Potential Block Contamination Abuses Reclamation of Prefixes Analysis of 1. The Need to Audit the Data Like much of the country, California currently is experiencing a numbering crisis.
From to January , the number of area codes in this state increased gradually from 3 to During the next three years, however, the number of area codes in California nearly doubled. By the end of , California had 25 area codes statewide. Without the implementation of major number conservation measures, the telecommunications industry had plans underway to add 22 more area codes in California by the end of , resulting in a statewide total of 47 area codes.
This study recounts the history of the area code, from the time it was included in the area code. It now covers the northern part of San Diego in Southern California.
This report should be viewed in a broader context than the facts pertaining solely to the area code. The report evaluates the status of number availability in the area code, and discusses the various state and federal policies which govern number use in California and nationwide.
In addition, the report analyzes number use by carrier category and identifies what measures the CPUC can employ in the and other area codes to improve efficiency of number use in order to prematurely avoid opening new area codes. Data is self-reported by the companies; the CPUC staff has not audited any utilization data submitted for this study and report.
The utilization study sheds new light on the numbering crisis in the area code. The data reveals that despite increasing demand for numbers, the area code is not fully utilized.
The study found that of the 7. The data further establishes that the area code possesses considerable room for growth, and thus, aggressive measures such as splits or overlays are not yet warranted in the area code. Chapter , In November , TD completed utilization reports covering the , , , and area codes. TD also released utilization reports on the , , , and area codes in March In May , TD released another four reports covering the , , and area codes. In July , TD released an additional four reports on the , , , and area codes.
This report on the area code continues TD's analysis covering specific area code number utilization levels. The area code contains approximately 7. These numbers are available to telecommunications companies that obtain the numbers from the North American Numbering Plan Administrator NANPA , 1 and in turn, assign the numbers to their customers for their immediate use. Alternatively, companies may reserve numbers for future use, or retain numbers for some internal administrative use.
Some companies provide blocks of numbers to resellers or "dealers", which then assign those numbers to customers. The FCC deems numbers that companies allocate to resellers to be "intermediate" numbers. In addition, each assigned number, after disconnection, must "age" during a transition period before assignment to the next customer.
Many companies have inventories of numbers in the "aging" process. Finally, some numbers in this area code are not available for public use, as they have been set-aside for emergency purposes, for technical network support, or for other reasons. The FCC has determined that numbers in these five categories - assigned, administrative, reserved, intermediate, or aging - are unavailable, either because they are already in use or are designated for some present or future use.
TD's analysis shows that of the 7. Wireline carriers, such as Pacific Bell and many competitive local exchange carriers, hold roughly 1. At the same time, the study finds that under FCC rules, about 1.
The FCC has determined that wireless carriers do not have to participate in the pool at this time. Thus, 1. The study further finds that of the 6. The first table below illustrates the current distribution of numbers assuming that pooling is in effect in the area code. The second table shows the distribution that would occur if all the recommendations in this report were implemented. Finally, the study notes that companies identify 1.
TD staff recommends specific measures the CPUC can employ to ensure that companies use those "unavailable" numbers more efficiently. Given the near doubling of the number of area codes in California, from to , this vital public resource should be used as efficiently and effectively as possible. The CPUC and the telecommunications industry should strive to minimize the quantity of numbers left "stranded" in company inventories.
California is currently experiencing an explosive demand for telephone numbers and area codes. The increased demand for numbers is due to many factors, including competition for local phone service, as well as the popularity of faxes, pagers, cell phones, internet services, etc. California's robust economy and the growth in the state's population also contribute to the increased demand for telephone numbers.
This increase in demand is complicated by a number allocation system dating from the s that is inefficient in today's competitive marketplace. Prior to , one phone company 5 provided local telephone service to all customers in a particular area, and new area codes were opened as the population grew. The number of California area codes rose steadily from 3 in to 13 in , and stayed at that level until January By the end of , California had 25 area codes.
