20070625final_order_no_30351.pdf

Office of the Secretary
Service Date
June 25, 2007
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
AT&T MOBILITY'S REQUEST FOR A
WAIVER OF FCC THRESHOLD
REQUIREMENTS FOR NUMBERING
RESOURCES IN IDAHO'S SANDPOINT
RATE CENTER
ORDER NO. 30351
CASE NO. ATT-07-
On May 29, 2007, AT&T Mobility (f/k/a "Cingular Wireless" and "Blue License
Holding ) filed a request for a waiver of numbering resource guidelines following denial of its
application filed with Neustar, the North American Number Plan Administrator ("NANP A"
On May 2, 2007, AT&T requested 1 000 additional numbers from the Pooling Administrator
P A") in order to meet customer demand in the Sandpoint, Idaho area.
THE PETITION
AT&T has filed an application for additional numbering resources in the Sandpoint
rate center. In its application to Neustar, AT&T submitted an MTE Worksheet indicating when
AT&T would deplete or exhaust its numbering resources in the Sandpoint rate center. The
worksheet calculated that the number utilization rate would be 67.311 %. The Company
application was ultimately denied because it did not meet NANPA's 75% threshold utilization
rate requirement for Idaho.
The Commission "may affirm or overturn the NANPA's decision to withhold
numbering resources from the carrier based on its determination of compliance with the
reporting and numbering resource" requirement. 47 C.R. ~ 52. 15(g)(3)(B)(iv). AT&T has
made a "safety valve" request for additional numbering resources in the Sandpoint rate center
based upon a "verifiable need " demonstration that it will exhaust its numbering resources within
three months, and the actual or projected growth for the rate center. AT&T Transmittal Letter
1. The Company asserts that it (1) "does not have many numbers in this rate center, and (2)
AT&T Mobility needs to use two thousand-blocks in this rate center as administrative numbers.
Id. at 2. The 2 000 numbers in the Sandpoint rate center are reserved for Global Title
Translations, leaving only 372 numbers for future customer assignment. AT&T claims that it
has investigated whether it could release the administrative numbers and assign them to its new
ORDER NO. 30351
customers and/or transfer the reserved numbers to another rate center. The Company states that
either option could potentially have an adverse effect on customer service and billing.
STAFF ANALYSIS
Staff recommended that the Commission grant AT&T's request. Staff noted that it
contacted Neustar regarding AT&T's application to overturn Neustar s decision to deny the
Company s request for additional numbering resources and was informed that it may be
reasonable for AT&T to request additional numbering resources given the architecture of its
network. Staff also noted that similar requests have been granted by this Commission in the past
and that if the 2 000 reserve numbers were removed from AT&T's calculation of its utilization
rate then it would meet the 75% utilization requirement for Idaho. Thus, Staff concluded that
granting AT&T's request for additional numbering resources would not result in an inefficient
use of Idaho s numbering resources.
DISCUSSION
After reviewing AT&T's Petition and Staffs recommendation , the Commission finds
that AT&T's Petition should be granted. Further, the Commission finds that the requested
number assignment is necessary for AT&T to meet the needs of its Sandpoint area customers.
Granting AT&T's request will allow the Company to maintain an adequate supply of numbering
resources for assignment to its new customers. The Commission also finds that it is reasonable
to direct that Neustar provide AT&T with the requested numbering resources to meet current
demand from its Sandpoint customers. Finally, the Commission reminds AT&T that unused
000 blocks shall be returned to the NANP A within six months.
ORDER
IT IS HEREBY ORDERED that AT&T Mobility s Petition for waiver of the FCC's
numbering resource optimization requirements is approved.
IT IS FURTHER ORDERED that Neustar assign a 1 000 block of numbers to AT&T
so that AT&T may assign them to its new customers in the Sandpoint rate center.
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration with twenty-one (21) days of the service date of this Order. Within seven (7)
days after any person has petitioned for reconsideration, any other person may cross-petition for
reconsideration. See Idaho Code ~ 61-626.
ORDER NO. 30351
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this ;J::r+~
day of June 2007.
MARSHA H. SMITH, COMMISSIONER
MACK A. REDFORD, COMMI
ATTEST:
~&JJe D. Jewell
Commission Secretary
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ORDER NO. 30351