20011114Motion to File Late Supplemental Comments.doc

LISA D. NORDSTROM
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
Idaho State Bar No. 5733

Street Address for Express Mail

472 W. Washington Street
Boise, Idaho 83702-5838

Attorney for Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE PETITION OF THE NORTH AMERICAN NUMBERING PLAN ADMINISTRATOR FOR THE APPROVAL OF NUMBERING PLAN AREA RELIEF FOR THE 208 AREA CODE. )
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MOTION TO FILE
LATE SUPPLEMENTAL COMMENTS

COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its Attorney of Record, Lisa D. Nordstrom, Deputy Attorney General, and submits the following information to supplement its comments previously filed on September 13 and November 13, 2001. On September 26, 2001, the Commission issued a Notice of Public Workshops and Hearings and Extended Comment Deadline. The Commission’s Notice requested that written comments be filed no later than November 13, 2001. Pursuant to Rule 56 of the Commission’s Rules of Procedure, the Commission Staff moves to submit these late-filed comments for the following reasons:
1. These Comments consist of the Federal Communications Commission’s (FCC) Telephone Numbering Resource Utilization Report and Press Release, which were released on November 13, 2001 – the same day as the Commission’s comment deadline. This FCC Report explains how effectively telephone numbers are being used by carriers nationally and allows comparison to the Idaho utilization rates described in Staff Comments submitted on November 13, 2001.

2. No party will be prejudiced by the submission of this information as it is not argumentative and merely provides background data that may assist the Commission in its decision.

Respectfully submitted this 14th day of November 2001.

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Lisa D. Nordstrom
Deputy Attorney General

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MOTION TO FILE
LATE SUPPLEMENTAL COMMENTS 1