1442 Implementation of number conservation measures granted to the Commonwealth by the Federal Communications Commission in its order released July 20, 2000--1K pooling; M-00001427 P-00961027F0002

Implementation of Number Conservation Measures Granted to the Commonwealth by the Federal Communications Commission in its Order Released July 20, 2000--1K Pooling; M-00001427 P-00961027F0002

[31 Pa.B. 4356]

Public Meeting held
July 13, 2001

Commissioners Present:  Glenn R. Thomas, Chairperson; Robert K. Bloom, Vice Chairperson; Aaron Wilson, Jr.; Terrance J. Fitzpatrick

Order

By the Commission:

Introduction

   On May 24, 2001, the Commission adopted an order directing that Pennsylvania's second interim pooling trial be implemented in the Pittsburgh area on October 29, 2001. We also directed all local number portability-capable (LNP) carriers who have numbers in the 412 and 724 area codes (also referred to as Numbering Plan Areas or NPAs) to implement various pre-pooling guidelines, such as block protection, on June 25, 2001. Finally, we also requested comments from interested parties regarding implementation issues and indicated that a second order would be adopted at a July public meeting. In this order we name NeuStar, Inc. as our pooling administrator, schedule the First Implementation Meeting for August 6, 2001, at 11 a.m. and set forth parameters regarding the current rationing in the 412 area code in consideration of the pooling trial.

Background

   Federal and State statutes have afforded new telephone companies the opportunity to compete against existing ones for local telephone business.¹ These statutes were designed to foster competition in the telecommunications marketplace with the hope of ultimately lowering prices and improving choices for consumers. Unfortunately, however, the proliferation of fax machines, computer modems, cellular phones, and competitive carriers in the local service market have created an unprecedented demand for NXX codes.² Consequently, area codes are rapidly exhausting in Pennsylvania and Nationwide.

   The Commission, in addition to other state and Federal regulators as well as the telecommunications industry, has been dedicated to finding a solution for this complex numbering problem for several years. Efforts concerning numbering resources have focused both on developing methods of allocating numbers more efficiently and on developing methods for increasing carriers' accountability for the numbering resources they are allocated. One conservation measure with the potential of significantly slowing the depletion of numbering resources is number pooling. ''Pooling'' refers to sharing spare resources, and thousands-block pooling (1K pooling) is a method of assigning them. In number pooling, there is an inventory of telephone numbers that participating service providers³ share and use in groups of 1,000 numbers. The entity that monitors the pool and allocates the pool's resources is the Pooling Administrator. Service providers participating in the pool contribute numbers to the pool through 1,000 block donations. When these resources are not enough to meet the forecasted needs of the participating service providers, then the Pooling Administrator seeks a 10,000 block (or NXX code) assignment from the North American Numbering Plan Administrator (NANPA).⁴

   On July 20, 2000, the FCC issued an order (FCC's Delegation Order) granting the Commission's request to implement 1K pooling on an interim trial basis in Pennsylvania.⁵ More specifically, the Commission was given the authority to implement 1K pooling in the Philadelphia Metropolitan Statistical Area (MSA)⁶ or the Pittsburgh MSA and in any new NPA implemented to relieve numbering shortages in these two MSAs. The Commission was required to first implement 1K pooling in a single MSA and not expand to another MSA until pooling was fully implemented in the initial one. Using this authority, the Commission implemented Pennsylvania's first interim 1K pooling trial on April 27, 2001, in the Philadelphia area 610/484 NPAs.⁷

   Upon implementation of our first interim 1K pooling trial, we mandated in our May 24, 2001, order that our second 1K pooling trial commence on October 29, 2001, in the 412 and 724 NPAs as well as the 878 NPA (which overlays both 412 and 724). Further, we sought comments regarding various implementation issues such as what company should be selected to administer our Pittsburgh area and any other future pooling trials and how to deal with the rationing currently in effect in the 412 NPA. Comments were due on July 2, 2001, with no provision for reply comments. We received and considered comments from Verizon Pennsylvania Inc. (Verizon), The United Telephone Company of Pennsylvania and Sprint Communication Company L.P. (Sprint) and AT&T Wireless Services, Inc. (AT&T Wireless). We adopt this second pooling order as a result of the review of the comments filed.

