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The End Is Near: FCC delivers final nail in the coffin to 7-digit dialing in 87 area codes

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  critique policy telecom

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UPDATE: The number of affected area codes is 87, not 88. As this continues to be an evolving situation, refer to the Anti-Digit Dialing League's official website for the latest details.

WASHINGTON, July 16, 2020—Today, the Federal Communications Commission adopted rules to establish 988 as the new, nationwide, 3-digit phone number for Americans in crisis to connect with suicide prevention and mental health crisis counselors. The rules require all phone service providers to direct all 988 calls to the existing National Suicide Prevention Lifeline by July 16, 2022.

To ensure that calls to 988 reach the National Suicide Prevention Lifeline, all covered providers will be required to implement 10-digit dialing in areas that both use seven-digit dialing and use 988 as the first three numbers in seven-digit phone numbers. — FCC Press Release, 7/16/2020

Wait, what? All covered providers will be required to implement 10-digit dialing… — cue screeching, wailing horror music.

Time's up. You can't hide any longer. You can't run. Michael Myers has arrived, and this time, there's no escape. The FCC finally has you cornered. What began as an assault on the liberties of Americans all across our country is all but finished now, and the FCC has just raised the hammer that will strike the final nail into the coffin.

Unless you've been closely following the telecom industry, as we do, you may or may not have heard about the mandation of 988 dialing throughout the U.S. Its history goes back to the National Suicide Hotline Improvement Act of 2018. Although the FCC released a report yesterday, much of it quotes material verbatim from an older report which dates to August 14, 2019. In other words, the stage has been set for this murder for some time. And who is the victim of the FCC's latest scheme? More than two hundred area codes which will lose the ability to dial local calls as seven digits.

This isn't the first assault on the integrity of our nation's dialing plan. Since the 2000s, overlays have overtaken splits as the predominant way of dealing with number shortages in area codes, even though splits are objectively superior to overlays. More recently, the FCC gave the middle finger salute to operators of private branch exchanges by requiring 911 be dialable from internal phone systems without requiring any escape code, completely ignoring the implications of this unwarranted move. In all these cases, rather than address the underlying problems, the FCC has decided to place bandages on paper cuts and deliver puncture wounds, effectively waging a war of misguided and ignorant policy against the American people. Even though overlays cause irreparable damage to an area's numbering plan while splits yield only temporary pain, the FCC has decided that it would rather take the easy way out. All because one nine-year old was not educated about how phone systems work (we can thank Uncle Sam for raping Ma Bell for that), hundreds of millions of phone lines are now needlessly inconvenienced. And now, because the FCC has decided that it no longer needs to make a pretense of having any brains at all, it's arbitrarily decided that 988 is going to be a prefix-free dialing code from anywhere in the U.S., and you can say hello to Uncle Sam's middle finger if you don't like that.

Common sense would seem to dictate that 211 be allocated to this purpose. In fact, the National American Numbering Council recommended the same thing:

In its report, the NANC considered expanding the 211 code as a viable option because 211 is already used for crisis calling in some U.S. markets. It noted that “[a]llowing 211 operators to act as a first line of defense in suicide prevention calls might alleviate the pressure on 911 call takers and allow the caller to obtain assistance for other non-suicide related services in addition to mental health referrals.” But the NANC also recognized some disadvantages to expansion of the 211 code, such as requiring callers in crisis to navigate an interactive voice response system, and the potential training deficit of individuals answering 211 calls. — August 2019 Report, p. 5
N11 Code% of Total N11 Calls
61148.81%
91128.94%
41111.71%
3114.22%
2112.90%
5112.24%
8110.91%
7110.27%

The NANC goes on to make some fairly inflammatory remarks, including denigrating 511 users and managing to come to the obvious conclusion that repurposing 611 for the new code could be difficult. Indeed.

The NANC goes on to state the obvious:

At first, it would appear that the NANC supported using 211 for this purpose:

Ultimately, the NANC recommended expanding the 211 code beyond providing community services to include crisis and suicide prevention services, stating that is technically feasible and would be the most expedient and beneficial in providing easy access to suicide prevention and mental health crisis support services. However, the NANC also recommended that, if a single-purpose code is preferred, a new 3-digit dialing code—preferably 988—could be deployed for the use of a national suicide prevention and mental health crisis hotline. — p. 7

The NANC ultimately ruled in favor of 988 largely because of the (mostly justified) challenges associated with repurposing or piggybacking off of other N11 code:

  • Based on the record, we conclude that 211 is not appropriate for a nationwide suicide prevention hotline because it could create confusion and additional delays to callers in crisis.
  • And there are several advantages to repurposing 511, including that traveler use of 511 may be diminished
  • In particular, while 611 has not been officially designated by the FCC, data indicate that this code receives nearly 300 million calls annually.
  • In addition, the suicide call-volume projections from SAMHSA122 and the VA123 indicate that directing these calls to 911 would increase call volumes above levels that the 911 system can reasonably be expected to accommodate.

