June 23, 2022

Electronically Filed

Mr. Andrew S. Johnston

Executive Secretary
Maryland Public Service Commission
William Donald Schaefer Tower
6 St. Paul St. 16th Floor
Baltimore, Maryland 21202

Case No. 8853: Notification by the North American Numbering Plan

Administrator (NANPA) of Need for Relief Plan Implementation for the
240/301 Numbering Plan Area (NPA) Code

Dear Mr. Johnston:

The North American Numbering Plan Administrator (“NANPA”) hereby submits for
filing a letter on behalf of the Maryland telecommunications industry to request
approval to begin implementation of an all-services distributed overlay as the relief
method for the “240/301” Numbering Plan Area (“NPA”) (aka “area code”).

If you have any questions regarding this filing, please contact me at 571-363-3824.

Respectfully submitted,

_______________________________
Heidi Wayman
Manager, Data Management
North American Numbering Plan
Administrator
Two Tower Center Blvd
Floor #20
East Brunswick, NJ 08816
571-363-3824
hwayman@nanpa.com
June 23, 2022

Mr. Andrew S. Johnston

Executive Secretary
Maryland Public Service Commission
William Donald Schaefer Tower
6 St. Paul St. 16th Floor
Baltimore, MD 21202

RE: Case No. 8853: Notification by the North American Numbering Plan
Administrator (NANPA) of Need for Relief Plan Implementation for the 240/301
Numbering Plan Area (NPA) Code

Dear Mr. Johnston:

The North American Numbering Plan Administrator (“NANPA”), as the neutral

third-party Numbering Plan Area (NPA, also referred to as “area code”) relief planner

for Maryland and on behalf of the Maryland telecommunications industry (“Industry”),1

hereby notifies the Maryland Public Service Commission (“Commission”)2 that the need

for relief in the 240/301 NPA is imminent. The Commission issued the Proposed Order

on November 30, 2000 (“November 2000 Order”), approving an all-services distributed

overlay (“overlay”) as the means of relief for the 240/301 NPA, and assigned a Final

Order No. 76681 on January 3, 2001.3 The overlay was to be implemented pursuant to

1
The Industry is composed of current and prospective telecommunications carriers operating in, or
considering operations within, the 240/301 area code.
2 The Federal Communications Commission (“FCC”) delegated authority to the states to review and

approve NPA relief plans. See 47 C.F.R. §52.19.

3 In the matter of the petition of Neustar Inc., North American Numbering Plan Administrator, for

approval of relief plans for the 443 and 240 area codes, Case No. 8853, (Nov. 30, 2000) (“November
2000 Order”).
Letter to Mr. Johnston
Page 2 of 8

the stipulation agreed to by the Industry at that time and outlined in paragraphs 1-2 of

the November 2000 Order.

1. The Commission should immediately approve an overlay

of the 443/410 and 240/301 NPAs. The Commission
should direct NANPA to assign the new area codes as soon
as the order is issued so that network preparation for the
implementation of the new area codes can begin.

2. The Commission should direct NANPA to update the

industry and this Commission monthly on the projected
exhaust dates beginning when each of the NPAs is within
ten months of exhaust. Time to exhaust in months shall
be calculated based upon actual carrier demand for
numbers to ensure that all carriers, including non-pooling
capable carriers, will have access to numbers when
needed to meet customer demand. Customer notification
will not begin until NANPA notifies the industry and the
Commission that the existing area codes will exhaust
within three months. The Commission reserves its right
to take appropriate steps to the extent that it is not
convinced that exhaust will occur within three months.

Consistent with the Commission’s Order and to update the record, NANPA

hereby notifies you that the 240/301 area code is currently projected to exhaust, absent

relief, during the fourth quarter of 2023. After receipt of Commission approval, the

Industry will take steps to implement the all-services distributed overlay approved in

the November 2000 Order for the 240/301 NPA with the customer education and

technical implementation plan and schedule herein described.

