Pennsylvania Office of Consumer Advocate
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5th Floor Forum Place
Harrisburg, PA 17101-1923

Phone: 717-783-5048 or toll free 800-684-6560
Fax: 717-783-7152


Committee on Consumer Affairs, Subcommittee on Telecommunications, House of Representatives

Hearing on Area Code Depletion

August 8, 2001

Jim Thorpe, Pennsylvania

Testimony of

Sonny Popowsky

Consumer Advocate of Pennsylvania


Thank you for the opportunity to appear before you today to address the issue of Area Code Depletion. This is an issue that has been of major concern to me and to the Office of Consumer Advocate for many years. With me here today is Philip McClelland, a Senior Assistant Consumer Advocate at my Office, who has served for the last two years as one of three consumer representatives on the North American Numbering Council. In that role, Phil has persistently presented consumer concerns about the cost and inconvenience of constant area code depletion and has urged the telecommunications industry to come up with less costly and more efficient responses to this problem.

It is particularly appropriate that this hearing is being held in Jim Thorpe, which is within the home district of Representative Keith McCall. Representative McCall, with the able assistance of Bob Mustin and Audrey Powell, has been a leader in the effort both in Harrisburg and in Washington D.C. to stop the squandering of telephone numbers that we are here to discuss today. Indeed, I would note that several Representatives from Northeast Pennsylvania have been active in protecting the interests of the consumers in this area with respect to this persistent problem.

My basic premise is that the proliferation of area codes across Pennsylvania and across the Nation would not be so bad if it were really necessary, or if it served some useful purpose. But in fact, because of the antiquated way in which telephone numbers have been distributed, millions of numbers are effectively being wasted, including millions of numbers in Pennsylvania. Most of the people in this room can easily remember when we had four area codes in Pennsylvania - 215, 717, 814, and 412 - and people could actually tell what part of Pennsylvania you were from if they knew your area code. We have now seen the 215 area code split and overlaid into four area codes (with two more ready in the wings), 412 into three area codes, and 717 divided into the 717 and 570 area codes. Only 814 remains unchanged.

It is true that we use more telephone numbers today than we did ten or twenty years ago, with multiple home phone lines, cellular phones, fax machines, modems and the like. If that were the cause of the problem, then area code depletion might be an acceptable byproduct of a booming telecommunications industry. But the real problem is not the telephone numbers that we are using, but rather the telephone numbers that we are not using. The fact is that there are about 7.7 million usable seven-digit telephone numbers within any particular area code. So with 10 area codes now in place, we already have approximately 77 million telephone numbers to serve Pennsylvania. We also know that even if every man, woman and child in Jim Thorpe and the rest of the 570 area code had a telephone, fax, cell phone, and beeper, they still wouldn't have used up the 7.7 million numbers in this area.

The problem, as I'm sure most of you are by now aware, is that until very recently, telephone numbers could only be distributed in 10,000 number blocks. This meant that if a new competitive local exchange company wanted to provide service in the telephone exchange serving Jim Thorpe, for example, it had to obtain 10,000 numbers, even if it only had a handful of likely prospective customers.

When our office first learned in April 2000 that the 570 area code was in jeopardy and that the industry was proposing to begin taking steps to add another area code, we were frankly astounded. I had attended the public hearings that were held in Northeast and Southcentral Pennsylvania, when it was decided that the original 717 area code would be geographically split, and the people and businesses of Northeast Pennsylvania would have to accept a new area code. This change, of course, required the consumers in this area to incur substantial expense and inconvenience, but it was worth it, in part, because they could preserve 7-digit local dialing and would not face the confusion and anti-competitive effects inherent in the use of an overlay area code where more than one area code is present in the same area. When the 570 area code was introduced it was projected that it would last through 2005. Yet, less than two years after the 570 area code was actually implemented, the people of this area were told that 570 was running out of numbers and that yet another new area code would have to be established.