Ultimately, the NANC correctly concluded that reallocating 511 or 611 would be downright stupid. What doesn't make sense is that 311 was never considered, given that it is the least universally deployed N11 code in the NANPA. In this regard, NANC failed to do its due diligence, given that it correctly recognized the stupidity of repurposing numbers which receive millions of calls per year while ignoring a nonstandard N11 code that doesn't even work in many places. If the NANC didn't like 211, 311 wasn't a bad next option. And how many calls is this hotline really expecting? Is a 911 PSAP going to get suddenly inundated with these, to the point where it can no longer handle them? How hard would it be for a 911 operator to have a "TRANSFER TO SUICIDE PREVENTION" button on her console? One wonders how much thought really went into coming to these conclusions.

The NANC goes on to tout 988, largely because it's not a currently assigned area code:

Moreover, 988 has technical advantages. First of all, it is not currently assigned as a geographic area code and therefore does not suffer the same problems surrounding repurposing an existing area code. In addition, in order for a switch to detect a new, non-N11 three-digit code, it helps if the code is not comprised of the leading digits (often called the “prefix”) of a local number. In this regard, 988 has fewer corresponding central office code assignments across the U.S. than some other codes the NANC considered. — p. 15

The NANC then glosses over just one of the many bleak implications of this decision:

To be sure, the NANC cautioned in its report that “the 988 code is not without technical and operational concerns.” Specifically, the NANC explained that currently, it is unlikely that any non-N11 3-digit dialing code, such as 988, can be deployed ubiquitously across all networks. This is because “[s]ome wireline switches may be unable to support any new 3-digit dialing code that is not an N11 code.” For switches that can support 988, the NANC found that configuration and software upgrades could be implemented fairly quickly. We recognize that suicide does not discriminate by geographic region, and to be effective, any code designated for a national suicide prevention and mental health crisis hotline system must be ubiquitously deployed. From the NANC analysis, however, it seems that the current technical and operational concerns related to the 988 code could be more easily and quickly addressed and resolved than any re-education efforts related to repurposing a N11 code. Although we believe 988 is the fastest path to implementing a 3-digit code, Commission staff estimates that a relatively small percentage of legacy switches cannot accommodate the 988 code. As telephone companies continue to upgrade their legacy networks, we expect these legacy switches will be replaced, ultimately making the use of 988 as a designated suicide prevention and mental health crisis hotline ubiquitous.

There. They just came out and said it. Screw reliable phone service. The NANC doesn't care if millions of people lose reliable phone service, as long as they can dial 988. Hey, now that some phone tech somewhere has finally had it, maybe this number will prove useful to him…

But what about the rest of us? The NANC was kind enough to think of us, too. Here is the course of action the FCC ultimately decided to pursue:

If the 211 code is not expanded, then alternatively, the “988” non-N11 code should be deployed for a national suicide prevention and mental health crisis hotline system, as long as it is understood that 988 likely cannot be deployed ubiquitously across all networks, and mandatory 10-digit dialing may need to be implemented in area codes where 988 is assigned as a central office code in area codes where 7-digit local dialing is the norm. — p.71
Where 7-digit dialing within the area code is still allowed, TDM wireline switches would need to implement a post dial delay or inter-digit timeout to distinguish between calls to the new non-N11 3- digit dialing code or calls to the corresponding central office code, if assigned. Such a timeout could result in the caller terminating the call because he thinks the call failed, or unrelated calls being routed to the hotline when a 7-digit number is dialed too slowly. The post dial delay or inter-digit timeout would not be required if the 3-digit dialing code does not correspond to any assigned central office codes, or where mandatory 10-digit dialing already is implemented, assuming that the 3-digit code does not correspond to an area code already in service. — p. 94

Well, I hate timeouts as much as the next person, but hey, we have 011+ for international, so if dialing Operator results in a timeout, why not 988? Meh. The FCC never cared about timeouts before — why should it care now?

Here's a statistic that reveals the grim reality of the number of casualties resulting from this decision:

Approximately 161 area codes of 360 geographic area codes assigned and in service today allow 7-digit dialing (44.7%). — p. 94

There are about eighty-eight 988 central office codes assigned in area codes where 7-digit dialing is permissible for local calls in the U.S. and its territories. Those 88 central office codes are assigned in area codes across 38 states and territories. — p. 110

161 area codes. That's 161 area codes the FCC just screwed over. Are you one of the millions of people living in one of these 161 area codes that will soon be forced to part with a rational dialing plan? Scroll to the bottom if you are.

However, the 988 code is not without technical and operational concerns. To accommodate 988 as a 3-digit code in areas where 7-digit dialing is still the norm and 988 is already assigned as a central office code, TDM wireline switches would need to implement (if possible) a post dial delay or inter-digit timeout so the switch can determine if the call originator intended to dial 3 digits to reach the national crisis hotline or dial 7 digits in the form of 988-XXX-X to reach a local number. Service providers with TDM wireline switches that cannot implement a post dial delay or inter-digit timeout would either 1) need to implement mandatory 10-digit dialing for local calls in those areas where the 988 central office code is already assigned, or 2) replace the switches, or 3) be exempted from being required to complete calls to the 988 code on a 3-digit basis for those switches. In that exemption case, consumers would have to be educated to continue to dial 800-273-TALK or other toll-free numbers to reach the crisis hotline if 988 wasn’t supported by their service provider. — p. 109

Hey, I'm liking option 3!

