AREA CODE RED

Though they may seem to play a minor role in life, people are surprisingly passionate about their area codes. It's not unusual for public meetings covering dialing changes to be standing room only and to feature intense, sometimes angry discussion.

These changes, though, are inevitable. The proliferation of telephony-based services has put a crunch on numbering resources in practically every urban area in the country, and the task of working through this number crunch has fallen to individual state public utility commissions (PUCs).

Recently, over the objections of wireless carriers, the FCC has allowed these commissions an extra tool to help with number utilization: the implementation of service-specific and technology-specific area code overlays.

In reversing an earlier ban on these overlays the FCC has, in a nutshell, given PUCs the right to appeal for the establishment of area codes that would be set aside for certain services, such as automatic teller machines (ATMs) and credit card-enable gas pumps or for specific technologies like wireless phones and pagers.

When making this decision, six states — California, Connecticut, Indiana, Massachusetts, Ohio and Pennsylvania — came forward in support of these overlays.

The gist of the states' comments was this: By placing service and technology-specific numbers in their own area code, the numbering demands on the existing area code will decrease. This will obviate the need for a split or an overlay of that area code, or number plan area (NPA), and will therefore maintaining its geographic integrity.

At the same time, such overlays could open up new resources to non-number pooling carriers, who might be subject to rationing or other limitations on numbering resources, while freeing blocks of numbers in the original NPA the non-pooling carriers had laid claim to.

Despite the potential benefits of technology-specific area code overlays, wireless carriers oppose them on several points, including the contention that these area codes are discriminatory.

According to a spokesman for Sprint, the Telecom Act of 1996 requires dialing parity between different technologies. If a wireless-only overlay were implemented in an existing NPA, calling between two landline or two wireless phones in that area might require only seven-digit dialing, while calling between a wireless phone and a landline would necessitate 10-digit dialing.

“People want to have ease of use. The idea of wireless and wireline parity is that it treats both methods of calling as equal in value,” said the spokesman. Wireless-only area codes, he said, would make dialing on wireless phones, “more complicated and harder to do than wireline.”

Though the spokesman declined to speculate on the negative effects these more complicated dialing patterns would have on wireless carriers, the implication is clear: Having separate area codes could drive down subscriber numbers and usage minutes, both of which would negatively impact a carrier's revenue.

Despite the claim of discrimination, though, some state PUCs and consumer advocates say that many consumers, including wireless users, would prefer the creation of a technology-specific area code over a geographic split or all-services overlay. If forced to choose, these customers would prefer to have their wireline phone identified with their current area code than their wireless phone.

“One of the things we've often heard…is that the public is very interested in being able to do an area code specifically for telephone numbers used for wireless companies,” said Phil McClelland, senior assistant consumer advocate with the Pennsylvania Office of Consumer Advocates. “The way it often comes out is, ‘let's put cell phone numbers in a different area code and maybe our particular area code won't have to go through relief.’”

All sides involved in the debate, though, acknowledge that this attitude, betrays a certain lack of understanding of numbering demand on the public's part. The wireless industry is not the sole cause of numbering pressure. Credit card-enabled gas pumps and cash registers as well as automatic teller machines and second phone lines for dial-up Internet connections all use telephone lines, creating additional pressure on numbering resources.

This could mean that in a given NPA wireless phones and pagers alone might not have the numbering demand to merit their own area code. This possible lack of demand, therefore, is another argument carriers make against tech-specific area codes.

If an existing NPA is faced with relief in the form of an area code split, there will likely be a temptation, fueled by public sentiment, to simply create a service or technology-specific overlay. Phone numbers, then, could be left stranded, which would only hasten the exhaust of available NPAs.

Some state PUCs, however, seem to recognize that the first priority when creating one of these overlays is efficient number utilization.

According to Deanne O'Dell assistant council with the Pennsylvania PUC, while maintaining geographic integrity of an existing area code would be a factor in the state's decision to create a service or technology specific overlay, “the bigger factor is the conservation of numbering resources. If there's any way [to conserve numbers] with any other type of conservation measure we would want to look at it very closely as well.”

Even if a service or technology-specific NPA is approved by the FCC, though, the possibility still exists that it could end up stranding numbering resources. To prevent this from occurring the commission laid out non-binding guidelines for what type of overlay it would most likely approve.

Since creating a new NPA in which numbering resources would go unused would go against the very reason a service- or technology-specific area code would be created, wireless-only area codes should be transitional in nature, changing to an all-services overlay once the original, landline NPA reaches exhaust. By using this trigger, demand on the new NPA would jump, thereby ensuring the best use of its numbers. (Recognizing the seriousness of the drain on numbering resources, many wireless carriers, while still opposed to technology-specific overlays, have indicated that transitional NPAs would in fact be acceptable.)

In addition, the FCC said these new area codes should cover multiple landline area codes to ensure the widest pool practical of potential users, a move that, again, would increase demand on the new area code.

Having a wireless-only area code cover many geographical NPAs, however, could lead to billing issues, said Roger Entner, program manager in the wireless mobile services practice area for The Yankee Group.

If a technology-specific area code covers multiple landline area codes, a call could be categorized as long-distance even if it is in the same NPA.

“They will have ungodly amounts of customer service calls saying, ‘I thought that was a local call and you billed me for a long-distance rate. I want my 15 cents reimbursed,’” he said.

In its ruling, the FCC also addressed the issue of take-backs when one of these new overlays is created. Take-backs, in which a number that has been distributed is reclaimed by the previous NPA and replaced by number from the new NPA, would be acceptable for point-of-sale devices, such as ATMs and cash registers, because computers, not consumers do the dialing, minimizing inconvenience to consumers and anti-competitive effects.

In the case of wireless services, the commission took a much stronger stand on the issue, however. Reclaiming numbers from wireless users would be a significant inconvenience to the consumer, while placing the onus of managing take-backs on wireless carriers would be costly to those carriers. The FCC said it would likely oppose take-backs in this situation.

The commission, however, decided against a blanket prohibition on take-backs, however, because creating one of these overlays, “without freeing up numbering resources in the underlying area code may not provide meaningful benefits because the life of the underlying NPA would not likely be significantly prolonged.” For take-backs to be acceptable, the commission said state PUCs would have to show the affected consumers support such a measure; be required to plan a phased in take-back approach that would ease the burden on customers and service providers; and would have to provide incentives for both to relinquish their existing numbers.

Though all of this is just theory, the application of these ideas should soon be put to the test. Supplementing a March 2001 filing that requested transitional overlays to serve non LNP-capable carriers — the bulk of which are wireless providers — on January 9 Connecticut requested that the same NPAs include non-geographically sensitive numbers such as gas pumps and ATMs.

No timetable has been set for a decision.