known as “contamination” of these blocks of 1,000, should a service provider wish to offer a clean, uninterrupted sequence of local telephone numbers to a new customer. Notice of Inquiry -3- Docket No. 2020-00026 for the exclusive use of that provider.5 This clearly leads to inefficiencies. As an extreme example, let's take a hypothetical 555 exchange located in Mainetown, population 2,500.6 Let's assume that the borders of Mainetown and the borders of the exchange that serves Mainetown are the same. If five providers (one traditional land line provider, one cable telephone provider, and three cellular providers) each have two blocks in Mainetown's 555 exchange, and each provider is using only 101 numbers in each of their blocks, then you would end up with a situation where 1,010 line numbers would actually be utilized out of the potential 10,000 line numbers in the Mainetown 555 exchange, but no other providers could obtain numbers in that exchange because all ten line number blocks are "contaminated." The Mainetown 555 exchange would be "full" even though nearly 90% of the line numbers are currently unused. This same scenario occurs at a large scale with exchanges. To continue with the Mainetown example, because Mainetown's 555 exchange is now "full" while only utilizing around 10% of the line numbers, if another provider (for example another cellular carrier) needs line numbers in Mainetown, Somos will have to open a second exchange in Mainetown, thus taking 10,000 more line numbers and reserving them for Mainetown's exclusive use. Now Mainetown's 2,500 people have tied up 20,000 numbers. Granted, Mainetown is an extreme example, but it does illustrate how Maine's 207 area code can have 37% actual utilization but still be in imminent threat of exhaustion. The following is a map showing the current assignment of exchanges in Maine:7 5 Providers may return unused line numbers in uncontaminated blocks (i.e., line number blocks where less than 100 of the 1,000 line numbers are being used) back to the pool for assignment to other providers. 6 7 So, all of Mainetown's telephone numbers would be 207-555-XXXX (0000 to 9999). NANPA Central Office Code Assignment Records (available at https://nationalnanpa.com/reports/reports_cocodes_assign.html). Notice of Inquiry -4- Docket No. 2020-00026 Commission Staff track daily activity reports from NANPA and Somos to assess requests for new exchanges and new line number blocks to try and preserve 207. When possible, the Commission works with a provider seeking numbering resources Notice of Inquiry -5- Docket No. 2020-00026 and a provider in the exchange that may have line numbers in an uncontaminated block that can be donated back to the numbering pool. In an additional effort by the Commission to extend the life of 207, on June 26, 2019, the Commission filed a request with the FCC to join the New Hampshire Public Utilities Commission in their effort to pilot Instant Telephone Numbering.8 Instant Telephone Numbering would be a "just-in-time" assignment of individual line numbers from the numbering pool for a given exchange, rather than the assignment of 1,000 line number blocks to individual providers. It is the Commission’s belief along with the New Hampshire commission that Instant Telephone Numbering is a better use of a limited resource and offers providers an efficient way to access the numbers they actually need versus removing an entire 1,000 line number block from the pool that may not always be utilized. Instant Telephone Numbering could effectively prolong the life of 207 for many years. There are other potential actions that could help slow the exhaustion of 207. One potential action is "rate center consolidation." As explained above, area codes are broken up into smaller geographic areas represented by exchanges. Exchange boundaries do not necessarily correspond exactly to municipal or other political boundaries. Technically, exchange boundaries correspond to the boundaries of what are known as "rate centers." Rate centers are geographically defined areas that were at one time used as billing zones and for determining which calls are "local" and which calls are "long distance," but these distinctions are of small consequence today. A given rate center can contain multiple exchanges. At a high level, rate center consolidation means the combining of two or more rate centers into one, geographically larger rate center. The following is an oversimplified example of rate center consolidation, using the Mainetown hypothetical from above. Mainetown's neighbor, Dirigoville, population 2,500, is located in its own rate center and has its own exchange: 111.9 In Dirigoville, however, there are only three providers using two 1,000 line number blocks each; Dirigoville, then, has four line number blocks, or 