Background:

The 301 NPA was created in 1947 and served the entire state of Maryland for 44

years. In 1991, the 301 NPA was split to create the 410 NPA. As a result of the split, the

eastern portion of the state bordering the District of Columbia (DC) metropolitan area,

as well as the cities of Hagerstown and Frederick, retained the 301 NPA. The 410

covered the Baltimore and Annapolis areas. Nearing exhaust again, overlays were

2
Letter to Mr. Johnston
Page 3 of 8

implemented for both NPAs in June 1997, creating the 240/301 and the 410/443

overlay areas. In 2000, the 240/301 and 410/443 NPAs were again projected to exhaust

and NANPA filed a petition for relief which resulted in the approval of the additional

overlay NPAs in the November 2000 Order.

Coincident with the release of the November 2000 Order, Maryland began a

number conservation measure, thousands-block number pooling, in both of these NPAs.

As a result, implementation of the new area codes assigned for relief of these areas, 667

for the 410/443 and 227 for the 240/301, was postponed. The exhaust of the 410/447

NPA was delayed for more than a decade, with the new 667 NPA being implemented in

2012. The 240/301 NPA exhaust was deferred more than 20 years and is now in need of

relief. The 227 NPA is still reserved for the relief of the 240/301 NPA.

As required by the FCC, NANPA collects CO code assignment, utilization, and

forecasted demand data to determine the projected demand for numbering resources.

NANPA uses this data to project the exhaust date of each area code and publishes the

results twice each year. In April 2022, NANPA published its semi-annual Numbering

Resource Utilization/Forecast (NRUF) and NPA Exhaust Analysis (“April 2022 NRUF

Report”) which indicated that the 240/301 NPA will exhaust during the fourth quarter

of 2023.4

Description of the Overlay Implementation Plan: The all-services

distributed overlay would superimpose a new NPA over the same geographic area

covered by the existing 240/301 NPA. NANPA will assign Central Office (“CO”) codes

4 April 2022 NRUF and NPA Exhaust Analysis (“April 2022 NRUF Report”) can be accessed on the

NANPA web site at https://nationalnanpa.com/reports/reports_npa.html.

3
Letter to Mr. Johnston
Page 4 of 8

from the new overlay area code only after all assignable CO codes from both the 240 and

301 NPAs are exhausted. All existing customers would retain their current area code in

the 240 or 301 NPAs and would not have to change their telephone numbers. The

current dialing plan will remain unchanged. The dialing plan is set forth in the

following table:

Dialing Plan for the 240/301 All-Services Distributed Overlay

Type of Call Call Terminating in Dialing Plan

Local Call Home NPA (HNPA) or 10 digits (NPA-NXX-XXXX)*
Foreign NPA (FNPA)

Toll Call HNPA or FNPA 1+10 digits (1+NPA-NXX-XXXX)

Operator Services HNPA or FNPA 0+10 digits (0+NPA-NXX-XXXX)
Credit card, collect,
third party
*1+10 permissive dialing at service provider discretion

While the November 2000 Order contains implementation instructions to the

Industry, many factors have changed in the 22 years since this Order was approved.

Since 10-digit local dialing is already in place in the 240/301 NPA, the only remaining

elements for consideration are the customer education for and implementation of the

new NPA.

The new 227 NPA that was assigned after the November 2000 Order is still

reserved. In preparation for submitting this letter to you, NANPA conferred with

Commission staff and facilitated a meeting of the Industry on June 1, 2022, during

which the Industry, by consensus decision, agreed to implement relief for the 240/301

area code in accordance with a nine-month schedule which is the current common

timeframe. The schedule does not include specific dates but rather timeframes to

identify the phases of implementation. Adhering to this Industry agreed-upon schedule

will allow the new NPA to be implemented at least six months prior to the projected

4
Letter to Mr. Johnston
Page 5 of 8

exhaust of the 240/301 NPA.5 The Industry will select specific dates at a subsequent

implementation meeting to ensure they do not interfere with certain holidays, high

traffic calling days, network freeze periods, or other NPA relief implementation activities

occurring across the country. NANPA will notify the Industry about this meeting once

this plan is approved by the Commission.