If you're not already sick to your stomach, though — wait, it gets worse! The NANC actually had the audacity to try to spin this as a positive:

Indeed, 10-digit dialing could help simplify the implementation of 988 as a 3-digit code for a national crisis hotline, and could help advance nationwide number portability as well.

Right — because number portability is exactly what we all need right now, as if the assault on area codes being geographic in nature hasn't already gone far enough. To add insult to injury, the chief inconvenience of all of this 988 business is reduced to a mere afterthought in the NANC's recommendations:

In addition, those consumers in areas that move from 7-digit to 10-digit dialing because post dial delay or inter-digit timeout could not be implemented would also need to be made aware of the new dialing procedures. Service providers with customers in those impacted areas could alert customers via bill inserts, bill messages, website notices, etc. — p. 111

In addition. Oh, yeah, the fact that millions of people are going to lose 7-digit dialing permanently, don't forget to tell people about that, FCC. Wow.

A few things should be reiterated at this point. First, the number 988 itself is not anything special. It will simply forward to the toll-free number already designated as the National Suicide Hotline: 800-273-HELP. What's ironic about this is that the FCC doesn't expect that people have the mental capacity to remember 800-273-HELP, so it's decided to rip apart the dialing plans of 200+ area codes to allow for the code 988 to be dialed without a timeout, forcing tens of millions of people to now dial all local calls the same way they dial long-distance calls for no real reason. Even though most people are never going to dial 988 in their whole life, the FCC has decided that because it's so important that we have a 3-digit code assigned to this number, everybody else in this country can dial 3 (or 4) additional digits for every local call they make (because people can't remember 800-273-HELP, but they can definitely bear to dial their own area code for the rest of their lives). It's a classic FCC play. Confuse the heck out of people, and cause as much mayhem and inconvenience as possible. But let's be honest — what did you really expect from the FCC? Competence?

The whole situation is so ironic it isn't even funny. In the July 16, 2020 report released by the FCC, they actually state outright:

The first “is the assertion that an N11 number would be easier to remember than a 10 digit number — July 16 report, p. 6

No duh! This is exactly what the Anti-Digit Dialing League has been saying since 1962! Fewer numbers are better than more! Why dial more digits when you can dial fewer of them? But the FCC has decided that this single number is so important than every other number must now be dialed as 10 or 11 digits. How many hours of your life are you going to lose dialing your own area code?

We collectively mourn the loss of some of the last vestiges of the integrity of our nation's phone system. Its decline has been a sad chapter in American history, from the Rape of Ma Bell by Uncle Sam to releasing providers of last resort from their obligation to provide reliable telephone service and encouraging telecom companies to neglect their outside plant and allow copper to deteriorate.

But really, what did we expect from our government's most corrupt agency. It's led by former wireless lobbyists, and it continues to denies decades of non-industry science showing significant harm from non-ionizing radiation? And rather than promote real solutions for safe and reliable communications in emergencies, the FCC continues to promote delusional falsehoods instead.

Is there a silver lining? If it's any comfort, not every area code does have a 988 exchange — of the 161 area codes with 7-digit dialing, 88 have a 988 exchange, which means that 73 area codes will be able to keep 7-digit dialing — for now. Although this won't be the death of 7-digit dialing in the United States, it will certainty be the beginning of end, and the demise of 7-digit dialing for many Americans is looming nearer more certainty than ever before. The only hope for the 161 area codes with 988 exchanges is to have the 988 exchanges themselves reallocated so they don't need to lose 10-digit dialing. Common sense would dicatate the inconvenience of having these 10,000 people change their phone numbers pales in comparison to permanently burdening everyone in that entire area code from having to dial all their local calls as 10 or 11 digits. But does common sense usually prevail in America when telecom is concerned? And if history serves as any precedent, it probably won't this time, either.

Throughout the immense struggles we face today and the dark times ahead for our nation's phone system, the Anti-Digit Dialing League remains alive and well. As always: dues, none; donations, sought. Join the A.D.D.L. today! We've been opposing numbering nonsense in the United States since 1962. If you're affected by the FCC's latest moronic decision, we want to hear from you! If not, you can nonetheless stand in solidarity with the freshest victims of the FCC's latest show of incompetence.

Appendix A: 7-Digit Dialing Obituary

We mourn the loss of 7-digit dialing in many area codes today. Please join us for a moment of silence in recognizing the casualties of the following area codes:

Also: View list of affected area codes by state from NANPA.