4,000 numbers, available. So, if Mainetown and Dirigoville were to merge their rate centers, the 555 exchange and the 111 exchange would serve both towns, and when a provider wanted to give a line number to a new customer in Mainetown they could use a 555 number or a 111 number, and not have to open a new exchange. Another possible action would be to increase the line number block contamination threshold. Going back to Mainetown, if the threshold for contamination of line number blocks was, for example, 30% instead of the current 10%, then providers could donate some of their blocks with 899 unused line numbers back to the pool; a block would only become contaminated, and unable to be donated back to the pool, if a 8 The request filed by the Commission and the NHPUC can be found at: https://ecfsapi.fcc.gov/file/10626976401465/2019-0626%20MPUC%20Letter%20to%20FCC%2099-200.pdf. 9 So, all of Dirigoville's telephone numbers would be 207-111-XXXX (0000 to 9999). Notice of Inquiry -6- Docket No. 2020-00026 provider used 301 line numbers in a given block. This way, if a new provider came to Mainetown, they could be assigned one of the donated 899 number blocks from the pool. Another option could be what is known as a "technology-specific overlay." With a technology-specific overlay, a specific technology or technologies (e.g., pagers, fax machines, or other non-voice uses) can be designated to use a new area code, thus preserving line numbers in the 207 Area Code for telephones. III. TOPICS OF INQUIRY Given the imminent exhaustion of 207, the Commission is opening this Inquiry to obtain answers from providers and interested persons to the following questions: A. Reclaiming Un-Pooled Blocks or Slightly Contaminated Blocks 1. Does your company hold any blocks that are currently un-pooled or only slightly contaminated that could be donated back to the 207-pool? 2. If yes, is your company willing to return any blocks that are un-used or under-utilized to improve the pool availability? B. Rate Center Consolidation 1. Please share with the Commission if your company has had any experience with Rate Center Consolidation (RCC)? 2. If you are a VoIP, Cable, or wireless company offering unlimited in-state and intra-LATA toll service, how would RCC impact the voice service product you provide if one or more rate centers are combined? a. b. c. 3. How would RCC impact the rates for the services to your customers? Are your rates the same statewide? Please provide your rates. If you are an ILEC or CLEC offering basic local calling service that is limited to a distinct geographic area such as a rate center, how would the combining of one or more rate centers impact the voice service product you provide? a. b. c. How would RCC impact the rates for the services to your customers? Are your rates the same statewide? Please provide your rates. Notice of Inquiry -7- Docket No. 2020-00026 4. If RCC is implemented, are there geographic boundaries that would be more favorable to providers such as by county? 5. If RCC is implemented, would it make sense to combine the rate centers of the ILEC ownership groups together? For example, all Consolidated Communications rate centers could become one rate center. 6. Would it make sense to turn the entire 207 Area Code into a single rate center? 7. Please describe what kind of costs may be involved in combining rate centers for your company? 8. Please share any other feedback you have about RCC, your experience with it, and your preference for how it could be implemented. C. Increase Block Number Contamination According to Numbering Resource Utilization/Forecast (NRUF) Data compiled by NANPA, 168 out of 247 Maine rate centers are utilizing less than 20% of their blocks.10 Many of these blocks in these rate centers have contamination levels that are higher than 10 percent, but lower than 25% (hyper-contaminated blocks). Currently, contaminated blocks greater than 10% usage are unavailable to be pooled to other carriers. In 2003, the FCC approved a trial to increase the contamination levels of two area codes in California from 10% to 25%.11 The study suggests that the trial had some success, but that further review of increasing contamination levels in the future would be beneficial. 1. If the Maine Commission seeks a trial from the FCC to increase contamination levels of blocks for use by service providers, please explain how creating hyper-contaminated blocks would impact your company? a. Are there any significant costs involved that would be different than using a contaminated block with less than 10% utilization? 10 The NRUF report is a confidential semiannual report providing utilization and forecasted block data compiled by NANPA. Information provided here is aggregated and not company-specific. 