The following are activities and timeframes considered by the Industry for an

Implementation Schedule for the 240/301 NPA All-Services Distributed Overlay:

Implementation Schedule for the 240/301

All-Services Distributed Overlay
TIMEFRAME FOR
EVENT
240/301 OVERLAY
Customer Education
and Network Nine months
Preparation Period
At completion of Customer
Education and Network
Earliest Activation Preparation Period and after all
of CO codes in the 240/301 CO codes are
new NPA ** exhausted
(six months prior to
exhaust)

** CO codes in the new 227 NPA will not be assigned until all available codes in the 240/301 NPA
have been exhausted.

The November 2000 Order states that “customer notification will not begin until

NANPA notifies the Industry and the Commission that the existing area codes will

exhaust within three months.”6 At the time of the November 2000 Order, Maryland

had implemented the two new overlay area codes just three years prior. Consumers

were more familiar with the addition of new NPAs than they would be today because

5 The NPA Code Relief Planning and Notification Guidelines (ATIS-0300061, April 1, 2022) (“NPA Relief

Planning Guidelines”) require that relief be implemented six months prior to exhaust.

6 November 2002 Order, paragraph 2

5
Letter to Mr. Johnston
Page 6 of 8

there has not been relief in the 240/301 NPA since 1997. Adherence to the following

customer education and network preparation timeframes that meet with today’s

standards will enable the Industry to begin customer education for the new 227 NPA

nine-months prior to the introduction of the area code and allow for adequate time to

prepare networks in advance.

The following tables outline the methods and processes the Industry typically

utilizes in current relief projects for implementation of a new overlay NPA. These

milestones consider that mandatory 10-digit local dialing is already in place but could

be modified by the Industry during the actual implementation:

Customer Education Milestones:

Milestone Description Responsibility

1 Issue single customer notification All Service Providers
(e.g., bill messages, bill inserts, direct mail,
text messaging, email)
2 Issue initial press release announcing Commission;
overlay and new 227 overlay NPA Service Providers to the
extent they are able to do so
3 Send Special letter to Directory Publishers Co-chairs of industry
committee
4 Update social media with information All Service Providers
regarding the overlay (optional)
5 Update websites with information All Service Providers
regarding the overlay
6 Develop language for use in Directories to Service Providers that
alert the consumers of the new 227 area publish directories
code.
7 Issue second press release just prior to the Commission;
new overlay NPA’s effective date Service Providers to the
extent they are able to do so

6
Letter to Mr. Johnston
Page 7 of 8

Technical Milestones:

Milestone Description Responsibility

1 Obtain industry test code from NANPA and One Service Provider
activate the test number. volunteer
2 Open the test code in carriers’ network. All Service Providers
3 Establish NPA Specific type of Trunks All Service Providers (as
needed)
E911 Work Plan
4 Confirm new ESN/NPD has been
E911 Providers
established for the new NPA
5 Ensure SRDB table has new NPA built E911 Providers
6 Notify PSAPs, PSALI customers and County
E911 Providers
Coordinators (1st and 2nd Notification)
7 Review and Submit CLEC Trunk Order All Service Providers
Requests to local provider if needed (as needed)
8 Update PSAP equipment PSAPs
9 Trunk Orders Complete E911 Providers
10 Build E911 Network/Tandem Translations E911 Providers
11 Verify if all PSAP work has been completed PSAPs
12 Activate E911 Network/Tandem
E911 Providers
Translations

Conclusion: The Industry will take steps to implement the 227 NPA all-

services distributed overlay as relief for the 240/301 NPA as previously approved by

the Commission in the November 2000 Order and in line with the customer education

and technical implementation plan and the timeframes outlined above. The Industry

requests approval of the customer education and implementation plans as outlined

herein by August 31, 2022, in order to allow sufficient time for implementation.

7
Letter to Mr. Johnston
Page 8 of 8

Thank you for your attention to this matter. If you should have any questions,

please do not hesitate to contact me directly at 571-363-3824 / hwayman@nanpa.com.

Respectfully submitted,

Heidi Wayman,
Manager, Data Management,
Two Tower Center Boulevard
Floor #20
East Brunswick, NJ 08816

Attachment

cc:
Kenneth Albert
Benjamin Baker
Zachary Peterman

8
ATTACHMENT
June 20, 2022

To: All 240/301 NPA Code Holders and Interested Industry Members (Maryland)

Subject: Final Minutes of the Relief Planning Meeting for the 240/301 NPA
__________________________________________________________________________

Attached are the final minutes from the June 1, 2022 relief planning meeting to reach consensus
on a letter to be filed with the Maryland Public Service Commission for the 240/301 NPA.
These minutes became final on June 20, 2022.

If you have any questions, please give me a call at (571) 363-3824 or via email at
hwayman@nanpa.com.