+-------+----------------------+------+------+------------+-------+
| LATA  | LATA Name            | NPA  | NXX  | City       | State |
+-------+----------------------+------+------+------------+-------+
|   888 | CANADA               |  403 |  988 | CALGARY    | AB    |
|   888 | CANADA               |  587 |  988 | EDMONTON   | AB    |
|   888 | CANADA               |  780 |  988 | EDMONTON   | AB    |
|   888 | CANADA               |  825 |  988 | EDMONTON   | AB    |
|   832 | ALASKA               |  907 |  988 | JUNEAU     | AK    |
|   476 | BIRMINGHAM ALABAMA   |  205 |  988 | BIRMINGHAM | AL    |
|   480 | MOBILE ALABAMA       |  251 |  988 | MARLOW     | AL    |
|   528 | LITTLE ROCK ARKANSAS |  501 |  988 | JACKSONVL  | AR    |
|   666 | PHOENIX ARIZONA      |  480 |  988 | HIGLEY     | AZ    |
|   668 | TUCSON ARIZONA       |  520 |  988 | NOGALES    | AZ    |
|   666 | PHOENIX ARIZONA      |  928 |  988 | YUMA       | AZ    |
|   888 | CANADA               |  672 |  988 | CRANBROOK  | BC    |
|   888 | CANADA               |  250 |  988 | MACKENZIE  | BC    |
|   888 | CANADA               |  604 |  988 | NOVANCOUVR | BC    |
|   888 | CANADA               |  236 |  988 | VANCOUVER  | BC    |
|   888 | CANADA               |  778 |  988 | VANCOUVER  | BC    |
|   730 | LOS ANGELES CA       |  626 |  988 | ALHAMBRA   | CA    |
|   730 | LOS ANGELES CA       |  760 |  988 | BARSTOW    | CA    |
|   730 | LOS ANGELES CA       |  714 |  988 | BREA       | CA    |
|   730 | LOS ANGELES CA       |  805 |  988 | EL RIO     | CA    |
|   730 | LOS ANGELES CA       |  310 |  988 | INGLEWOOD  | CA    |
|   730 | LOS ANGELES CA       |  949 |  988 | IRVINE     | CA    |
|   730 | LOS ANGELES CA       |  562 |  988 | LONG BEACH | CA    |
|   730 | LOS ANGELES CA       |  213 |  988 | LSAN DA 01 | CA    |
|   730 | LOS ANGELES CA       |  323 |  988 | LSAN DA 13 | CA    |
|   738 | STOCKTON CA          |  209 |  988 | MODESTO    | CA    |
|   730 | LOS ANGELES CA       |  951 |  988 | MORENO     | CA    |
|   722 | SAN FRANCISCO CA     |  650 |  988 | MT VIEW    | CA    |
|   722 | SAN FRANCISCO CA     |  510 |  988 | OKLD FRTVL | CA    |
|   730 | LOS ANGELES CA       |  909 |  988 | ONTARIO    | CA    |
|   726 | SACRAMENTO CA        |  916 |  988 | ORANGEVALE | CA    |
|   724 | CHICO CA             |  530 |  988 | ORLAND     | CA    |
|   732 | SAN DIEGO CA         |  619 |  988 | SNDG SNDG  | CA    |
|   732 | SAN DIEGO CA         |  858 |  988 | SNDG SNDG  | CA    |
|   722 | SAN FRANCISCO CA     |  415 |  988 | SNFC JUNPR | CA    |
|   722 | SAN FRANCISCO CA     |  408 |  988 | SNJS WEST  | CA    |
|   730 | LOS ANGELES CA       |  818 |  988 | VAN NUYS   | CA    |
|   722 | SAN FRANCISCO CA     |  925 |  988 | WALNUT CRK | CA    |
|   722 | SAN FRANCISCO CA     |  707 |  988 | WHITETHORN | CA    |
|   656 | DENVER CO            |  720 |  988 | DENVER     | CO    |
|   656 | DENVER CO            |  303 |  988 | DENVERSWST | CO    |
|   656 | DENVER CO            |  970 |  988 | FT COLLINS | CO    |
|   658 | COLORADO SPRINGS CO  |  719 |  988 | LA VETA    | CO    |
|   920 | CONNECTICUT          |  475 |  988 | BRIDGEPORT | CT    |
|   920 | CONNECTICUT          |  203 |  988 | NEW HAVEN  | CT    |
|   920 | CONNECTICUT          |  860 |  988 | SIMSBURY   | CT    |
|   228 | PHILADELPHIA PA      |  302 |  988 | SELBYVILLE | DE    |
|   828 | DOMINICAN REPUBLIC   |  809 |  988 | SANTODMNGO | DR    |
|   828 | DOMINICAN REPUBLIC   |  829 |  988 | SANTODMNGO | DR    |
| 46018 | SOUTHEAST FL GR-EA   |  561 |  988 | BOCA RATON | FL    |
