For the almost 40 years that I have been in the telephone business, the
term NANP envisions area codes and central office codes associated with
telephone numbers. In reality, the term NANP did not appear until 18
years after the plan was originally published by AT&T in 1947. The first
two names associated with the plan contained the term Dialing Plan.

Numbers and a set defined switching architecture are what constituted
what we now know as the North American Numbering Plan. The numbers and
the architecture were both vital to the success of the plan. Following
the MFJ and the Telecommunications Act of 1996, the architectural plan
necessary for the orderly use of the numbers has unraveled and the
numbers have been extracted by regulators to be administered as a
separate entity without regard for the switching architecture.

Historically, numbering schemes expanded as dictated by equipment,
calling areas and services. The codified plan in 1947 enabled calls to
be automatically routed by the system and properly rated for billing
purposes. For all intents and purposes, telephone calls are still rated
and routed as envisioned in 1947. Revenues divided by each individual
company involved in the call rely on this.

The original plan created a numbering system that would last until the
end of the 20^th^ century. Well, here we are in 2004 still operating
with the 10-digit plan created in 1947. However, the network associated
with the plan is partially regulated, taxed and administered. The
network as we know it is not managed by any entity. New players created
by so called deregulation and new technologies are free riding on the
backs of those funding the existing system. This has created some severe
inefficiencies in the administration of telephone numbers. Technology
has outpaced the ability of regulations and administrators to keep up.
Major service providers have had to reduce work forces and create
operational support systems in order to reduce costs and keep up with
the work load. This has created a significant brain drain on the
telephone industry.

Newer technologies and services introduced into the communications
industry since the adoption of the NANP have been dealt with by using
the expansion techniques built into the original plan. Some of these
services and technologies introduced since the MFJ have not been dealt
with in the most efficient manner. The newer technologies that we see
being introduced in 2004 are creating some degrees of concern among
consumers and regulators. However, the NANP was created to be technology
independent and some previous technologies and services have been
integrated gracefully into the plan. Number uses of newer technologies
are dependent upon the interconnection and interoperability of the
technologies.

Uneven regulation and taxation are hampering the orderly integration of
new and old technology. Integration is the key since economics prevents
instant universal replacements of existing technologies. Integration is
further hampered by regulators not being able to agree on what exactly
the new technology is and how it fits in. Some new players are taking
advantage of this by offering services with little investment in actual
network elements. They can offer services to the consumer much cheaper
because they are not faced with funding the same elements as the
incumbents or providing the reliability and dependability that consumers
have had from their existing communications systems.

Many countries of the world have had to expand their national dialing
systems in the last 10 years due to new technologies, services and
growth. The world itself had to expand the maximum amount of digits
allowed under each national dialing plan from 12 to 15 digits in order
to accommodate this. This occurred on January 1, 1997.

The telephone industry has developed an orderly expansion from the
10-digit NANP to a 12-digit NANP. If newer technologies and services
require additional numbers, the plan can be implemented.

Work by the NANC, and other groups about number uses, is premature. The
playing field needs to be leveled and government regulators need to
decide what exactly the new technology constitutes and whether the new
technology becomes the PSTN when it starts completing public
communications messages, whether they are voice or text. One person's
data can be another's entertainment.

If we look at the last 2 years, we will discover that the biggest
unforecasted impact on the NANP has been the U.S. Federal Government.
The FCC has used up the N11 Service Access Codes and redefined them as
abbreviated dialing codes. Congress has seen fit to comply with
lobbyists and asked for a 3-digit phone number when there is no such
thing as a 3-digit phone number. Now the Department of the Navy, and
presumably the entire Department of Defense, is seeking a single area
code.

Some of the numbering impacts can be lessened by:

-   Applying the same regulations to all segments (especially taxation)

-   Having users of numbering resources play by the same rules

-   Eliminate distance sensitive billing

-   Eliminate rate centers, LATAs and state boundary limitations

-   Institute time only billing

-   Integrate PSAPs , Wireless, and large PBXs into the PSTN

-   Adopt the universal 10-digit dialing plan developed by INC.

-   Approve the INC NANP Expansion Plan

If the goal is deregulation and competition, then the goal should be to
let the numbering demand adapt to meet the competitive needs.