20040312Comments.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3283
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
IDAHO TELEPHONE ASSOCIATION FOR
SUSPENSION OF NUMBER PORTABILITY
REQ UIREMENTS.
COMMENTS OF THE
COMMISSION STAFF
CASE NO. GNR-O4-
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Weldon B. Stutzman, Deputy Attorney General, in response to Order No.
29428 , the Notice of Petition and Notice of Modified Procedure in Case No. GNR-04-1 issued
on February 20, 2004, and submits the following comments.
On February 5 2004, a Petition was filed by the Idaho Telephone Association (ITA) on
behalf of 16 of its members requesting a 6-month suspension of the requirement that they provide
number portability from wireline to wireless carriers. The Petition states that the member
companies are pursuing an economical and technically feasible way to provide local number
portability (LNP), but that a system upgrade is required. Specifically, the companies propose to
provide number portability through shared equipment and services provided by Syringa Networks
LLC, requiring that Syringa convert its switch to a tandem switch. The Petition states that the
conversion is already underway but that it cannot be completed prior to the May 24, 2004
deadline.
STAFF COMMENTS MARCH 12, 2004
STAFF ANALYSIS
As mentioned in the ITA petition, Section 251(f)(2) of the Telecommunications Act of
1996 provides small carriers the opportunity to petition a state commission for suspension of local
number portability requirements. According to their Application, it is technically infeasible for
the IT A member companies to provide LNP without significant system changes and their proposal
to provide it through Syringa Networks is an attempt to mitigate the significant costs of the
necessary changes. Staff believes that the ITA companies are making reasonable efforts to
comply with the LNP requirements by exploring a technically feasible and cost effective solution
and Staff generally supports the ITA's request for an extension until November 24 2004.
Because the plan to have Syringa Networks provide LNP to the ITA members is unique, it
is important to ensure that this solution is technically equivalent and that it will be transparent to
customers. For example, Staff would want to know that Syringa s solution would not require 10-
digit dialing to ported numbers, that inappropriate toll charges would not be incurred to ported
numbers, that default routing would occur appropriately, and that any other technical performance
would be the same as if each of the ITA member companies provided the LNP. Also, Staff would
expect that approval of the extension gives the ITA adequate time to work out any technical
requirements with Syringa or, alternatively, provide LNP as individual companies so that no
suspension ofLNP obligations should be expected beyond November 24 2004.
Staff recommends the IT A submit a written update to the Commission no later than
August 24, 2004, regarding the progress made to implement LNP capability for its member
companies. Staff will also be in contact with the North American Number Plan Administration
(NeuStar) seeking its confirmation that Syringa s plan to provide LNP for the IT A companies will
work appropriately.
STAFF RECOMMENDATION
Staff recommends that the Idaho Telephone Association s petition for temporary
suspension of local number portability obligations be granted until November 24, 2004. Staff
further recommends that the IT A provide a written update to the Commission by August 24, 2004
regarding the technical feasibility of Syringa Networks providing local number portability
effectively for the ITA member companies.
STAFF COMMENTS MARCH 12, 2004
Respectively submitted this
Technical Staff: Doug Cooley
i:umisclcomments/gnrtO4.1 wsdc
STAFF COMMENTS
/2 day of March 2004.
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Weldon B. utzman
Deputy Attorney General
MARCH 12, 2004
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 12TH DAY OF MARCH 2004
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. GNR-04-, BY MAILING A COpy THEREOF, POSTAGE PREPAID
TO THE FOLLOWING:
CONLEY E WARD
GNENS PURSLEY LLP
PO BOX 2720
BOISE ID 83701-2720
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SECRET AR
CERTIFICATE OF SERVICE