20100730Decision Memo.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KEMPTON
COMMISSIONER SMITH
COMMISSIONER REDFORD
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:CAROLEE HALL
DATE:JULY 28, 2010
RE:ELECTRIC LIGHTWAVE, LLC dba INTEGRA TELECOM'
(INTEGRA) PETITION FOR WAIVER OF FCC THRESHOLD
REQUIREMENTS FOR NUMBERING RESOURCES IN IDAHO'
BOISE RATE CENTER; CASE NO. ELI-I0-01.
BACKGROUND
On June 23 2010, Electric Lightwave, LLC, dba: Integra Telecom, filed a formal request
for a Commission waiver of numbering resource guidelines following denial of its Application
filed with the North American Numbering Plan Administrator (NANP A). According to its
Application, the Company is seeking a waiver in order to secure a new Local Routing Number
(LRN) I for assignment to the Company s new switch that will serve the Boise rate center. The
Application was denied by NANP A because the current telephone numbers held by the
Company are available and the requirements are not adequately being met. Staff contacted the
Company to verify its remaining resources and investigate exactly what the Company could do
to maximize its remaining resources. Because the Company is opening a new switch in the
Boise rate center it is in need of an LRN and an entire code.
STAFF ANALYSIS
Integra participates in the thousand-block-pooling in the Boise rate center. Methods such
as pooling and rate center consolidation help make number conservation efforts more effective
I Local Routing Number is a 1 a-digit telephone number used in the context of local number portability. It is an
identifier of a particular CLEC's traffic/switch in the central office and is needed for porting numbers.
DECISION MEMORANDUM JULY 28, 2010
and are designed to extend the time it takes to exhaust a rate center s numbering resources. After
evaluating Integra s waiver request, Staff believes that granting this waiver will not have any
detrimental effect on the numbering resources in the Boise rate center. There remains a high
demand for numbering resources within the Boise rate center; therefore, it is unlikely that any
resources will be stranded or unusable in the immediate future.
According to FCC orders and numbering guidelines, carriers may appeal NANP A
decisions ofthis nature to the appropriate state regulatory authority. This Commission has
granted similar waivers in the past to meet the requests of other carriers
RECOMMENDA TION
Because the Company is in need of an LRN for its new switch, Staff recommends that the
request for a waiver be granted.
COMMISSION DECISION
Does the Commission agree with Staffs recommendation?
i:udmemos/ECTRIC LIGHTWAVE, LLC dba INTEGRA TELECOM'S Safety Valve Request ELI- T-I 0-0 I
2 See Order Nos. 28769 29279 30351 30427, 30983 and 31034
DECISION MEMORANDUM JULY 28, 2010