|   448 | PENSACOLA FLORIDA    |  850 |  988 | CANTONMENT | FL    |
|   454 | GAINESVILLE FL       |  352 |  988 | CLERMONT   | FL    |
| 45403 | GAINESVILLE FL OL-EA |  352 |  988 | CLERMONT   | FL    |
|   458 | ORLANDO FL           |  321 |  988 | EAU GALLIE | FL    |
|   460 | SOUTHEAST FLORIDA    |  954 |  988 | HOLLYWOOD  | FL    |
| 46017 | SOUTHEAST FL GG-EA   |  954 |  988 | HOLLYWOOD  | FL    |
| 45204 | JACKSONVIL FL CL-EA  |  904 |  988 | JACKSONVL  | FL    |
|   460 | SOUTHEAST FLORIDA    |  305 |  988 | KEYS       | FL    |
|   460 | SOUTHEAST FLORIDA    |  786 |  988 | MIAMI      | FL    |
| 46017 | SOUTHEAST FL GG-EA   |  786 |  988 | MIAMI      | FL    |
|   458 | ORLANDO FL           |  407 |  988 | ORLANDO    | FL    |
|   952 | TAMPA FLORIDA        |  941 |  988 | SARASOTA   | FL    |
|   952 | TAMPA FLORIDA        |  813 |  988 | TAMPACEN   | FL    |
|   438 | ATLANTA GEORGIA      |  404 |  988 | ATLANTA    | GA    |
|   438 | ATLANTA GEORGIA      |  770 |  988 | ATLANTA NW | GA    |
|   438 | ATLANTA GEORGIA      |  678 |  988 | CEDARTOWN  | GA    |
|   438 | ATLANTA GEORGIA      |  470 |  988 | GRANTVILLE | GA    |
|   446 | MACON GEORGIA        |  478 |  988 | PERRY      | GA    |
|   440 | SAVANNAH GEORGIA     |  912 |  988 | POOLER     | GA    |
|   438 | ATLANTA GEORGIA      |  706 |  988 | ROYSTON    | GA    |
|   871 | GUAM                 |  671 |  988 | AGANA      | GU    |
|   834 | HAWAII               |  808 |  988 | MANOA      | HI    |
|   632 | DES MOINES IOWA      |  515 |  988 | DES MOINES | IA    |
|   635 | CEDAR RAPIDS IOWA    |  319 |  988 | HUDSON     | IA    |
|   652 | IDAHO                |  208 |  988 | BOISE      | ID    |
|   358 | CHICAGO ILLINOIS     |  312 |  988 | CHICGOZN01 | IL    |
|   358 | CHICAGO ILLINOIS     |  773 |  988 | CHICGOZN01 | IL    |
|   362 | CAIRO ILLINOIS       |  618 |  988 | HERRIN     | IL    |
|   358 | CHICAGO ILLINOIS     |  630 |  988 | LA GRANGE  | IL    |
|   358 | CHICAGO ILLINOIS     |  708 |  988 | LA GRANGE  | IL    |
|   358 | CHICAGO ILLINOIS     |  847 |  988 | LA GRANGE  | IL    |
|   368 | PEORIA ILLINOIS      |  309 |  988 | LACON      | IL    |
|   360 | ROCKFORD ILLINOIS    |  815 |  988 | ROCKFORD   | IL    |
|   336 | INDIANAPOLIS INDIANA |  317 |  988 | INDIANAPLS | IN    |
|   358 | CHICAGO ILLINOIS     |  219 |  988 | LKSFRSSONS | IN    |
|   338 | BLOOMINGTON INDIANA  |  812 |  988 | NASHVILLE  | IN    |
|   332 | SOUTH BEND INDIANA   |  574 |  988 | NEWCARLISL | IN    |
|   826 | JAMAICA              |  876 |  988 | KINGSTON   | JM    |
|   534 | TOPEKA KANSAS        |  785 |  988 | BENDENA    | KS    |
|   532 | WICHITA KANSAS       |  620 |  988 | COFFEYVL   | KS    |
|   466 | WINCHESTER KENTUCKY  |  859 |  988 | PARIS      | KY    |
|   464 | OWENSBORO KENTUCKY   |  270 |  988 | SALEM      | KY    |
|   488 | LAFAYETTE LOUISIANA  |  337 |  988 | LAFAYETTE  | LA    |
|   490 | NEW ORLEANS LA       |  504 |  988 | NEWORLEANS | LA    |
|   128 | EASTERN MASS         |  617 |  988 | BOSTON     | MA    |
|   128 | EASTERN MASS         |  508 |  988 | FRAMINGHAM | MA    |
| 99999 | LATA NOT APPLICABLE  |  413 |  988 | PLANT TEST | MA    |
|   128 | EASTERN MASS         |  978 |  988 | WILMINGTON | MA    |
|   888 | CANADA               |  204 |  988 | WINNIPEG   | MB    |
|   888 | CANADA               |  431 |  988 | WINNIPEG   | MB    |
|   242 | SALISBURY MARYLAND   |  443 |  988 | CENTREVL   | MD    |
|   238 | BALTIMORE MARYLAND   |  410 |  988 | ELLICOTTCY | MD    |
