20040326Decision Memo.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
CO MMISSI 0 NER SMITH
COMMISSIONER HANSEN
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
WORKING FILE
FROM:DOUG COOLEY
DATE:MARCH 24, 2004
RE:PETITION OF INLAND TELEPHONE COMPANY FOR SUSPENSION OF
NUMBER PORTABILITY REQUIREMENTS. CASE NO. INL- T -04-
On February 11 , 2004, a Petition was filed by Inland Telephone Company requesting
suspension until December 31 , 2005, of the requirement that it provide number portability from
wireline to wireless carriers. In an Order issued November 10, 2003 , the FCC requires that
incumbent LECs in areas outside the largest 100 metropolitan areas implement number
portability no later than May 24 2004. Section 251 (t)(2) allows local exchange carriers with
fewer than 2% of the nation s subscriber lines to petition a state commission for suspension or
modification of the portability requirements. The Petition states that Inland will need to upgrade
its switch at a cost of approximately $400 000 in order to provide local number portability.
Inland states suspending its number portability obligation will not adversely affect customers
because it has not received a single number porting request and does not anticipate a significant
demand in the foreseeable future.
STAFF ANALYSIS
On February 24 2004, the Commission issued a Notice of Modified Procedure to process
Inland's petition. Written comments were filed by the Commission Staff. In its comments, Staff
generally supports Inland's request for a suspension and believes the Company is making a
reasonable effort to comply with portability obligations by establishing a switch replacement
schedule for its offices in Washington and Idaho. Staff pointed out that Inland has been granted
DECISION MEMORANDUM MARCH 24, 2004
an extension by the Washington Utilities and Transportation Commission and further
recommends that the Company be granted an extension in Idaho until December 31 , 2005.
COMMISSION DECISION
Does the Commission approve Inland's Petition to suspend its wireline-to-wireless
local number portability requirements until December 31 , 2005?
DC:udmemos/inland Inp memo
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DECISION MEMORANDUM MARCH 24, 2004