   The Commission remains committed to having adequate numbering resources available to all telecommunications providers while being mindful of the impact of proliferating new area codes on Pennsylvania's citizens. By implementing 1K pooling in combination with other number conservation measures,⁸ the Commission will better ensure that telecommunications carriers have adequate numbering resources without needing to resort to adding new area codes.

Discussion

I.  NeuStar Will Administer All Future Pennsylvania Pooling Trials

   In our May 24, 2001, order on this matter, we sought comment regarding what company should be our interim pooling administrator for the Pittsburgh and subsequent pooling trials in Pennsylvania. The interim pooling administrator handles the mechanics of the 1K pooling trial and, at the time of our May 24, 2001, order, there were potentially two companies which could administer the pool, Telcordia Technologies and NeuStar, Inc. Although NeuStar was selected as the interim pooling administrator for our 610/484 1K pooling trial, the final order regarding that pooling trial⁹ did not indicate that NeuStar would administer subsequent 1K pooling trials in Pennsylvania. Therefore, since Telcordia was still interested in administering pooling trials when our May 24, 2001, order was adopted, we decided that both NeuStar and Telcordia should have the opportunity to submit comments to us explaining why their company should administer Pennsylvania's future pooling trials.

   We did recognize in our May 24, 2001, order, however, that the FCC was in the process of naming a National pooling administrator. In the FCC's Numbering Order,¹⁰ the FCC determined that 1K number pooling should be implemented nationally by a National pooling administrator chosen by the FCC.¹¹ To that end, the FCC sought bids from interested companies and stated that 1K number pooling would be implemented on a National level within 9 months of the selection of a National pooling administrator.¹² Further, the FCC stated that upon the rollout of National pooling, all existing interim state trials would be taken over Nationally.

   As of our May 24, 2001, order, the FCC had not selected which company would administer the National 1K pooling trials. Therefore, we decided in our May 24, 2001, order to seek comment on which company should serve as our future 1K pooling administrator. However, we did indicate that if the FCC selected a company prior to July 2001, then we would select that same company as our pooling administrator on a going-forward basis. On June 18, 2001, the FCC named NeuStar as the National pooling administrator.¹³ Therefore, we will also name NeuStar as our interim pooling administrator for the Pittsburgh area pooling trial and for any other future Pennsylvania trials.

II.  Our Second Interim Pooling Trial Will Be In The 412, 724 and 878 NPAs

   We indicated in our May 24, 2001, order that our second interim 1K pooling trial will commence in the 412, 724 and 878 NPAs. While Sprint requests that the Commission limit the Pittsburgh area 1K pooling trial to the 412 NPA, it does not offer any supporting reasons. In its comments, Verizon also argues that the pooling trial should only be implemented in the 412 NPA and offers several reasons in support of this assertion. First, Verizon states that by pooling in the 724 and 878 NPA we will be violating FCC requirements that state commissions implement pooling in three NPAs per Number Portability Administration Center (NPAC)¹⁴ region per quarter. Second, Verizon states that pooling in more than three NPAs per NPAC quarter per region is not practicable for large ILECs like Verizon because of the extensive operating support systems work it must do to identify, verify and remove thousand blocks for donation to the pool in each NPA. Third, Verizon argues that pooling in the 878 NPA, if pooling is only implemented in one of the underlying area codes (412), will be difficult to implement. Finally, Verizon notes that the effect of not adding the 724 NPA to the pooling trial will only be minor because the 724 NPA is in the Pittsburgh MSA and if it is put into jeopardy, it will be scheduled for National pooling sooner.