|   240 | HAGERSTOWN MARYLAND  |  301 |  988 | HAGERSTOWN | MD    |
|   236 | WASHINGTON DC        |  240 |  988 | SILVER SPG | MD    |
|   340 | DETROIT MICHIGAN     |  248 |  988 | BIRMINGHAM | MI    |
|   342 | UPPER PENINSULA MI   |  906 |  988 | EWEN       | MI    |
|   348 | GRAND RAPIDS MI      |  616 |  988 | GRAND RPDS | MI    |
|   340 | DETROIT MICHIGAN     |  810 |  988 | MONTROSE   | MI    |
|   344 | SAGINAW MICHIGAN     |  989 |  988 | SAGINAW    | MI    |
|   636 | BRAINERD-FARGO ND    |  218 |  988 | HALLOCK    | MN    |
|   628 | MINNEAPOLIS MINN     |  952 |  988 | HOPKINS    | MN    |
|   524 | KANSAS CITY MISSOURI |  816 |  988 | BLUE SPG   | MO    |
|   524 | KANSAS CITY MISSOURI |  660 |  988 | KIRKSVILLE | MO    |
|   522 | SPRINGFIELD MISSOURI |  417 |  988 | SPRINGFLD  | MO    |
|   520 | ST LOUIS MISSOURI    |  314 |  988 | ST LOUIS   | MO    |
|   482 | JACKSON MISSISSIPPI  |  601 |  988 | JACKSON    | MS    |
|   482 | JACKSON MISSISSIPPI  |  662 |  988 | MYRTLE     | MS    |
|   648 | GREAT FALLS MT       |  406 |  988 | DILLON     | MT    |
|   888 | CANADA               |  506 |  988 | MONCTON    | NB    |
|   422 | CHARLOTTE NC         |  704 |  988 | CHARLOTTE  | NC    |
|   949 | FAYETTEVILLE         |  910 |  988 | FAYETTEVL  | NC    |
|   426 | RALEIGH N CAROLINA   |  919 |  988 | GOLDSBORO  | NC    |
|   424 | GREENSBORO NC        |  336 |  988 | GREENSBORO | NC    |
|   638 | BISMARK NORTH DAKOTA |  701 |  988 | BISMARCK   | ND    |
|   958 | LINCOLN NEBRASKA     |  402 |  988 | ADAMS      | NE    |
|   888 | CANADA               |  709 |  988 | NORMANSBAY | NF    |
|   122 | NEW HAMPSHIRE        |  603 |  988 | PORTSMOUTH | NH    |
|   224 | NORTH JERSEY NJ      |  732 |  988 | ASBURYPARK | NJ    |
|   224 | NORTH JERSEY NJ      |  201 |  988 | JERSEYCITY | NJ    |
|   222 | DELAWARE VALLEY NJ   |  856 |  988 | MARLTON    | NJ    |
|   224 | NORTH JERSEY NJ      |  973 |  988 | MT VIEW    | NJ    |
|   224 | NORTH JERSEY NJ      |  908 |  988 | SUMMIT     | NJ    |
|   664 | NEW MEXICO           |  575 |  988 | CARLSBAD   | NM    |
|   664 | NEW MEXICO           |  505 |  988 | SANTA FE   | NM    |
|   888 | CANADA               |  782 |  988 | WALTON     | NS    |
|   888 | CANADA               |  902 |  988 | YARMOUTH   | NS    |
|   888 | CANADA               |  867 |  988 | YELLOWKNIF | NT    |
|   720 | RENO NEVADA          |  775 |  988 | ROUND MT   | NV    |
|   721 | PAHRUMP NEVADA       |  702 |  988 | SEARCHLIHT | NV    |
|   132 | NEW YORK METRO NY    |  917 |  988 | BROOKLYN   | NY    |
|   136 | SYRACUSE NEW YORK    |  315 |  988 | COPENHAGEN | NY    |
|   134 | ALBANY NEW YORK      |  518 |  988 | HILLSDALE  | NY    |
|   132 | NEW YORK METRO NY    |  631 |  988 | HUNTINGTON | NY    |
|   132 | NEW YORK METRO NY    |  212 |  988 | NWYRCYZN01 | NY    |
|   132 | NEW YORK METRO NY    |  646 |  988 | NWYRCYZN01 | NY    |
|   132 | NEW YORK METRO NY    |  347 |  988 | NWYRCYZN07 | NY    |
|   132 | NEW YORK METRO NY    |  929 |  988 | NWYRCYZN15 | NY    |
|   138 | BINGHAMTON NEW YORK  |  607 |  988 | OTEGO      | NY    |
|   140 | BUFFALO NEW YORK     |  716 |  988 | SO DAYTON  | NY    |
|   132 | NEW YORK METRO NY    |  718 |  988 | STATEN IS  | NY    |
|   133 | POUGHKEEPSIE NY      |  845 |  988 | WARWICK    | NY    |
|   132 | NEW YORK METRO NY    |  516 |  988 | WESTBURY   | NY    |
|   132 | NEW YORK METRO NY    |  914 |  988 | WSCHSTZN08 | NY    |
|   320 | CLEVELAND OHIO       |  440 |  988 | AMHERST    | OH    |
|   328 | DAYTON OHIO          |  937 |  988 | BEAVERCREK | OH    |
