20220906Decision Memo.pdf

DECISION MEMORANDUM
TO COMMIS S IONER AI\DERS ON
COMMISSIONER CIIATBURN
COMMISSIONER HAMMOND
COMMISSION SECRETARY
LEGAL
WORI(NG FILE
FROM:JOHAN E. KALALA.KASANDA
MICHAEL DUVAL
DATE: SEPTEMBER6,2022
RE:FARMERS MUTUAL TELECOM, Inc FILED A PETITION FOR A
SAFETY VALVE WAIVER OF FCC THRESHOLD REQUIREMENTS
FOR NUMBERING RESOURCES IN FRUITLAND PAYETTE IDAIIO
RATE CENTERS; CASE NO. FMU-T-22-02.
BACKGROTJND
On August 22,2022, Famers Mutual Telecom, Inc. ("Farmers" or "the Company")
contacted the Idaho Public Commission ("Commission") Staff requesting that the Commission
enter an order waiving the Federal Communications Commission's ("FCC") Threshold
Numbering Resource Requirements for the Fruitland and Payette Idaho rate centers.
On August 23,2022, Staff contacted the Company regarding its petition and instructed
the company on how to formally refile. On August 25,2022, the Company formally resubmitted
its petition to the Commission, with the proper documentation.
In the Petition, the Company asserted that it is replacing its existing Metaswitch VP35l0
equipment/facilities in its Fruitland and Payette, Idaho exchanges. Because of this change, a new
Number Plan Area ('NPA-NXX") and Location Routing Number ("LRN'')I are required to
establish homing arrangements for Local Exchange Routing Guide 7 Switching Homing
Arrangement information ("LERGTSHA') so the Company can order and install new trunking2.
I The NPA, or Numbering Plan Area, is commonly called the area code. The NXX refers to the three digits of a
phone number immediately following the area code and is also called the "exchange" or Central Switching Office
Designation. The LRN, or Location Routing Number, is a unique l0-digit number used to identifo a switch that
holds ported or pooled numbers. Calls to ported or pooled numbers are routed based on the NPA-NXX of the
numbers associated with the LRN.
2 The LERG provides routing data obtained from the iconectiv Business Integrated Routing and Rating Database
System ("BIRRDS") into which data is entered by service providers ("SPs") and/or their agents.
1DECTSION MEMORANDUM SEPTEMBER 6,2022
Petition at l.The Company stated once the new switch is operational, its existing customers will
be ported to it from the old switch. Id. Any unneeded 1,000 blocks will be returned to the North
American Numb ering Plan Administrator ("NANPA" ). 1d
On August 22,2022, the Company applied through the Pooling Administration System
("PAS") of the NANPA for an LRN for the new Fruitland and Payette, Idaho switch within its
Local Access Transport Area ("LATA"). NANPA's administrator, Somos, Inc., denied the
Company's application because the Company did not meet the months-to-exhaust and/or
utilization requirements in the Thousands-Block Number Pooling Administration Guidelines3
(the "Guidelines"). See Petition, Attachment A.
STAFF ANALYSIS
Federal regulations allow a carrier to appeal a NANPA decision to withhold numbering
resources. See 47 C.F.R. $ 52.1s(g)(axiv) and (5). 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" requirements. See 47 C.F.R. $
52.15(gg)(iv) and (5). The Commission "also may overturn the NANPA's decision to withhold
numbering resources from the carrier based on its determination that the carrier has demonstrated
a verifiable need for numbering resources and has exhausted all other available remedies." 47
C.F.R. $ 52.15(gX5). Lastly, the Company is a Title 6l regulated telephone corporation
organized under the laws of the state of Idaho and is authorized to do business in Idaho and to
provide basic and local exchange telecommunications services pursuant to a Certificate of Public
Convenience and Necessity No.305 that was issued to it by the Commission.
After evaluating the Company's Petition, Staff believes that granting this waiver will not
have any detrimental effect on the numbering resources in the Fruitland and Payette rate centers.
Because of the Company's business need to replace the existing Metaswitch equipment/facilities,
it is reasonable for the Company to upgrade its facilities for the consumers of the Fruitland and
Payette rate centers. Staff believes that the new switch is going to improve the performance of
the two exchanges and will increase the need for additional numbers.
3 To be assigned an additional thousands-block (NXX-X) for growth, "Months to Exhaust" must be less than or
equal to 6 months. (FCC 00-104, Section 52.15(g)(3)(iii))
DECISION MEMORANDUM 1 SEPTEMBER 6,2022
According to FCC orders and numbering guidelines, carriers may appeal NANPA
decisions of this nature to the appropriate state regulatory authority. This Commission has
granted similar waivers in the past to meet similar requests of other carriers. (See Commission
Orders Nos. 33976, 34108, 34238, 34364, 34501).
RECOMMENDATION
Staff recommends that the waiver request for the full NXX-LRN be granted with the
caveat that any unused numbers be retumed to the pooling administrator.
COMMISSION DECISION
Does the Commission wish to approve this Petition?
E.
UdmemosffMT :l -22-02 Decision Memo
DECISION MEMORANDUM -3-SEPTEMBER6,2022