The Telecommunications Act of sought to open competition for the local telephone service market and competitive local phone companies 6 began to enter the marketplace, each requiring its own stock of numbers. The traditional system of number allocation was not designed to provide telephone numbers to more than one company.
In the past, when telecommunication companies needed telephone numbers to serve their customers, they received blocks of 10, numbers, i.
Because companies were assigned blocks of 10, numbers, they may have been assigned more numbers than they needed. For example, under this system, a company with only customers would have received a 10, number block, the same quantity of numbers a company with 9, customers would receive.
Thus, numbers are taken in these large blocks, creating an artificial demand for more numbers, which in turn fuels the need to open more area codes. The need to assign 10, numbers is a practice from the past when one telephone company provided service to all customers in its territory. Today, with over telecommunications companies in the state needing numbers to serve customers, and with the limited quantity of numbers available in each area code, this process is no longer an efficient way to allocate numbers.
The rise in demand for numbers combined with the inefficient allocation system for numbers has forced the rapid opening of new area codes throughout the state. Since , the number of area codes in California has nearly doubled to Without the implementation of major number conservation measures, the telecommunications industry had plans underway to add 22 more area codes in California by With more and more companies needing numbers of their own, new area codes are not necessarily the best solution.
The area code is a classic example of area code proliferation in California. The area code was created in when it was split from the area code. The area code was implemented in when it was geographically split from the area code. The area code was originally part of the area code, one of the first three area codes in California when the North American Numbering Plan was implemented in The area code originally covered all of southern California.
The area code was reduced in size by the creation of area code in , in , in , in , in , and in The area code was created in Therefore, the NANPA submitted for CPUC consideration an exhaust relief plan containing two alternatives for introducing a new area code into the area, to provide additional numbers for phone company use. The alternatives submitted included two three-way geographic splits. To create a new area code, the options are either splits or overlays. In an overlay, a new area code is created covering the same geographical area as the existing area code.
The area code was the first phase of the three way geographic split of the area code. The CPUC has deferred implementation of the second phase of the three-way split. In December of , by Decision. In that same decision, the CPUC required its Telecommunications Division TD staff to study number use to determine the quantity of available, unused numbers in the area code. This report fulfills that requirement. For those area codes nearing number exhaust, the CPUC has instituted a lottery process to fairly allocate the remaining prefixes among phone companies when demand exceeds supply.
There is no lottery. Therefore, companies receive numbers from Code Administration 8. For initial prefixes 9 , there is no restrictions as long as the company is authorized to provide telecommunications services in California.
Companies requested and received prefixes in the area code between January 1, and December 31, With the CPUC working with companies to reclaim excess prefixes held by companies, companies returned ten unneeded prefixes to the NANPA during the same period, for a net distribution of prefixes. During the first nine months of , twenty two prefixes have been requested and granted and 24 prefixes have been returned to the NANPA, for a net distribution of negative two prefixes.
As of September 30, , there were prefixes available for assignment in the area code. Recognizing the substantial social and economic burdens associated with constant area code changes, the CPUC has taken steps to resolve the numbering crisis. Responding to widespread public outcry over the proliferation of new area codes, the CPUC suspended, beginning in December , all plans for new area codes previously approved.
In July , the CPUC adopted number conservation measures, including establishing number pools, fill rates, and sequential numbering. In addition, the CPUC has ordered number pools for an additional four other area codes during Number pooling allows telephone companies to receive numbers in smaller blocks than the traditional 10, numbers, enabling multiple providers to share a prefix, thereby utilizing this limited resource much more efficiently. The technology that enables the network to support the assignment of smaller blocks is referred to as Local Number Portability or LNP.
This same platform is utilized for number pooling. Thirteen of the top MSAs are located in California; the area code is located in one of them. In the area codes with number pooling, wireline carriers participate in pooling and wireless carriers participate in the lottery or receive prefixes from Code Administration if no lottery.