Sincerely,

Heidi A. Wayman
Manager, Data Management
NANPA

CC: Kenneth Albert – Maryland Public Service Commission Staff

Benjamin Baker– Maryland Public Service Commission Staff
Zachary Peterman– Maryland Public Service Commission Staff
 Maryland 240/301 NPA
Relief Planning Meeting via Web Conference
Final Minutes
June 1, 2022

WELCOME, INTRODUCTIONS & AGENDA REVIEW

Heidi Wayman, Manager, Data Management–NANPA, welcomed the participants,
reviewed the agenda and the objective of the meeting. A list of attendees can be found in
Attachment #1.

REVIEW CONSENSUS PROCESS AND NPA RELIEF PLANNING GUIDELINES

Heidi stated that the ATIS (Alliance for Telecommunications Industry Solutions) approved
industry consensus process would be followed. She reviewed the consensus process and
explained how consensus is determined. In addition, she stated that the minutes would be
comprised of consensus agreements, and that issues not captured by consensus could be
expressed in the form of a Statement for the Record, which could be conveyed at any point
during the meeting.

MEETING OBJECTIVE
On November 30, 2000, the Public Service Commission of Maryland (“Commission”)
issued a Proposed Order approving an all-services distributed overlay as the relief method
for the 240/301 NPA in Case No. 8853, Order No 76681. The Proposed Order (“Order”)
became final on January 3, 2001.

Due to changes in Industry guidelines and best practices since the Order became final back
in 2001 when implementing area code relief, NANPA convened the Telecommunications
Industry of Maryland (“Industry”) to reach consensus on a letter to be submitted to the
Commission to request approval to commence implementation of the previously approved
all-services distributed overlay for the 240/301 NPA based upon an updated
implementation schedule.

REVIEW CASE NO. 8853

Heidi reviewed pertinent sections and ordering paragraphs included in the Order to help the
Industry reach consensus on any items to be included in the regulatory filing.

1. The Commission should immediately approve an overlay of

the 443/410 and 240/301 NPAs. The Commission should
direct NANPA to assign the new area codes as soon as the
order is issued so that network preparation for the
implementation of the new area codes can begin.

2. The Commission should direct NANPA to update the

industry and this Commission monthly on the projected
exhaust dates beginning when each of the NPAs is within
ten months of exhaust. Time to exhaust in months shall

1
 be calculated based upon actual carrier demand for
numbers to ensure that all carriers, including non- pooling
capable carriers, will have access to numbers when
needed to meet customer demand. Customer notification
will not begin until NANPA notifies the industry and
the Commission that the existing area codes will exhaust
within three months. The Commission reserves its right
to take appropriate steps to the extent that it is not
convinced that exhaust will occur within three months.

IT IS, THEREFORE, this 30th day of November, in the year

Two Thousand,

ORDERED: (1) That the Partial Stipulation and Settlement Agreement

submitted by the parties on November 13, 2000 is hereby accepted.

(2) That this Proposed Order will become a final Order of the
Commission on January 3, 2001, unless before that date an appeal is
noted with the Commission by any party to this proceeding as provided
in Section 3-113(d)(2) of The Public Utility Companies Article, or the
Commission modifies or reverses the Proposed Order or initiates further
proceedings in this matter as provided in Section 3-114(c)(2) of The
Public Utility Companies Article.

NPA STATUS
Central Office (“CO”) Code Assignment History:
Heidi provided a read-out of the monthly CO code assignment activity for the Maryland
240/301 NPA. As of May 31, 2022, the 240 NPA has 749 CO codes assigned, 36 CO codes
available for assignment and 15 unavailable CO codes. The 301 NPA has 777 CO codes
assigned, four (4) CO codes available for assignment and 19 unavailable CO codes. There
have been 22 CO codes assigned through May 31, 2022, 55 CO codes assigned in 2021, 26
CO codes assigned in 2020, 20 CO codes assigned in 2019, 29 CO codes assigned in 2018,
and 17 CO codes assigned in 2017. (See Attachment #2)

Exhaust Forecast: In April 2022, NANPA published its semi-annual Numbering

Resource Utilization/Forecast (NRUF) and NPA Exhaust Analysis (“April 2022
NRUF Report”) which projected the 240/301 NPA overlay will exhaust during the fourth
quarter of 2023 (4Q2023).

