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03 January 2011

To the Pennsylvania PUC

In December 2010, it was announced that the 814 area code, or NPA, would be split into two, with the Erie area receiving a new designation of 582 effective 1 February 2012. Not surprisingly, many Erieites haven't taken too kindly to this proposal, and an online petition at has since garnered over 11,000 signatures. As the deadline to file the petition with the Pennsylvania Public Utility Commission (PUC) is Monday 3 January, I thought I'd add my two cents. Seeing that I actually have some semblance of a cohesive opinion on this matter which is too long for any comment field, my "comments" are below:

Firstly, the public comment process on these proposed changes was a farce. Neither sufficient effort nor adequate foresight was put into determining how and where these meetings would take place. As a result, four of the five hearings were held in the area which is to retain the 814 Numbering Plan Area (NPA) designation. The only hearing in the proposed 582 NPA (in Erie) was delayed due to weather by two months, and it wasn't anywhere nearly as publicized as any of the others.

Are we really supposed to believe that all of this adds up to "fewer people from [the Erie] area protest[ing] a possible change"? Where were the hearings in other Northwestern Pennsylvania cities, like Meadville and Warren? Most of the people signing this petition were never given a legitimate chance to voice their opinions.

Secondly, an NPA split effectively discriminates against those receiving the new designation, to the tune of millions of dollars spent reprinting letterhead, promotional materials, and internal directories. Moreover, every company in the nation which retains customer phone numbers will have to comb through their databases and manually determine which records should be changed and which should not—or, more likely, they'll just shift the onus to the customers themselves: an even more cumbersome proposition. Introducing an overlay designation avoids every one of these pitfalls and eliminates these unnecessary costs, both monetary and human. The only "expense" is introducing ten-digit dialing.

In an already-digital world where ten-digit dialing is already the norm on cell phones and Voice over Internet Protocol (VoIP) services (not to mention most of the rest of the country), why should we even think to undergo an NPA split, a system whose only tangible benefit is the retention of now-antiquated seven-digit dialing, instead of an overlay, a system which has been implemented countless times around the country with nary a problem?

It couldn't be clearer that the Pennsylvania Public Utility Commission (PUC) in no way exercised due diligence in soliciting comments from a broad-based sample of the populace of the existing 814 NPA, and that they completely failed at the simple task of considering all of their options. This entire process has been flawed from the start, and I implore the Pennsylvania PUC to seriously rethink its decision in light of this petition.


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