20070619Decision memo.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
COMMISSIONER SMITH
COMMISSIONER REDFORD
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:CAROLEE HALL
DATE:JUNE 11,2007
RE:AT &T MOBILITY'S REQUEST FOR WAIVER OF FCC THRESHOLD
REQUIREMENTS FOR NUMBERING RESOURCES IN IDAHO'
SAND POINT RATE CENTER IN CASE NO. ATT-07-01.
BACKGROUND
On May 29, 2007, AT&T Mobility (formerly known as 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 Numbering Plan Administrator
(NANP A). According to its Application, on May 2, 2007 Blue Licenses Holding requested 1000
additional numbers in the Sandpoint Rate Center.
On or about May 2007 AT&T submitted an automated Part 1A and MTE (Months to
Exhaust) worksheet to Neustar to obtain numbering resources necessary to meet the demands of
its customers in the Sandpoint calling region. The reason for the denial was based upon AT&T's
utilization calculation of 67.311 percent, which is below the required 75 percent for Idaho.
STAFF ANALYSIS
During its analysis staff contacted AT&T Mobility regarding a discrepancy in the Public
Administrator s Report of assigned numbers and usage of those numbers. The Company
responded that it currently has two thousand numbers in the Sandpoint Rate Center reserved for
Administrative Global Title Translations, thereby leaving 372 numbers available for customer
assignment. Staff contacted Neustar regarding this matter and was told that it may be reasonable
to reserve two thousand numbers for the type of network architecture that AT&T Mobility is
currently deploying. If the two thousand reserve numbers were to be removed from the percent
in use calculation, then AT&T Mobility would meet the 75% utilization requirement.
AT &T participates in the thousand-block-pooling in the Sandpoint rate center. Methods
such as pooling and rate center consolidation help make number conservation efforts more
effective, and are designed to extend the time it takes to exhaust (MTE) a rate center s number
resources. After evaluating AT&T's responses to Staff s inquiries , staff does not believe that
granting this requested waiver will result in an inefficient use of Idaho s numbering resources at
this time. According to FCC orders and numbering guidelines, carriers may appeal NANP A
decisions of this nature to the appropriate state regulatory authority. The Commission has
granted similar waivers in the past to meet the requests oflarger customers. (See Order Nos.
28769 and 29279).
RECOMMENDATION
Staff recommends that the request for one thousands-block to AT&T Mobility be granted
so that the Company can service the needs of its Sandpoint customers. Staff also recommends
that AT&T Mobility continue to follow FCC numbering guidelines by assigning numbers as
demand requires within the specific assigned prefix area ofIdaho only. Further, Staff
recommends that AT&T be reminded that unused 1 000 blocks will be returned to the NANPA
within six months.
COMMISSION DECISION
Should the request for waiver from AT&T Mobility be granted?
~MZ
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ulchall/decision memo/numbering/AT&T's Sandpoint Safety Valve Request AT&T-O7-