20070612Application.pdf

MORGENSTERN, DALE C, A TTOPS
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From:
Sent:
To:
Subject:
MORGENSTERN, DALE C, ATTOPS
Thursday, May 24,20075:10 PM
carolee.hall ~ puc.idaho.gov
Sandpoint Safety Valve
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Attachments:Sandpointdoc; Sandpoint Safety Valve MTE data 5-07.xls; san~~oinipAiMTE.Pdf;
Sand point Rejection 2007.pdf
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Sand point Safety
Valve MTE daL
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Sand POint doc (57
KB)
Sand point PAS 3andpoint Rejection
MTE.pdf (49 KB) 2007.pdf (...
Carolee:
Let me introduce myself. I am with the new AT&T, responsible for interfacing with the
Commissions wrt safety valves and other numbering and 911 issues. In the legacy AT&T I had a
similar function.
The above data , however, is a safety valve for Cingular. It is my 1st one , so please be patient. I
am including the request , MTE data for Sandpoint and the PAS output. Please feel free to call
me if additional information is needed.
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June 7, 2007
Via Electronic Mail
Ms. Carolee Hall
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702-5983
A-ff-l-O7-O
RE:AT&T Mobility Safety Valve Request for Sandpoint Rate Center
Confidentiality Requested
Dear Ms. Hall:
AT&T Mobility (fonnerly known as Cingular Wireless and Blue License
Holding) respectfully requests that the Idaho Public Utilities Commission
Commission ) grant an immediate and expedited safety valve request to AT&T
Mobility for additional numbering resources for the Sandpoint rate center. AT&T
Mobility applied for a thousands-block from the Pooling Administrator ("P A") but was
been denied as it did not meet the required utilization rate of seventy-five (75) percent.
Attached is a copy of the P A denial. Due to unique circumstances described in more
detail below, AT&T Mobility requires a thousands-bock immediately for the Sandpoint
Rate Center so that it can continue to provide service to new customers in that area.
The Idaho Commission Should Grant AT&T Mobility's Safety Valve
Request for Additional Numbering Resources in the Sandpoint Rate Center
In contemplation of unique situations such as this, the Federal Communications
Commission ("FCC") in its 3rd NRoI instituted a safety valve mechanism and delegated
authority to state commissions to grant such requests. As set forth by the FCC in the 3rd
NRO states can direct the P A to assign additional numbering resources to carriers that
have demonstrated a verifiable need for additional numbering resources if the carrier will
exhaust its numbering resources within three months and projected growth for the rate
center is based on actual or projected growth, but only ifthat projected growth varies no
See In the Matter of Number Resource Optimization Third Report and Order ("3rd
NRO", CC Docket No. 99-200, (reI. Dec. 28 2001), paragraphs 61-66.
more than fifteen percent (15%) from historical growth.2 AT&T Mobility submits the
following infonnation demonstrating its need for additional numbering resources in the
Sandpoint rate center.
AT&T Mobility does not meet the seventy-five percent (75%) utilization rate to
qualify for additional numbering resources in the Sandpoint rate center due to two
factors: 1) AT&T Mobility does not have many numbers in this rate center, and 2) AT&T
Mobility needs to use two (2) thousands-blocks in this rate center as administrative
numbers. As described in the attachment, of the nine thousands-blocks, AT&T Mobility
has in this rate center, six thousand fifty eight (6058) numbers are assigned, two thousand
000) numbers are administrative and three hundred seventy two (372) numbers are
available for assignment for a utilization factor of 67.311 %. As described in the attached
spreadsheet, based on AT&T Mobility's projected growth in this rate center AT&T
Mobility anticipates that it will exhaust before the three month requirement as set forth by
the FCC for safety valve requests.
The two (2) thousands-blocks that are being used as administrative numbers from
this rate center have been assigned as E.164 numbers for Global Title Translations.
E.164 is an ITU Telecommunications Standardization Sector (UTU - T) recommendation
which defines the international public numbering plan used in the public switched
telephone network including GSM (and UMTS) transmission technology utilized by
AT&T Mobility and other carriers. At its simplest level, E.164 numbers are numbers
used as part of a network addressing scheme that allows for the identification of the
location ofthe customer along with the carrier serving that customer.3 To accomplish
this, each switch within AT&T Mobility's network must be assigned at least one E.164
number and the E.164 numbers are announced to our roaming partners both domestically
and internationally. Further, these numbers have some geographic significance; as such
AT&T Mobility is utilizing the E.164 administrative numbers from the two (2)
thousands-blocks in the Sandpoint Rate Center for its switches and other network
elements in Idaho as well as'California, Oregon, Montana, Nevada, Colorado, Arizona
New Mexico , Idaho, Utah, Wyoming and Washington. Still not clear why 1K are
needed?
AT&T Mobility has investigated whether numbers within these two blocks could
be released for potential activation to new customers and/or whether it could assign these
164 numbers from a thousands-block in a different rate center. AT&T Mobility has
found that neither of these options is feasible without potentially affecting service and
billing to customers. First, due to limitations with data translations in the switches the
E.164 administrative numbers should preferably be contiguous. Not clear why? Second
reassigning the E.164 number would cause AT&T Mobility to renumber a large number
3rd NRO paragraph 63
3 Global title translation is the use of a non-SS7 identifier as a routing address. Global title translation is
necessary when the point code of the destination network node is not known, or when the destination is in
another country. Analysis of the global title may occur at several STPs or international gateways in the
signaling path, until it is fmally possible to convert the global title into the destination point code.
of switches. This has the potential of causing switch outages of varying in length from
hundreds of minutes to several hours which would impact customers' ability to make or
receive calls. Further, these numbers have been "broadcast" to all of our roaming
partners both domestically and internationally, so that any changes would need to be re-
communicated which can increase the likelihood of errors occurring. The change notice
and request has a minimum forty-five (45) day lead time.
Conclusion
For the foregoing reasons, AT&T Mobility believes that the assignment of additional
thousand blocks in the Sandpoint rate are in the public interest and the Idaho Commission
should direct the P A to assign one (1) thousands-block to AT&T Mobility as soon aspossible.
If you have any questions regarding this matter, please contact...
Sincerely,
Dale C. Morgenstern
AT&T - Network Regulatory
0: 908-234-5120
F: 908-532-1413
Attachments
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