Thousands-Block Information:
Thousands-Block pooling commenced on August 15, 2001. There are 63 rate centers, all
of which are mandatory for pooling. From June 1, 2021 through May 31, 2022, there have
been 806 blocks assigned and 288 blocks available for assignment. For the same period, 59
CO codes have been assigned: 52 CO codes for pool replenishment, four (4) CO codes for
dedicated customers and three (3) CO codes for LRNs. The forecasted need for CO codes
for the next twelve months is 33 CO codes for pool replenishment and dedicated customers.

2
(See Attachment #3)

REVIEW DRAFT LETTER FOR THE 240/301 NPA OVERLAY

Prior to the meeting, NANPA drafted a letter to file with the Commission. The draft letter
includes the implementation timeframes to implement the new 227 NPA over the 240/301
NPA, dialing plan and customer education and technical milestones which will be
completed during the implementation of the new 227 area code. The draft letter was
approved after significant discussion and suggested edits by the Industry and Commission
staff.

The Commission staff asked for the following sentence to be reworded.

As a result, barring other direction from the Commission, the Industry will take steps to
implement the all-services distributed overlay approved in the November 2000 Order for
the 240/301 NPA with the customer education and technical implementation plan and
schedule herein described.

Consensus was reached to modify the sentence to read as follows:

After receipt of Commission approval, the Industry will take steps to implement the all-
services distributed overlay approved in the November 2000 Order for the 240/301 NPA
with the customer education and technical implementation plan and schedule herein
described.

The following is the current dialing plan for the 240/301 NPA and will continue with the
implementation of the new 227 NPA.

Dialing Plan for the 240/301 All-Services Distributed Overlay

Type of Call Call Terminating in Dialing Plan
Local Call Home NPA (HNPA) or 10 digits (NPA-NXX-XXXX)*
Foreign NPA (FNPA)

Toll Call HNPA or FNPA 1+10 digits (1+NPA-NXX-XXXX)

Operator Services HNPA or FNPA 0+10 digits (0+NPA-NXX-XXXX)
Credit card, collect, third
party
*1+10 permissive dialing at service provider discretion

ESTABLISH IMPLEMENTATION SCHEDULE

Consensus was reached to recommend that CO codes will not be assigned in the new 227
NPA until all available codes in the 240/301 NPAs have been exhausted. A
recommendation was made, and consensus was reached to recommend to the Commission
a nine-month schedule for implementation of the 240/301/227 NPA overlay. Based on the
NPA Relief Planning and Notification Guidelines (ATIS 0300061, “Guidelines”), the new
NPA should be placed in service six months prior to exhaust. The recommended schedule
is as follows:

3
 Recommended Implementation Schedule for the All-Services Distributed Overlay

TIMEFRAME FOR
EVENT
240/301 OVERLAY

Customer Education and

Nine months
Network Preparation Period

At completion of Customer
Education and Network Preparation
Earliest Activation of CO codes
Period and after all 240/301 CO
in the new NPA **
codes are exhausted
(six months prior to exhaust)

** CO codes in the new 227 NPA will not be assigned until all available codes in the
240/301 NPA have been exhausted.

CUSTOMER EDUCATION PLAN

Consensus was reached to include in the filing with the Commission the following customer
and technical milestones for implementation of an additional overlay when mandatory 10-
digit local dialing is already in place; however, these milestones may need to be modified
during the actual implementation.

Customer Education Milestones:

Responsibility
1 Issue single customer notification All Service Providers
(e.g., bill messages, bill inserts, direct
mail, text messaging, email)
2 Issue initial press release announcing Commission;
overlay and new 227 overlay NPA Service Providers to the extent they are
able to do so
3 Send Special letter to Directory
Co-chairs of industry committee
Publishers
4 Update social media with information
All Service Providers (optional)
regarding the overlay
5 Update websites with information
All Service Providers
regarding the overlay
6 Develop language for use in
Service Providers that publish
Directories to alert the consumers of
directories
the new 227 area code.
7 Issue second press release just prior to Commission;
the new overlay NPA’s effective date Service Providers to the extent they are
able to do so