   Although the request that we limit the Pittsburgh area pooling trial to the 412 NPA is untimely,¹⁵ we have carefully considered and rejected this request for all of the following reasons. First, pooling has already occurred in more than three NPAs in the Mid-Atlantic region during the second quarter of 2001. In April 2001, Pennsylvania's first interim 1K pooling trial was implemented in the 610 and 484 NPAs. In June 2001, 1K pooling was implemented in Virginia's 804 and 434 NPAs. Consequently, in the second quarter of 2001, pooling was implemented in four NPAs in the Mid-Atlantic NPAC region. Verizon states that New Jersey is ''booked'' for pooling in January and February 2002 in two of their NPAs. However, January and February are not part of the fourth quarter 2001 which is when pooling will be implemented in the Pittsburgh area. We are only aware of pooling scheduled in Virginia's 757 NPA on October 12, 2001, and Virginia's 540 NPA on November 15, 2001. Therefore, the addition of Pennsylvania's 412 and 724 NPAs would mean the implementation of 1K pooling in four NPAs¹⁶ in the Mid-Atlantic region for the fourth quarter of 2001 as was done during the second quarter of 2001.

   Second, while we are mindful of the work involved for all carriers to implement 1K pooling, we do not believe that implementing pooling in all the Pittsburgh NPAs will unreasonably burden carriers. With respect to the ILECs, the 412 NPA is exclusively the territory of Verizon. However, there are three other ILECs in the 724 NPA geographic region and they comprise approximately half of the geographic area. Therefore, the burden of implementing a pooling trial in both of the geographic areas served by the 412 and 724 NPAs will not rest solely on one ILEC.

   Third, we disagree with Verizon's assertion that the practical effect of not adding the 724 NPA into the pooling trial may only be a small one. To the contrary, we believe that by not adding the 724 NPA into the pooling trial we will be diminishing the success of the Pittsburgh area pooling trial. The purpose of 1K pooling is to preserve as many NXX codes as possible to lengthen the life of the area code. Further, in the specific circumstance of Pittsburgh, we want to preserve both the 412 and the 724 NPAs to avoid the premature assignment of new NXX codes from the 878 NPA. Thus, if we preserve many NXX codes in the 412 NPA through pooling but allow the 724 NPA to continue depleting its resources through NXX code assignment, then the 878 NPA will need to be opened to fulfill the needs of the 724 NPA. Consequently, any advantage gained in the 412 NPA as a result of pooling would be diminished by the fact that the 878 NPA overlay would need to be opened to alleviate the situation in the 724 NPA. Therefore, we believe pooling in both the 412 and the 724 NPAs is the best strategy to prevent the premature need to assign NXX codes from the 878 NPA.

   Fourth, we do not agree with Verizon's assertion that the 724 NPA could be pooled during National rollout sooner rather than later. Verizon bases this assertion on the premise that exhaust of the NXX codes in the 724 NPA would place the 724 NPA into a jeopardy status. According to Verizon, once the 724 NPA is placed into jeopardy, National pooling would come sooner. Area code relief, however, has been implemented for the 724 NPA in accordance with an industry consensus plan for the 878 NPA overlay. Therefore, the 724 NPA will not need to be declared to be in jeopardy; rather, when the 724 NPA NXX codes are exhausted then NXX codes from the 878 NPA will be utilized.

   Finally, we do not interpret either the FCC's Numbering Order,¹⁷ nor the FCC's Delegation Order¹⁸ as prohibiting us from implementing the Pittsburgh area pooling trial in the 412, 724, and 878 NPAs. Paragraph 159 of the FCC's Numbering Order states ''we also tentatively conclude that the [national] rollout should encompass a maximum of three NPAs in each NPAC region per quarter.''¹⁹ The restriction of the three NPAs per NPAC per quarter was in reference to the National rollout schedule. We find implementation of pooling in all three of Pittsburgh's area codes to be practical, reasonable and not unduly burdensome for all the reasons set forth above.