|   923 | LIMA-MANSFIELD OHIO  |  419 |  988 | CHATFIELD  | OH    |
|   324 | COLUMBUS OHIO        |  614 |  988 | GAHANNA    | OH    |
|   324 | COLUMBUS OHIO        |  740 |  988 | JACKSON    | OH    |
|   328 | DAYTON OHIO          |  513 |  988 | TRENTON    | OH    |
|   923 | LIMA-MANSFIELD OHIO  |  330 |  988 | WOOSTER    | OH    |
|   536 | OKLAHOMA CITY OK     |  405 |  988 | MCLOUD     | OK    |
| 99999 | LATA NOT APPLICABLE  |  918 |  988 | PLANT TEST | OK    |
|   888 | CANADA               |  289 |  988 | AJAXPCKRNG | ON    |
|   888 | CANADA               |  365 |  988 | AJAXPCKRNG | ON    |
|   888 | CANADA               |  548 |  988 | GUELPH     | ON    |
|   888 | CANADA               |  226 |  988 | KITCHEWTRL | ON    |
|   888 | CANADA               |  343 |  988 | OTTAWAHULL | ON    |
|   888 | CANADA               |  249 |  988 | PARRYSOUND | ON    |
|   888 | CANADA               |  613 |  988 | SMITHS FLS | ON    |
|   888 | CANADA               |  905 |  988 | STCTNSTHLD | ON    |
|   888 | CANADA               |  705 |  988 | SUDBURY    | ON    |
|   888 | CANADA               |  416 |  988 | TORONTO    | ON    |
|   888 | CANADA               |  437 |  988 | TORONTO    | ON    |
|   888 | CANADA               |  647 |  988 | TORONTO    | ON    |
|   888 | CANADA               |  519 |  988 | WINDSOR    | ON    |
|   672 | PORTLAND OREGON      |  971 |  988 | ASTORIA    | OR    |
|   670 | EUGENE OREGON        |  541 |  988 | EUGENE     | OR    |
|   672 | PORTLAND OREGON      |  503 |  988 | PORTLAND   | OR    |
|   670 | EUGENE OREGON        |  541 |  988 | SPRINGFLD  | OR    |
|   228 | PHILADELPHIA PA      |  484 |  988 | BALACYNWYD | PA    |
|   228 | PHILADELPHIA PA      |  267 |  988 | FEASTERVL  | PA    |
|   234 | PITTSBURGH PA        |  724 |  988 | GREENVILLE | PA    |
|   226 | CAPITAL PENNSYLVANIA |  717 |  988 | HARISBGZN1 | PA    |
|   228 | PHILADELPHIA PA      |  215 |  988 | PHILA      | PA    |
|   228 | PHILADELPHIA PA      |  267 |  988 | PHPHSBZN40 | PA    |
| 99999 | LATA NOT APPLICABLE  |  814 |  988 | PLANT TEST | PA    |
|   224 | NORTH JERSEY NJ      |  610 |  988 | READING    | PA    |
|   228 | PHILADELPHIA PA      |  610 |  988 | READING    | PA    |
|   232 | NORTHEAST - PA       |  570 |  988 | SUNBURY    | PA    |
|   888 | CANADA               |  418 |  988 | CHARNY     | PQ    |
|   888 | CANADA               |  450 |  988 | CHOMEDEY   | PQ    |
|   888 | CANADA               |  438 |  988 | MONTREAL   | PQ    |
|   888 | CANADA               |  514 |  988 | MONTREAL   | PQ    |
|   888 | CANADA               |  819 |  988 | PUVIRNITUK | PQ    |
|   888 | CANADA               |  581 |  988 | QUEBEC     | PQ    |
|   888 | CANADA               |  873 |  988 | SHERBROOKE | PQ    |
|   888 | CANADA               |  579 |  988 | ST THERESE | PQ    |
|   820 | PUERTO RICO          |  787 |  988 | FAJARDO    | PR    |
|   434 | COLUMBIA S CAROLINA  |  803 |  988 | COLUMBIA   | SC    |
|   434 | COLUMBIA S CAROLINA  |  843 |  988 | HARLEYVL   | SC    |
|   640 | SOUTH DAKOTA         |  605 |  988 | SIOUX FLS  | SD    |
|   888 | CANADA               |  306 |  988 | REGINA     | SK    |
|   888 | CANADA               |  639 |  988 | WILCOX     | SK    |
|   468 | MEMPHIS TENNESSEE    |  731 |  988 | JACKSON    | TN    |
|   474 | KNOXVILLE TENNESSEE  |  865 |  988 | LENOIRCITY | TN    |
|   470 | NASHVILLE TENNESSEE  |  615 |  988 | NASHVILLE  | TN    |
|   999 | RESERVED FOR SVCS    |  710 |  988 | 710SERVICE | TS    |
