******************************************************** NOTICE ******************************************************** This document was converted from WordPerfect to ASCII Text format. Content from the original version of the document such as headers, footers, footnotes, endnotes, graphics, and page numbers will not show up in this text version. All text attributes such as bold, italic, underlining, etc. from the original document will not show up in this text version. Features of the original document layout such as columns, tables, line and letter spacing, pagination, and margins will not be preserved in the text version. If you need the complete document, download the WordPerfect version or Adobe Acrobat version, if available. ***************************************************************** DA 99-505 NSD File No. 99-25 March 12, 1999 Mr. Ronald R. Conners Director, North American Numbering Plan Administrator 1133 15th St., NW 12th Floor Washington, DC 20005 Re: Sprint PCS Request for Emergency Numbering Relief in the 516 NPA Dear Mr. Conners: This letter addresses Sprint PCS's March 3, 1999, request that the Federal Communications Commission direct the North American Numbering Plan Administrator (NANPA) to release immediately two central office codes that have already been earmarked for Sprint PCS under the rationing procedures in place in the 516 Numbering Plan Area (NPA), which covers Long Island, New York. As is further explained below, we concur with the conclusion of the New York State Department of Public Service that Sprint PCS has adequately demonstrated its genuine and immediate need to obtain numbering resources in advance of the assignment schedule provided for in the 516 NPA rationing plan. Pursuant to the FCC's plenary authority over numbering administration, we direct the NANPA to release the referenced central office codes immediately. According to information submitted to the Common Carrier Bureau, Sprint PCS has certain central office codes in the Nassau County rate center and the Suffolk County rate center within the 516 NPA. Under the 516 NPA rationing plan, Sprint PCS has been allocated two additional central office codes in the 516 NPA, but according to the terms of the plan, these codes are not scheduled to be released to Sprint PCS until June 1999 and March 2000. Sprint PCS has demonstrated that it has almost no available telephone numbers in the Suffolk County rate center. Sprint PCS indicates that it has entered into a reverse billing arrangement with Bell Atlantic in order to use numbers from the Nassau County rate center to provide service to Suffolk County customers. Use of this arrangement means that Sprint PCS's numbering resources in the Nassau County rate center will exhaust more quickly. Sprint PCS projects that without extraordinary relief, it will be completely out of telephone numbers in the 516 NPA within the 66 day period ordinarily required to activate a central office code once it has been assigned to a carrier. In addition, although it usually ages numbers for 90 days in order to avoid customer confusion, wrong numbers, and incorrect billing of roaming charges, Sprint PCS indicates that it is currently aging numbers in the 516 NPA on a one-week to zero-day cycle, in order to help meet demand. Based on this information, we are satisfied that Sprint PCS has met the standard for extraordinary relief articulated by the Commission in the Pennsylvania Numbering Order. Sprint has demonstrated that it has virtually exhausted all available numbers in the Suffolk rate center, and that it will exhaust all of its numbering resources in the 516 NPA in the near future. Sprint has further demonstrated that it is already using extraordinary and costly measures, including severely curtailed aging cycles, and reverse billing arrangements, in order to provide service to customers in the 516 NPA. It is clear that if it does not obtain additional numbering resources very soon, at best, Sprint PCS will be forced to expand its use of these extraordinary measures, and, at worst, may be unable to provide service to customers in the 516 NPA. Therefore, we direct the NANPA to assign and release immediately to Sprint PCS the two codes that have been earmarked for Sprint in the 516 NPA rationing plan. We take this action today only in view of the urgency of Sprint PCS's need for relief, and we do not do so lightly. Where area code relief is being implemented in a timely fashion, it should not be necessary for the FCC to mandate this type of extraordinary relief. To the extent that extreme exhaust situations of this type are unavoidable, however, we believe that the industry, working with the central office code administrator, is capable both of anticipating, and of adopting measures to address, requests for extraordinary relief. We further believe that the industry should consider how to address emergency situations -- possibly by reserving a certain portion of remaining central office codes for needs-based emergency relief -- when formulating a central office code rationing scheme for a particular NPA. In such light, we direct the NANPA, in its capacity as the central office code administrator, to convene a 516 industry meeting to reconsider the rationing plan adopted in the 516 NPA, and we specifically instruct the industry to consider the issue of how to address emergency requests for relief, like Sprint PCS's, that may arise in the future. We request your response to this within 45 days. Sincerely, Yog R. Varma Deputy Chief, Common Carrier Bureau cc: Jonathan Chambers, Sprint PCS Penny Rubin, New York Public Service Commission Janet Hand Deixler, New York Public Service Commission Cheryl Callahan, New York Public Service Commission Alan Hasselwander, Chairman, North American Numbering Council