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One of the iconic symbols of New Hampshire, our 603 area code, is safe for now but a tweak to the telecommunications system would make it even safer, not to mention helping keep the whole country from having to dial 11 or even 12 digits to make a call.

That’s the basic argument of a petition before the Federal Communications Commission asking that New Hampshire be a test bed for a more efficient way of doling out phone numbers. Maine, another of the eight states covered by a single area code, may join the request.

“The current system is incredibly wasteful,” said Amanda Noonan, director of External Affairs for the state Public Utilities Commission.

This discussion comes even as the whole idea of area codes becomes less and less relevant, because cell phones and voice-over-Internet have frayed the historic and technical link between phone numbers and geographic location.

“I’m talking to you now from Ohio on a New Hampshire number,” pointed out Noonan. “To the younger generation the idea of an area code meaning something or an exchange meaning something – it’s arcane.”

But area codes continue to have a hold on culture. Phone numbers in New York City carrying the original 212 area code are in high demand, for example, and when news came out in the 1990s that New Hampshire might have to add a second area code, there were howls of opposition from all sides because nobody wanted to lose their 603.

Since then the state’s area code has become even more popular: Dozens of companies have 603 as part of their trademark name, and in 1999 the Legislature passed a law (RSA 374:59) telling the PUC to do everything it could to “adopt telephone number conservation measures to the maximum extent allowed by federal law for area code 603.”

That phrase “extent allowed by federal law” is significant because the FCC has taken over virtually all aspects of phone number distribution, Noonan said. The PUC can register concern when, for example, New Hampshire numbers are issued to companies with no connection to the state, but that’s about it.

Those systems operate within the North American Numbering Plan or NANP, which started in 1947 to standardize phone systems and allow inter-connection while keeping phone numbers unique. The system now covers Canada and parts of the Caribbean, but not Mexico.

NANP rules determine how carriers dole out potential phone numbers in geographic areas covered by phone exchanges, which are the first three digits of a seven-digit phone number, designed “NXX” in telecommunications parlance.

The original switched-network design of the telephone system meant that each exchange carried 10,000 potential phone numbers, corresponding to the final four digits of the phone number, from 0000 to 9999. If there aren’t enough customers in the service area of the exchange to need all those numbers, many will sit unused.

In theory the 603 area code can include 7.7 million different seven-digit phone numbers, after discounting numbers that aren’t allowed, such as exchanges starting with a zero. Since only about 3.4 million of the numbers are in use, there should be plenty to spare but many of those are forced to sit idle.

The FCC petition, written by David Wiesner, director of the PUC’s legal division, cites an egregious example involving the town of Derry: “Derry has 28 NXX codes assigned to it, representing a theoretical pool of 280,000 numbers – enough numbers to provide every resident with seven or more unique, geographically relevant phone numbers.”

Most of those numbers are unlikely to be allocated to anybody.

The petition says of 50 service providers in the state with assigned numbers, “only nine providers utilize more than half of their number assignments.”

This system is so wasteful that area codes began running out of exchanges soon after NANP was created, forcing more to be created. The original NANP had 157 area codes; more than 335 now exist. Eventually it’s possible that NANP might have to add another digit to all phone numbers to avoid running out, requiring 11- or 12-digital dialing in some parts of the country.

To extend the life of area codes the FCC adopted number pooling in the early 2000s, allowing numbers to be distributed in batches of 1,000 instead of 10,000, a change made possible by digital technology. Combined with a a few other tweaks this means the 603 area code is safe through at least the year 2030.

But in the PUC’s petition, which was filed a year ago but hasn’t been acted on, New Hampshire wants the FCC to go further, doling out numbers in smaller lots, maybe even one at a time. It argues that New Hampshire is a perfect “test bed” for individual telephone number or ITN assignment “using existing software and methods.”

That last point is important, Noonan said, because some telephone carriers have balked at this plan, saying it would cost too much.

“My professional opinion is that software changes and maintenance would be very minimal on top of what they’re doing for pooling already,” Noonan said. A test run could prove it.

“Now we have a lot experience in pooling. It’s pretty seamless, porting numbers and letting computers keep track of it,” she said. “There’s no reason not to adopt pooling in smaller increments.”

The petition can be seen online.

https://ecfsapi.fcc.gov/file/10426251258868/20190426-NHPUC-ITN-Petition-to-FCC.pdf

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