III.  First Implementation Meeting

   In accordance with the Section 7.2.2 of the Thousands-Block Number (NXX-X) Pooling Administration Guidelines, INC 99-0127-023, issued January 8, 2001, the pooling administrator is required to hold a public meeting with all the service providers expected to participate in the 1K pooling trial. NeuStar's practice is to have the First Implementation Meeting for a second pooling trial in a state via conference call. Therefore, we will direct that a First Implementation Meeting for the Pittsburgh area pooling trial be held on August 6, 2001, at 11 a.m. The materials for this call will be submitted by NeuStar at a later date.

IV.  Rationing in the 412 and 878 NPAs

   The 412 NPA was declared to be in jeopardy in October of 1999, and the industry subsequently reached a consensus to ration NXX codes at the rate of six per month. Using the authority we were delegated in the FCC's Delegation Order,²⁰ we entered an order on December 27, 2000, at M-00001427F0002 and P-00961027 directing that the rationing plan continue for 6 months after implementation of the 878 overlay. Consequently, rationing at a rate of six per month will continue in the 412 NPA until February 17, 2002. Further, if any NXX codes are assigned from the 878 overlay to rate centers in the 412 NPA, those will also be rationed at the rate of six per month.

   The Commission sought comments regarding the necessity of continuing this rationing plan until February 2002 once the interim pooling trial is implemented in the Pittsburgh area. More specifically, the Commission inquired whether there is a benefit to having both a pooling trial and a rationing plan in the same NPAs. Further we were seeking comment on how to ration NXX codes among non-pooling carriers and the pooling administrator if both pooling and rationing were implemented.

   Comments were filed by Verizon, Sprint and AT&T Wireless regarding this issue. All three commentators concur that the rationing in the 412 NPA should be discontinued. Verizon states that the underlying reasons for rationing NXX codes are eliminated once pooling is implemented because unused numbers will need to be donated to the pool and shared by the pooling participants. Further, Verizon states that any continuation of rationing should be extended only to those carriers not participating in the pooling trial. Sprint argues that rationing of NXX codes is incompatible with FCC directives because it precludes carriers needing numbers from obtaining them. AT&T Wireless also argues the rationing should be ended with commencement of the pooling trial because the Commission's initial goals for extending the rationing plan will be moot upon implementation of the pooling trial.

   While we recognize the difficulty of rationing for carriers, we do not believe that ending rationing upon the commencement of pooling in the 412 NPA would serve our goal of preserving the life of both the 412 NPA and the 878 NPA. In response to Verizon's argument that rationing loses its rationale upon implementation of pooling, we do not agree because not all carriers participate in pooling. Therefore, while pooling may force a certain number of carriers to share numbering resources, it does not force all carriers needing numbering to do so. Consequently, implementation of the pooling trial alone does not guarantee that numbers in the 412 NPA will not be prematurely assigned to carriers. Regarding Sprint's argument that rationing violates FCC directives, we note that the continuation of the current industry consensus rationing plan until February 2002 was done through the express delegation of authority we received in the FCC's Delegation Order.²¹

   Having determined that rationing should continue in the 412 NPA even upon implementation of the 1K pooling trial, we now consider AT&T Wireless' proposal regarding how to modify the rationing in consideration of pooling. AT&T Wireless submits that we should adopt an ''equal chance'' procedure which would allow all carriers to receive needed numbering resources in jeopardy situations. Under this procedure, carriers not participating in the pooling trial would participate in the rationing according to the already established rules. Carriers participating in the pooling trial would similarly participate in the rationing under the established rules once the pooling administrator certifies that these carriers' need for numbering resources cannot be met through the pool. Finally, the pooling administrator would participate in the lottery when there is less than 6 months inventory in a rate center until the NPA is 6 months from exhaust.

   We find merit in AT&T Wireless' approach to this situation in the sense that it attempts to ensure all carriers having a need for numbering resources be afforded the opportunity to receive them even in a rationing situation. However, we do have some concerns with this proposal such as the requirement that pooling carriers certify a need for numbers whereas non-pooling carriers do not need to do so. Further, there is no oversight regarding the pooling carriers' actual need for numbers. As we understand the proposal, the pooling administrator certifies that the carriers' need cannot be met by the numbering resources of the pool. However, the pooling administrator does not and should not be in the position of certifying that the need for the numbers exists.