|   560 | HOUSTON TEXAS        |  281 |  988 | ALIEF      | TX    |
|   548 | WICHITA FALLS TEXAS  |  940 |  988 | ASPERMONT  | TX    |
|   558 | AUSTIN TEXAS         |  512 |  988 | BASTROP    | TX    |
|   560 | HOUSTON TEXAS        |  346 |  988 | CLEVELAND  | TX    |
|   540 | EL PASO TEXAS        |  915 |  988 | DESERT HVN | TX    |
|   552 | DALLAS TEXAS         |  469 |  988 | ENNIS      | TX    |
|   552 | DALLAS TEXAS         |  817 |  988 | GLENDALE   | TX    |
|   552 | DALLAS TEXAS         |  214 |  988 | GRANDPRARI | TX    |
|   552 | DALLAS TEXAS         |  972 |  988 | GRANDPRARI | TX    |
|   560 | HOUSTON TEXAS        |  713 |  988 | HOUSTON    | TX    |
|   554 | LONGVIEW TEXAS       |  430 |  988 | HUGHES SPG | TX    |
|   554 | LONGVIEW TEXAS       |  903 |  988 | KILGORE    | TX    |
|   564 | CORPUS CHRISTI TEXAS |  361 |  988 | LOLITA     | TX    |
|   562 | BEAUMONT TEXAS       |  409 |  988 | ORANGE     | TX    |
|   556 | WACO TEXAS           |  254 |  988 | ROSEBUD    | TX    |
|   566 | SAN ANTONIO TEXAS    |  830 |  988 | SABINAL    | TX    |
|   566 | SAN ANTONIO TEXAS    |  210 |  988 | SANANTONIO | TX    |
|   560 | HOUSTON TEXAS        |  832 |  988 | SUGAR LAND | TX    |
|   536 | OKLAHOMA CITY OK     |  806 |  988 | W ROGER ML | TX    |
|   660 | UTAH                 |  385 |  988 | FARMINGTON | UT    |
|   660 | UTAH                 |  801 |  988 | KEARNS     | UT    |
|   660 | UTAH                 |  801 |  988 | MIDVALE    | UT    |
|   248 | RICHMOND VIRGINIA    |  804 |  988 | ASHLAND    | VA    |
|   236 | WASHINGTON DC        |  703 |  988 | BRADDOCK   | VA    |
|   252 | NORFOLK VIRGINIA     |  757 |  988 | PENINSULA  | VA    |
|   244 | ROANOKE VIRGINIA     |  540 |  988 | ROANOKE    | VA    |
|   932 | BLUE FIELD WV        |  276 |  988 | TAZEWELL   | VA    |
|   124 | VERMONT              |  802 |  988 | NORTH TROY | VT    |
|   676 | SPOKANE WASHINGTON   |  509 |  988 | ODESSA     | WA    |
|   674 | SEATTLE WASHINGTON   |  425 |  988 | RENTON     | WA    |
|   674 | SEATTLE WASHINGTON   |  206 |  988 | SEATTLE    | WA    |
|   674 | SEATTLE WASHINGTON   |  360 |  988 | SUMAS      | WA    |
|   674 | SEATTLE WASHINGTON   |  253 |  988 | TACOMA     | WA    |
|   674 | SEATTLE WASHINGTON   |  360 |  988 | WHATCOMCTY | WA    |
|   356 | SOUTHEAST WISCONSIN  |  414 |  988 | MILWAUKZN1 | WI    |
|   354 | SOUTHWEST WISCONSIN  |  608 |  988 | MOUNT HOPE | WI    |
|   342 | UPPER PENINSULA MI   |  715 |  988 | NIAGARA    | WI    |
|   356 | SOUTHEAST WISCONSIN  |  262 |  988 | PTWASHIGTN | WI    |
|   356 | SOUTHEAST WISCONSIN  |  920 |  988 | WATERTOWN  | WI    |
|   254 | CHARLESTON WV        |  304 |  988 | CHRLSTNZN2 | WV    |
|   254 | CHARLESTON WV        |  304 |  988 | SISSONVL   | WV    |
|   888 | CANADA               |  622 |  988 | NGC-CANADA | XX    |
|   999 | RESERVED FOR SVCS    |  500 |  988 | SACSERVICE | XX    |
|   999 | RESERVED FOR SVCS    |  521 |  988 | SACSERVICE | XX    |
|   999 | RESERVED FOR SVCS    |  522 |  988 | SACSERVICE | XX    |
|   999 | RESERVED FOR SVCS    |  523 |  988 | SACSERVICE | XX    |
|   999 | RESERVED FOR SVCS    |  533 |  988 | SACSERVICE | XX    |
|   999 | RESERVED FOR SVCS    |  544 |  988 | SACSERVICE | XX    |
|   999 | RESERVED FOR SVCS    |  566 |  988 | SACSERVICE | XX    |
|   999 | RESERVED FOR SVCS    |  577 |  988 | SACSERVICE | XX    |
|   999 | RESERVED FOR SVCS    |  588 |  988 | SACSERVICE | XX    |
+-------+----------------------+------+------+------------+-------+

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