4
Technical Milestones:

Responsibility
1 Obtain industry test code from NANPA and
One Service Provider volunteer
activate the test number.
2 Open the test code in carriers’ network. All Service Providers
3 Establish NPA Specific type of Trunks All Service Providers (as needed)
E911 Work Plan
4 Confirm new ESN/NPD has been
E911 Providers
established for the new NPA
5 Ensure SRDB table has new NPA built E911 Providers
6 Notify PSAPs, PSALI customers and
County Coordinators (1st and 2nd E911 Providers
Notification)
7 Review and Submit CLEC Trunk Order
All Service Providers (as needed)
Requests to local provider if needed
8 Update PSAP equipment PSAPs
9 Trunk Orders Complete E911 Providers
10 Build E911 Network/Tandem Translations E911 Providers
11 Verify if all PSAP work has been completed PSAPs
12 Activate E911 Network/Tandem
E911 Providers
Translations

STATEMENT FOR THE RECORD/OPEN DISCUSSION

There were no statements on the record.

NANPA FILING INDUSTRY EFFORTS WITH COMMISSION

Consensus was reached that NANPA will file the letter with the Commission informing
them of the outcome of this relief planning meeting. The Guidelines reflect that the relief
filing is to be submitted to the Commission within 6 weeks (July 13, 2022) of the relief
planning meeting unless otherwise decided by the Industry. After considerable discussion,
the Industry requested a response from the Commission by August 31, 2022. To provide
the Commission sufficient time to respond to the Industry letter, NANPA agreed to file the
regulatory filing with the Commission no later than the last business day of June 2022.

OPEN DISCUSSION AND STATEMENTS FOR THE RECORD

There were no additional items for discussion and a statement for the record was not
submitted.

REVIEW OF DRAFT MEETING MINUTES

The Industry reached consensus that the draft minutes resulting from this meeting will be
distributed to the Industry no later than June 21, 2022. Any changes or corrections are to
be submitted to Heidi via email at hwayman@nanpa.com no later than one week after the

5
minutes are posted to the NANP Administration System (NAS) on the NANPA website
when the minutes will become final.

The meeting was adjourned

###

These minutes became final on June 20, 2022 without any edits.

6
 Attachment # 1
Maryland 240/301 NPA
Relief Planning Meeting via Web Conference
June 1, 2022
Participants

NAME COMPANY

Melinda Yost DISH Wireless

Rita Schmitz Lumen
Benjamin Baker Maryland Public Service Commission
Kenneth Albert Maryland Public Service Commission
Zachary Peterman Maryland Public Service Commission
Heidi Wayman NANPA
Cecilia McCabe NANPA
Linda Hymans NANPA
Shaunna Forshee T-Mobile
Laura Dalton Verizon
Chanda Brown Verizon
Dana Crandall Verizon Wireless
Scott Terry Windstream
 Attachment #2

Maryland Central Office Code Summary

NPA 240 301
Assigned NXXs 749 777
Reserved NXXs 0 0
Unavailable NXXs 15 19
Available NXXs 36 4
Total 800 800

240/301 NPA Combined Code

Assignment History 2017 2018 2019 2020 2021 2022
17 29 20 26 55 22*
*As of May 31, 2022

April 2022 NRUF and NPA

Exhaust Analysis 4Q2023

Note: Unavailable indicates codes that are unavailable for assignment. These codes include, but are not
limited to, test and special use codes(e.g., 958, 959, 555, time), N11 and other unique codes (e.g., 976, 950)
and codes with special dialing arrangements (e.g., 7-digit dialing across NPA boundary).
 Attachment #3

THOUSANDS-BLOCK STATISTICS
ST/NPA: MD 240/301
MEETING DATE: 6/1/22
POOL START DATE (PSD) 8/15/01
RATE CENTERS
# Total 63
# Mandatory 63
# Mandatory-Single Service Providers (M*) 0
# Optional 0
# Excluded 0
BLOCKS ASSIGNED
# Total 806
(For time period 6/01/21- 5/31/22)

BLOCKS AVAILABLE
#Total 288
(As of preparation date: 5/31/22)

CODES ASSIGNED
# Total 59
# for Pool Replenishment 52
# for Dedicated Customers 4
# for LRNs 3
(For time period 6/01/21 - 5/31/22)

CODES FORECASTED
# Total 33
# for Pool Replenishment and Dedicated Customers 33
# for LRNs 0
(For the next twelve months as of: 5/31/22)