   Because of these concerns, we have decided to establish different guidelines. To that end, we are going to direct the NANPA to set aside 15 NXX codes in the 412 NPA for the use of the pooling administrator. These 15 NXX codes will be outside the rationing process. This will enable the pooling administrator to replenish the pool on an as-needed basis. However, because the projected need of the pooling carriers is determined by the forecasted demand of the pooling carriers we have concerns about pooling carriers inflating their forecasted need for numbers. Therefore, we will direct that the pooling administrator certify to the Commission that the pooling carriers' need for numbering resources cannot be met through the pool. Upon receipt of the certification, we will reserve the right to request proof directly from the carriers forecasting the need for numbers that such need is necessary. Unless we notify NANPA to the contrary within 20 business days, these NXX codes can be released to the pooling administrator.

V.  Requirements of Carriers

   Pursuant to Federal rules effective July 17, 2000, all service providers are required to assign all available telephone numbers within an opened thousands-block before assigning telephone numbers from an uncontaminated thousands-block. 47 CFR 52.15(j)(1). This requirement applies to a service provider's existing numbering resources as well as to any new numbering resources it obtains in the future. Additionally, the new Federally-mandated utilization rate went into effect on May 8, 2001; per 47 CFR 52.15(h), carriers requesting growth codes in a particular rate center will need to show that they have achieved a 60% utilization threshold in the codes they already have in that rate center.

   In our May 24, 2001, order, we established various pre-implementation guidelines for LNP-capable code holders in the Pittsburgh area in advance of the October 29, 2001, implementation date for our second interim 1K pooling trial. Consequently, all LNP-capable carriers in the Pittsburgh area were required to implement the following on June 25, 2001:

   1.  All code holders administer their codes in blocks of thousand numbers on a rate center basis.

   2.  All code holders set aside (i.e. restrict from assignment in their telephone administration systems) all unopened thousand blocks currently assigned to them, unless no other numbers are available.

   3.  All code holders refrain from assigning numbers from any thousands block in an NXX with 100 or fewer numbers currently in use unless no other numbers are available.

Conclusion

   Because the Commission is concerned about the current availability and usage of numbering resources and the impact of proliferating new area codes on consumers as well as telecommunications carriers, the Commission intends to implement its second interim 1K pooling trial on October 29, 2001, in the Pittsburgh area. By taking this step to conserve and more efficiently use valuable numbering resources, the Commission will better ensure that telecommunications carriers have adequate numbering resources to operate in Pennsylvania; Therefore,

   It Is Ordered That:

   1.  Pennsylvania's second interim pooling trial will be implemented in the 412, 724 and 878 area codes on October 29, 2001, by NeuStar, Inc.

   2.  A First Implementation Meeting will be convened on August 6, 2001, at 11 a.m. via conference call. The call-in number is: [phone] and all LNP-capable carriers with NXX codes in the 412 and 724 area codes are hereby directed to participate.

   3.  The current rationing plan in effect in the 412 NPA to ration all NXX codes at the rate of six per month is to continue until February 17, 2002, and all non-pooling carriers are subject to this rationing per previously established guidelines.

   4.  The NANPA shall set aside 15 NXX codes in the 412 area code which are to be used by the Pooling Administrator to replenish the pooling area and these 15 NXX codes are not subject to the rationing procedures.

   5.  When the pooling administrator determines new NXX codes from the 412 NPA are needed to fulfill the forecasted demands of the pooling carriers, the pooling administrator shall certify this need to the Commission.

   6.  Upon certification by the pooling administrator that it needs NXX codes in the 412 area code, the Commission reserves the right to request proof directly from the carriers forecasting the need for numbers that such need is necessary.

   7.  Unless the NANPA is notified to the contrary by the Commission within 15 business days of the certification by the pooling administrator that NXX codes are needed, the requested NXX codes can be released to the pooling administrator.