In the remaining area codes with rationing in effect, all phone companies participate in the lottery. The CPUC has been aggressively setting up number pools. The CPUC also issued a more detailed schedule in February identifying the start dates for the nine number pools scheduled to begin in A pooling schedule has not yet been set for the area code.
Once pooling is implemented in the area code, all wireline companies with numbers in rate centers located in top MSAs in will be required to donate 1,number blocks to the pooling administrator.
While FCC rules only require companies to donate numbers to a number pool in rate centers located in top MSAs, many companies have implemented LNP capability throughout their service territories. These companies could also donate or receive thousand-blocks in all rate centers in an area code's number pool, rather than just in the rate centers located within top MSAs.
Under the number pooling program, all LNP-capable carriers will receive numbers in blocks of 1, on an as-needed basis. There is no rationing process in the pool and the blocks received can be put into service almost immediately upon receipt.
All wireless carriers, as well as wireline carriers who decline to take part in pooling in the rate centers not located in a top MSA, will continue to receive numbers in blocks of 10, through the monthly lottery allocation process or from Code Administration in area codes without a lottery process.
While number pools have improved the efficiency of the distribution of numbers to companies, companies have not had strong incentives to efficiently manage the numbers already allocated to them. Thus the CPUC ordered companies to improve number inventory management with measures including rules on fill rates and sequential numbering. In July , the CPUC issued Decision , which extended number conservation measures adopted in the area code to other area codes within California.
These number conservation measures include the following:. In each rate center in which companies request additional numbers, they must provide to the NANPA a form demonstrating they will be out of numbers within six months.
TD anticipates these policies will potentially free more numbers for use in number pooling, to be allocated through the lottery or from Code Administration, or to be otherwise used by companies. Indeed, these measures together with the effects of number pooling have already achieved some positive effects.
Another positive outcome is the recent increase in the number of prefixes in the area code being returned to NANPA by companies as mentioned in Section B. Therefore, the CPUC's number conservation policies pooling, fill rates, and sequential numbering are governed by the FCC's delegation of authority to the states.
As a result, the FCC has delegated authority to plan and implement area code changes, as well as authority to implement number conservation measures. On April 26, , the CPUC filed a petition with the FCC requesting authority to institute number pools and other number conservation measures within the state to better manage this public resource. When the FCC granted the CPUC the authority to deploy various numbering resource optimization strategies, including the authority to institute thousand-block numbering pooling trials, it also clarified that California's authority will be superseded by future national measures adopted by the FCC.
The definitions of numbers and timelines for aging and reserved numbers that were adopted in that order have been incorporated into the utilization data cited herein.
With the release of the first NRO Order, the FCC adopted a number of administrative and technical measures that will allow it to monitor more closely the way numbering resources are used and to promote more efficient use of numbering resources.
In particular, the FCC adopted a nationwide system for allocating numbers in blocks of one thousand, rather than ten thousand, wherever possible, and announced its intention to establish a plan for national rollout of thousand-block number pooling. Because the FCC recognized that state thousand-block number pools underway might not conform to the national standards set forth in the first NRO Order, the FCC gave state commissions until September 1, to conform their thousand-block number pools to the national framework.
The FCC also declined to adopt a transition period between the time that cellular carriers must implement LNP and the time they must participate in any mandatory number pooling.
In its comments prior to the release of the first NRO Order, the CPUC had argued that California would be precluded from exploring whether number pooling could alleviate the crises for number resources in many parts of the state that are located outside the top MSAs.
This grant of authority to California would make pooling possible throughout the state. Currently, state commissions are constrained by the FCC from establishing an area code specifically for wireless telecommunications services. In the area code, there are fifteen wireless carriers holding 60 prefixes. If the CPUC were allowed to create a separate area code for those companies, these 60 prefixes in the area code could be reassigned to other phone uses, thus prolonging the life of the existing area code.
In the Second Report and Order, the FCC asks for further comments on technology-specific or non-geographic area codes. Before requiring the residents and businesses of the area code to undergo another area code change, the CPUC recognized the necessity of determining the number of telephone numbers that are in use and the number yet to be used.