When our office began to look behind the numbers that caused this phenomenon, we realized that hundreds of thousands of numbers were indeed not being utilized. For example, we found one telecommunications company that was headquartered in Little Rock, Arkansas, and which we had never heard of, but which had been assigned 150,000 telephone numbers in Wilkes-Barre alone. Wilkes-Barre, however, has a population of about 42,000 people, none of whom to our knowledge were being served by this company. Indeed the company's name wasn't listed in the Wilkes-Barre phone book. When we contacted the company in Little Rock, we were told that the company intended to provide internet access service in certain metropolitan areas of Pennsylvania such as Wilkes-Barre. In fact, we also learned that the company also had been assigned 160,000 numbers in Harrisburg and 160,000 numbers in Allentown as well. In all, the company had 570,000 numbers across Pennsylvania. Interestingly, effective July 29, 2001, the company has returned all of its numbers to the area code administrator.

Please don't misinterpret my remarks. I support local telephone competition in Pennsylvania and I recognize that every local telecommunications company needs equal access to telephone numbers in order to do business. But we must recognize that our existing number pool is limited and should not be squandered without further thought.

There must be a better way to distribute telephone numbers across Pennsylvania, and fortunately there is. It is now technologically feasible to distribute numbers in 1,000 rather than 10,000 number blocks. Our Public Utility Commission was initially granted authority by the Federal Communications Commission to begin 1000-block pooling in our largest metropolitan areas, around Philadelphia and Pittsburgh. But those areas already have multiple area code splits and overlays. In pleadings to the PUC, our Office urged the Commission to expand 1000-block pooling to the 570 and 717 area codes so that these areas can avoid or at least delay the need to split again or to establish an overlay code that would require 10-digit dialing. Most importantly, Verizon, Sprint, CTSI and a number of other telecommunications providers have now petitioned the PUC for authority to do 1000-block pooling in the 570 and 717 area codes on a voluntary consensus basis. I believe the industry should be commended for this proactive step, and I hope that the Public Utility Commission will approve that Petition at its next meeting, scheduled for tomorrow, August 9.

In addition to 1000 block pooling, the PUC also has begun to take steps to reclaim telephone number blocks that have been assigned to telephone companies but are not being used. The PUC is now using its authority to monitor the use of telephone numbers and this is already having a beneficial effect.

I would note in this regard that one of the bills now pending before the General Assembly, H.B. 868, would give our office, the OCA, access to number utilization data, subject to appropriate confidentiality protections. Our office would benefit from such data in our efforts to preserve our existing area codes and protect consumers from the needless expense and confusion of new area codes.

There are also a number of other tools that can be used to prevent unnecessary area code proliferation and several of these are spelled out in House Bill 868 and House Bill 302. Much can be accomplished already today, however, and I would not underestimate the effect of hearings like this one and the steady stream of letters from you and other members of the General Assembly to make my Office as well as the PUC and the FCC aware of the importance of this issue to your constituents.

Needless to say, the problem we're discussing today is not limited to Jim Thorpe or to Pennsylvania. But I would submit that this is as good a place as any to commit ourselves to taking all actions necessary to stop the squandering of our finite numbering resources.

The alternative to such a commitment is not just to force new area codes in Northeast Pennsylvania, but ultimately and perhaps not in the too far distant future to run out of three-digit area codes altogether. Under the North American Numbering Plan, there are 684 usable three-digit area codes and 361 have already been assigned. This means that we have already used more than half of all area codes available. Last year alone 28 new area codes were assigned. Given the recent rate of growth, some plans are already being made as to how to change our 10-digit telephone numbering system to 11 or 12 digits. Adding more area codes to Pennsylvania is a costly problem. But changing all the telephone numbers used in our Nation is an enormous one.

Moving to 11 or 12 digit numbers would not only tax our memories a little harder, but would also mean that much of our telephone equipment and the data bases in which we store these numbers would have to be reprogrammed. The FCC has estimated that it may cost $50 billion to $150 billion(1) to expand the North American Numbering Plan - costs that are comparable and similar in some respects to the Y2K problem that we recently prepared for and overcame. But it was inevitable that the Y2K problem would occur once the calendar reached January 1, 2000. It is not inevitable, however, that we will run out of 10-digit telephone numbers in the next 10 years or even 25 years if we use sensible number conservation measures. There are 5.3 billion telephone numbers in the North American Numbering Plan. The exhaustion of the North American Numbering Plan in the near future can be avoided. Today's hearing is a step in that direction.

Thank you again for the opportunity to testify today. I would be happy to try to answer any questions that you may have.

1. Number Resource Optimization, Notice of Proposed Rulemaking, 14 FCC Rcd 10322 (released June 2, 1999) at ¶ 6.




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