   8.  A copy of this order be served to all code holders in Pennsylvania, the Office of Consumer Advocate, the Office of Small Business Advocate, Sandra Boclair and Wayne Milby of the North American Number Plan Administrator, NeuStar, and Linda Hymans and Amy Putnam of NeuStar Pooling Administration.

   9.  A copy of this order shall be published both in the Pennsylvania Bulletin and on the Commission's web site at http://puc.paonline.com/.

JAMES J. MCNULTY,   
Secretary

[Pa.B. Doc. No. 01-1442. Filed for public inspection August 3, 2001, 9:00 a.m.]

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¹  See, The Communications Act of 1934, as amended by the Telecommunications Act of 1996, 47 U.S.C. § 251(e)(1), and Chapter 30 of the Pennsylvania Public Utility Code, 66 Pa.C.S. §§ 3001--3009.

²  NXX codes are the three digits following the area code in a 10-digit telephone number. Under the current infrastructure, telephone numbers are assigned to carriers by NXX code (each NXX code contains 10,000 numbers). Once those 10,000 numbers are given to the carrier, they are unavailable for assignment to any other carriers. Therefore, a carrier having a need for only 10 numbers because it has only 10 customers, still receives a full NXX code (10,000 numbers). Of those 10,000 numbers, 10 are assigned to end users, and the remaining 9,990 numbers become unused and unavailable for assignment to any other carrier that may be able to use them. Consequently, the amount of NXX codes in an area code can exhaust very quickly. As a result of this, new area codes need to be opened so that new NXX codes become available for use by carriers to assign numbers to end users.

³  To be able to participate in 1K pooling a carrier must be LNP-capable. See Report and Order and Further Notice of Proposed Rulemaking in the Matter of Numbering Resource Optimization, CC Docket No. 99-200, 15 FCC Rcd 7574, ¶ 116 (2000). Although the telephone network is designed to route traffic based on the assignment of an NXX code (10,000 numbers) to one specific carrier, the introduction of LNP has begun to make the network more flexible. Because LNP enables the switch-specific restriction of telephone number assignments to be removed, any telephone number can be assigned to any switch offering service in the telephone number's rate center. Consequently, all LNP-capable providers who service a particular rate area can share all telephone number resources. By making the entire spare number inventory available to many providers, telephone number utilization can be improved and expand the life of an NPA. Service providers who cannot participate in the pool would continue to receive NXX codes from the code administrator in 10,000 blocks.

⁴  The NANPA is the entity responsible for allocating numbering resources to telecommunications carriers and monitoring the life span of area codes. The NANPA works under a contract with the Federal Communications Commission.

⁵  In the Matter of Numbering Resource Optimization, CC Docket Nos. 99-200, 96-98, NSD File No. L-99-101. (FCC's Delegation Order). Beyond 1K pooling, this order also grants the Commission authority to do the following: 1) maintain rationing procedures for 6 months following implementation of NPA relief, 2) implement NXX code sharing (after investigating it, reporting results to FCC, and determining that it is feasible and economically viable), and 3) hear and address claims for an extraordinary need for numbering resources in an NPA subject to a rationing plan.

⁶  MSAs are geographic areas designated by the Bureau of Census for purposes of collecting and analyzing data. The boundaries of MSAs are defined using statistics that are widely recognized as indications of metropolitan character. See Policy and Rules Concerning Rates for Dominant Carriers, Memorandum Opinion and Order, 12 FCC Rcd 8115, 8122 (1997). See also http://www.census.gov/

⁷  Implementation of Number Conservation Measures Granted to Pennsylvania by the Federal Communications Commission in its Order released July 20, 2000-- Thousands-Block Number Pooling, Opinion and Order Regarding the Petition of Verizon Pennsylvania Inc. For Expedited Reconsideration, Docket Numbers M-00001427 and P-00961061F0002 (Order entered February 9, 2001).