The definitions used in the utilization study and a list of companies holding prefixes in the area code are in Appendix A. Of the 7. The other 4. The CPUC's utilization study found that, of the 3. Therefore, 6. A portion of these unused numbers can be made available for use by all companies, either through pooling in the future or through allocation from Code Administration. In addition, companies have reported 1.
A portion of these unavailable numbers can be used more efficiently if the recommendations contained in this report are implemented. The CPUC asked 40 companies, holding prefixes 3. Of the 40 companies in the area code, 37 submitted utilization data. A list of the companies that have been allocated numbers in the area code appears in Appendix A The remaining three companies hold nine prefixes in the area code.
The area code has 6. Of these unused numbers, TD found that companies held 2. The remaining 4. The summary of available numbers is shown in the table below.
Type 1 Carriers 21 26, Numbers Available for Allocation from Code Administration 2,, Numbers Set Aside for the Number Pool 1,, Total Available Numbers in the Area Code 6,, Not all of the 6. Of the 6. The remaining 1. As shown in the table below, the CPUC could shift the availability of numbers from one category to the other by adopting the recommendations 23 in this report.
Current technology requires a company to be LNP capable in order to donate numbers for another company to use. All wireline carriers in the area code are required to be LNP capable. However, not all of these 1. TD will not know how many of these 1.
The difference between the potential maximum 1. The remaining , of the 1. However, companies can immediately use these numbers to provide service to their customers or meet other needs. Wireless carriers hold , unused numbers in the area code. Until wireless carriers become LNP capable in November , none of these numbers may be reallocated to other companies. In the interim, wireless carriers may assign these numbers to their own customers. TD analyzed the utilization data to determine the availability of numbers within blocks of different contamination rates in order to assess different contamination thresholds that the CPUC could apply to number pools.
The following table summarizes available numbers by contamination level, by rate center, for wireline carriers. Rate Center. The first two numeric columns of Table show the potential numbers available to a future number pool, except for those numbers kept for companies' six-month inventory, under current rules. Available numbers in one rate center cannot be used in another rate center. Table shows that all rate centers have available numbers that companies could donate to the pool. TD cautions that, although Table shows potential results from increasing allowable contamination levels, further analysis and input from the industry would be necessary to determine accurately the quantity of additional blocks that could be added to the pool while still leaving companies with a six-month inventory.
Table shows available numbers in blocks of differing contamination levels held by wireless carriers. Of these , unused numbers held by wireless carriers, TD estimates that , TD staff is investigating whether there are methods to make some of these , unused numbers available to other carriers despite the FCC's exemption of paging companies from the LNP requirement.
Viewing the utilization data suggests, that companies have not generally followed practices of sequential numbering and filling blocks substantially before using new blocks. The CPUC's rules on sequential numbering and fill rate practices promulgated in Decision are designed to ensure that companies efficiently use their numbers in the future.
Where companies possess significant available numbers in a given rate center, these two efficiency measures could prevent the opening of new blocks or prefixes.
Companies reported utilization data as of December 31, The sequential numbering and fill rate decision was issued in July Some of these practices of non-sequential numbering and not filling blocks substantially before using new blocks may have happened before the July decision.
TD does not expect companies to continue contaminating blocks unnecessarily. Decision directed companies to return prefixes that are held unused for more than six months. Of these unused numbers, , are in 24 whole prefixes 35 that are completely uncontaminated, i. The following table shows the breakdown between wireless and wireline carriers. Blocks Spare Prefixes Differing Prefixes.
The , numbers in 24 spare prefixes can possibly be reclaimed if not used within six months. The FCC granted authority to state regulatory commissions to investigate and determine whether prefix holders have activated prefixes within the allowed time frames, and directed the NANPA to abide by the state commission's determination to reclaim a prefix if the state commission is satisfied that the prefix holder has not activated the prefix within the time specified in the first NRO Order.