11 NANC, Report on the Impact of a 25% Number Pooling Contamination Threshold (April 30, 2004) (available at http://www.nanc-chair.org/docs/nowg/Mar0425_IMG_Final_Report.doc). Notice of Inquiry b. -8- Docket No. 2020-00026 If there are costs associated with increasing the contamination level of a block, how do they compare against adding a new area code? 2. Should the Commission seek a higher contamination level beyond 25%? 3. Please share any additional feedback your company may have on increasing the contamination level from 10% to 25%. D. Technology-Specific Overlay Another option available to Maine is to request a technology-specific overlay for the 207 Area Code from the FCC. It is the Commission’s understanding that if approved, this request would automatically trigger 10-digit dialing for all customers in both area codes, and as the 207 Area Code reaches exhaust, the technology-specific overlay would open to all new number requests. 1. Does your company have any experience with technology-specific overlays? 2. What costs are involved for the technology that moves to the technology specific overlay and what costs may be associated for the technologies that remain in the existing 207 Area Code? 3. If the Commission moves forward with this approach, which technology should the Commission choose to be considered for the technology specific overlay? 4. Please share any other feedback you may have about technology-specific area codes? E. Forecasting As stated above, the current actual utilization of the 207 Area Code is approximately 37%. However, forecasted demand plays a significant role in the exhaustion of an area code. The forecasted demand impacts the number of NXX codes opened for pool replenishment in rate centers where forecasted demand exceeds the number of available blocks. The Commission sees a trend whereby companies may be over-forecasting their need for blocks of numbers. The over-forecasting of numbers also causes blocks to be pulled out of the pool for six-months only to have them returned if they are not put into service. 1. Please share with the Commission the basic methodology for how your company forecasts the need for additional blocks in a rate center? Notice of Inquiry IV. -9- Docket No. 2020-00026 PROCEDURE This inquiry is intended to obtain information and viewpoints from interested persons regarding possible actions that may be taken to prevent opening an additional area code to preserve the 207 Area Code. The Commission directs the Presiding Officer to establish a procedural schedule that will allow interested persons to provide input to the Commission about these issues, expediting the process to the extent reasonably possible, while providing sufficient opportunity for a complete and thorough examination of the issues involved. The Commission requests responses be filed in the above captioned Docket no later than Friday, May 8, 2020. V. NOTICE The Commission will provide this Notice of Inquiry to all persons and entities that the Commission believes may have an interest in this inquiry. Dated at Hallowell, Maine, this Ninth Day of April, 2020 BY ORDER OF THE COMMISSION /s/ Harry Lanphear Administrative Director COMMISSIONERS VOTING FOR: Bartlett Williamson Davis Notice of Inquiry - 10 - Docket No. 2020-00026 NOTICE OF RIGHTS TO REVIEW OR APPEAL 5 M.R.S. § 9061 requires the Public Utilities Commission to give each party at the conclusion of an adjudicatory proceeding written notice of the party's rights to seek review of or to appeal the Commission's decision. The methods of review or appeal of Commission decisions at the conclusion of an adjudicatory proceeding are as follows: 1. Reconsideration of the Commission's Order may be requested under Section 11(D) of the Commission's Rules of Practice and Procedure (65-407 C.M.R. ch. 110) within 20 days of the date of the Order by filing a petition with the Commission stating the grounds upon which reconsideration is sought. Any petition not granted within 20 days from the date of filing is denied. 2. Appeal of a final decision of the Commission may be taken to the Law Court by filing, within 21 days of the date of the Order, a Notice of Appeal with the Administrative Director of the Commission, pursuant to 35-A M.R.S. § 1320(1)(4) and the Maine Rules of Appellate Procedure. 3. Additional court review of constitutional issues or issues involving the justness or reasonableness of rates may be had by the filing of an appeal with the Law Court, pursuant to 35-A M.R.S. § 1320(5). Note: The attachment of this Notice to a document does not indicate the Commission's view that the particular document may be subject to review or appeal. Similarly, the failure of the Commission to attach a copy of this Notice to a document does not indicate the Commission's view that the document is not subject to review or appeal.