⁸  See Implementation of Number Conservation Measures Granted to Pennsylvania by the Federal Communications Commission in its Order released March 31, 2000--NXX Code Reclamation, Docket No. M-00001373 (Order entered August 22, 2000), 30 Pa.B. 4701 (September 2, 2000) (Commission established process for reclaiming NXX codes from carriers who have failed to activate them within 6 months of their availability for assignment to customers.); Implementation of Number Conservation Measures Granted to Pennsylvania by the Federal Communications Commission in its Order released July 20, 2000--NXX Code Rationing, Docket Nos. M-00001427 and P-00961027F0002 (Order entered December 27, 2000) (Commission ordered that NXX code rationing would continue in the 412 and 878 area codes at a rate of six per month until February 17, 2002); Rate Center Consolidation, Docket No. M-00011452 (Order entered February 9, 2001) (Commission creates subcommittee charged with the responsibility of creating a plan for implementing rate center consolidation in Pennsylvania and submitting that plan to the Commission by August 1, 2001); and, Implementation of Number Conservation Measures Granted to Pennsylvania by the Federal Communications Commission in its Order Released July 20, 2000--NXX Code Sharing, Docket Number M-00001427F0002 (Order entered February 26, 2001), 31 Pa. B. 1428 (March 10, 2001) (Commission sought comments regarding NXX code sharing).

⁹  Implementation of Number Conservation Measures Granted to Pennsylvania by the Federal Communications Commission in its Order released July 20, 2000-- Thousands-Block Number Pooling, Docket No. M-00001427 and P-00961061F0002 (Order entered December 27, 2000) at 21.

¹⁰  FCC's Numbering Order supra note 3 at ¶¶ 143-155.

¹¹  Id. at ¶ 128.

¹²  Id. at ¶ 156.

¹³  Mike Balmoris, ''Federal Communications Common Carrier Bureau Selects NeuStar, Inc. as National Thousands-Block Number Pooling Administrator,'' FCC News Release, June 18, 2001 available at http://www.fcc.gov/Bureaus/Common_Carrier/News_Releases/2001/.

¹⁴  The NPAC was developed to support the implementation of LNP and it provides supporting turn-key operational services, coordinates the porting of telephone numbers between carriers, and downloads routing information to update local routing databases. The NPAC is divided into seven regions across the United States: Midwest, Mid-Atlantic, Northeast, Southeast, Southwest, Western, and West Coast. Pennsylvania along with Maryland, Virginia, and New Jersey, comprise the Mid-Atlantic NPAC region. More information about the NPACs can be found at http://www.npac.com/.

¹⁵  Our May 24, 2001 order mandated pooling in the 412, 724 and 878 NPAs; we did not seek comments on this issue. Therefore, in accordance with our regulations, a petition for reconsideration of this issue should have been filed within 15 days after the May 24, 2001 order was entered. 52 Pa. Code § 5.572. We did not receive any petitions for reconsideration of our May 24, 2001 order.

¹⁶  Regarding pooling in the 878 NPA, the 878 NPA is being implemented as an overlay over the 412 and 724 NPAs and no codes will be assigned from it until the NXX codes from either the 412 or the 724 NPA are depleted. See NANPA Planning Letter PL-281 available at www.nanpa.com. In the 412 NPA, there are approximately 92 NXX codes left. Since these are being rationed at a rate of six per month, they will not be exhausted prior to October 2001 and the opening of the pooling trial. In the 724 NPA, there are approximately 79 NXX codes left and we do not expect exhaust of all these NXX codes to occur prior to implementation of the October pooling trial. Consequently, no blocks should be allocated to carriers from the 878 NPA prior to pooling. Therefore, the carriers do not need to do any block assessments for the 878 NPA.

¹⁷  FCC's Numbering Order supra note 3.

¹⁸  FCC's Delegation Order supra note 5.

¹⁹  FCC's Numbering Order supra note 3 at ¶ 159.

²⁰  FCC's Delegation Order supra note 5 at ¶ 63.

²¹  FCC's Delegation Order supra note 5 at ¶ 63.