In this ruling, the CPUC instructed the delinquent companies to comply immediately. Companies are to inform the CPUC either that the prefix es have been placed in service or returned, that the company was incorrectly included in the NANPA's delinquent list, or the reasons the prefix es have not been placed in service.
The CPUC will review the reasons and make a determination as to whether the prefix es must be returned or reclaimed by the NANPA, or whether to grant an extension of time to the company to place the prefix es in service.
Any delinquent company that fails to comply will be subject to penalties and sanctions. In the following sections, TD recommends a series of policies designed to require companies to use unavailable numbers more efficiently.
These policies would potentially free more numbers for use in the future number pool, to be allocated from Code Administration, or to be used otherwise by companies. Companies report that 1. Companies commonly refer to these numbers as "unavailable". Unavailable numbers include not only those actually in use by customers, but also the following categories:.
In its first NRO Order, the FCC ruled that companies must show that they have used a certain percentage of their existing inventory of numbers before they may obtain additional numbers in a given rate center. This order specified that companies' utilization rates will be calculated using only assigned numbers in the numerator.
This method greatly increases companies' incentive to use number sparingly for purposes of reserved, administrative, intermediate, or aging numbers; none of those uses will raise a company's utilization rate and enable it to obtain additional numbers.
In the area code, there are 1. The percentages of assigned numbers to total numbers held by companies are shown in the table below. Assigned Numbers to Numbers Held by Companies in millions. Assigned Numbers Held by Companies Assigned. Non-Working wireless describes numbers assigned to wireless customer equipment, but which are not yet working.
These numbers are considered a sub-category of assigned numbers. For example, wireless carriers sometimes pre-package a cellular telephone with an assigned telephone number for sale to customers.
Although the number is assigned, it will remain inactive until a customer purchases the telephone. There are no non-working wireless numbers reported for this area code. While the quantity of non-working wireless numbers reported generally is low, this sub-category of assigned numbers could increase because there are no restrictions on the number of days that a wireless company can hold these numbers, causing numbers to remain idle for an unspecified period.
The CPUC should consider several options to improve inventory management of non-working wireless numbers. One option is for the CPUC to require companies to return these numbers to the available category after days similar to the requirement the FCC has established for reserved numbers. Recommendations for Treatment of Non-Working Wireless. Under these INP arrangements, two telephone numbers are associated with each customer.
LNP eliminates the need for two telephone numbers for each customer when the customers change companies because customers can take their numbers with them. Since the area code is included in one of the top MSAs in the nation, all wireline carriers should be LNP-capable. They reported a total of numbers in the area code.
Since all the reported INP numbers were from ILECs and none were from their competitors, it does not appear that INP exists in the area code to facilitate competition for customers. Historically, the telecommunications industry has designated certain prefixes for special uses, usually to an ILEC.
These include numbers for recorded public information announcements such as time-of-day, weather forecasts, high-volume call-in numbers, and emergency preparedness 38 numbers.
These prefixes are not made available for general commercial use, and thus numbers within these prefixes that are not in actual use lie vacant. In , companies decided not to duplicate the special use prefixes in each area code.
Concerned that this process could adversely affect the public, the CPUC directed that these prefixes should be duplicated in each new area code. The utilization study shows that 4 prefixes are dedicated for special uses: one each for directory assistance, high volume calling, time, and weather service.
TD questions the necessity of assigning an entire prefix for each of the purposes listed above. Furthermore, having multiple special use prefixes is an inefficient use of numbers in the area code as well as in other area codes in California. Cell phone users can skip the 1 prefix, but must dial the area code before the 7-digit phone number.
Read This. The change was initiated by the California Public Utilities Commission CPUC as a way to avoid the disruption caused by creating an entirely new area code. The commission decided to remove the boundaries between the and geographic areas, allowing the two area codes to be issued to phone users in the same region.
The area code is expected to use up its available prefixes by late next year. The area code has enough capacity to last another 30 years. Combining the two area codes should hold off the need for a new area code for at least 17 years.
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