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                                                                                                                     DA 98-2636
                       December 28, 1998

The Honorable Sheila Lumpe
Chair
Missouri Public Utility Commission
P.O. Box 360
Jefferson City, Missouri 65102

     Re:  Request for Relief for 314 Numbering Plan Area

Dear Chairperson Lumpe:

     This letter responds to the Missouri Public Service Commission's December 1, 1998,
request that the Federal Communications Commission direct the North American Numbering Plan
Administrator (NANPA) to release a new area code to provide relief for the 314 Numbering Plan
Area (NPA).  In a Report and Order issued on July 22, 1998, the Missouri Commission ordered
implementation of a two-way geographic split of the existing 314 NPA in the St. Louis
metropolitan area.  In compliance with the Order, Southwestern Bell Telephone Company (SBC)
requested a new NPA in order to implement the approved NPA relief plan.  Due to the significant
imbalance in the projected lifetimes of the new and relieved NPAs,  however, the NANPA
determined that releasing the requested code would violate the industry's numbering assignment
guidelines which state that imbalances of 15 years or more shall be avoided.  Consequently, the
NANPA sought direction from the North American Numbering Council (NANC) prior to acting
on SBC's NPA request. 

     On August 26, 1998, the NANC forwarded to the Chief of the Common Carrier Bureau
its recommendation that the NANPA release the requested code.  The NANC noted the large
disparity in the forecasts of the lives of the new and revised NPAs under the proposed split.  The
NANC expressed greater concern, however, about the estimated life of the revised 314 NPA,
noting that SBC witnesses in the Missouri Commission proceeding estimated that the revised 314
NPA could exhaust as early as 2002, and the new NPA as 
early as 2009, if the Missouri Commission implemented no conservation procedures.  Given these
concerns, the NANC recommended that the Missouri Commission be asked to implement
conservation measures to ensure that the 314 NPA does not exhaust in less than five years.

     Upon review, the Common Carrier Bureau accepts the NANC's recommendation.  By
copy of this letter, we direct the NANPA to release the requested NPA code as soon as practical. 
We remain gravely concerned, however, about the potential imbalance and early exhaust problems
raised by the Missouri Commission's NPA relief plan for the 314 NPA.  As a general matter, we
believe that the NPA relief plans adopted by state commissions should be in full compliance with
the industry guidelines regarding NPA relief planning.  Although we approve release of the
requested code in the instant case, we intend to review carefully and critically any future area
code relief plans that are clearly outside the industry guidelines.

     As recommended by the NANC, we encourage the Missouri Commission to proceed with
examining and implementing number conservation measures, as contemplated by the July 22
Order, to ensure that the revised 314 NPA does not exhaust in less than five years.  In this regard,
the FCC recently signalled its desire to work cooperatively with state commissions on number
conservation strategies, by granting additional, limited delegations of authority to the state
commissions, where appropriate, to enable them to implement innovative number conservation
methods.  We invite you to explore these opportunities.

                                   Sincerely,


                                   Yog R. Varma
                                   Deputy Chief, Common Carrier Bureau

cc:  Alan Hasselwander, Chairman, NANC
     Ronald R. Conners, Director, NANPA Lockheed Martin - IMS
          The Hon. M. Dianne Drainer, Vice Chair, Missouri Public Service Commission
          The Hon. Harold Crumpton, Commissioner, Missouri Public Service Commission
          The Hon. Robert G. Schemenauer, Commissioner, Missouri Public Service Commission
          The Hon. Connie Murray,  Commissioner, Missouri Public Service Commission