20130612Petition.pdf

f el€coil?
June 3, 2013
Ms. Jean Jewell
Commission Secretary
ldaho Public Utilities Commission
PO Box 83720
Boise, lD 83702
?r,,\-1 -la-D-'
RE: Safety Valve Request of Potlatch Telephone Company d/b/a TDS Telecom for review of NeuStar
Pooling Administrator Denial of Application for Numbering Resources
Dear Ms. Jewell,
Potlatch Telephone Company d/b/a TDS Telecom submits this request to the ldaho Public Utilities
Commission (Commission) for review and waiver of the NeuStar Pooling Administrator's denial of our
request for additional numbering resources necessary to obtain a LRN for a new switch that will be
installed in Kendrick, lD.
On May 30, 2013 TDS Telecom submitted a Code Request for an additional LRN to the Pooling
Administrator for the assignment of one block of 1000 telephone numbers in the 360 area code. The
Pooling Administrator denied the request because TDS Telecom did not meet the months to exhaust
(MTE) or utilization criteria established by the FCC.
As the Commission is aware, the FCC has adopted a safety valve mechanism to allow carriers that do not
meet utilization criteria in a given rate center to obtain additional numbering resources. TDS Telecom is
installing a new Metaswitch in its Kendrick, lD location and thus requires one unique NPA-NXX assigned
for a LRN to be provisioned to identify the switch or POI in the number portability capable network.
The industry Location Routing Number (LRN)Assignment Practices (ATI5-0300065) document provides
that:
1. A unique LRN will be provisioned to identify each recipient switch or POI in the number portability
capable network.
2. A service provider will establish one (1) LRN per LATA from an assigned NXX for each recipient switch
or POI in the number portability capable network.
From a number conservation perspective, TDS Telecom is requesting to be assigned all 10 blocks within
the new NPA-NXX with the provision that TDS Telecom will protect all 10,000 numbers from permanent
customer assignment. What this will do is prevent the nine unused blocks from being returned to the
Pool and thus would prevent the possibility that another carrier request and be assigned one of the
blocks from the new NPA-NXX. As such, this would help ensure the numbers do not become
permanently stranded in the Kendrick' lD rate center'
oREGoN ctry, r:"r:fir',i22
OFFICE: 503.656.839?
FAX: [phone]
After TDS Telecom has migrated all customers to the new switch and removed our legacy switch from
the network, we will migrate the existing NPA-NXX and LRN to the new switch and will return the entire
new code that is currently being requested. TDS Telecom will return the new code within 12 months of
collapse of the new legacy switch. ln the event the 208 NPA falls into relief planning prior to the return
of the code, the Commission may request TDS Telecom to provide a progress report regarding the
switch migration in Kendrick and request TDS Telecom to try and expedite the migration so the new
NPA-NXX can be returned and repurposed elsewhere in the 208 area code geography.
The Pooling Administrators decision violates the intent and requirement of the FCC and Commission in
allowing carriers access to numbering resources to meet the required stands of portability in the
network and the Pooling Administrators denial of numbering resources interferes with TDS Telecom to
install a new switch in the Kendrick, lD rate center.
We respectfully request approval of this request as filed. lf you have questions or concerns regarding
this information please contact either Gail Long at 503-656-8399 or [e-mail] or myself
at [e-mail] or 608-654-4659. Thank you in advance for your help on this issue.
Sincerely,
/s/Paul Nejedlo
Paul Nejedlo
Sr. Administrator, Number Management
Enclosures:
Cc: Gail Long - TDS Telecom
GENERAL APPLICATION INFORMATION
1.'t Contact lnformation:
Block Applicant:
Company Name: POTLATCH TELEPHONE CO., !NC.
Headquarters Address: 525 Junction Bd
City, State, Zip: Madison. W1.53717
Contact Name: Paul Neiedlo
Contact Address: 525 Junction Rd
City,State,Zip: Madison , Wl .53717
Phone: [phone] FAX: _
Pooling Administrator: "
E-mail: pau![e-mail]
Tracking Number:
Type of
Application:
Contact Name:
Contact Address:
City,State,Zip:
NPA: 208
208-
KENDRICK.ID.
637454
FullNXX: LRN
F New
rr
Changei Disconnect
Dora Wirth
1800 Sutter St.
Concord ,CA,94520
Phone: [phone] FAX: [phone]
E-mail : dora.wirth @ neustar.biz
1.2 General lnformation:
Check one: No LRN needed LRN needed u' X
LATA: 676 ,"arr- Parent Company's OCN 0881
Number of Thousands-Blocks Requested : 1
Switching ldentification(Switch Entity/POl) :' KNDRIDXXGTo
City or Wire Center Name : KENDRICK
Rate Center Sub Zone: KENDRICK
1.3 Dates:
Rate Center: '' KENDRICK
Date of Application:'ii 05/302013 Bequested Block Effective Date:vrrr fingnofi
' By selecting this checkbox, I acknowledge that I am requesting the earliest possible effective
date the Administrator can grant. Please note that this only applies to a reduction in the
Administrator's processing time, however the request will still be processed in the order received.
Request Expedited Treatment? (See Section 8.6) Yes
-No1.4 Type of Service Provider Requesting the Thousands-Block :
a) Type of Service Provider : lncumbent Local Exchange Carrier (!LEC) (LEC, lXC,
CMRS, Other)
b) Primary type of service Blocks to be used for : Wireline
c) Thousands-Block(s)(NXX-X)assignmentPreference(Optional) 208-500
d) Thousands-Block(s) (NXX-X) that are undesirable for this assignment , if any
e) lf requesting a code for LFIN purposes, indicate which block(s) you will be keeping(the
remainder of the blocks will be given to the pool)208-rrr-1 -
1.5 Type of Request:
lnitial block for rate center : Yes _lf Yes , attach evidence of authorization and proof of
capability to provide service within 60 days.
Growth block for rate center : Yes X lf Yes , attach months to exhaust worksheet
' By selecting this checkbox, I acknowledge that I am willing to accept a block in red and
explicitly undersland that the underlying CO code may not yet be activated in the PSTN and loaded
in the NPAC on the block effective date.
Type of change(Mark all that apply)r ,.r r' ocN:lntra-company'" Switching ld' Part 1B
f ocN:lnter-corp"ny'f Effective Date
Change block : Yes
-lf
Yes , list NPA-NXX-X
1.6 Block Return :
a) ls this block Contaminated Yes _ No _
b) lf Yes how many TNs are NOT available for assignment :_
c) Have all new lntra SP ports been completed in the NPAC Yes _ No
d) Has this block been protected from further assignment Yes _ No
Disconnect block : Yes
-lf
Yes , list NPA-NXX-X
Remarks:
I hereby certify that the above information requesting an NXX-X block is true and
accurate to the best of my knowledge and that this application has been prepared in
accordance with the Thousands-Block (NXX-X) Pooling Administration Guidelines(ATIS-
0300066) available on the ATIS web site (http://www.atis.org/inc) or by contacting
[e-mail] as of the date of this application.
ft mtn istrator oslgot2o1 gPaulNeiedlo
Signature of Block Applicant Date
Instructions for filling out each Section of the Part 1A form:
Section 1.1 Contact information requires that Service Providers supply under "Block Applicant"
the company name, company headquarters address, a contact within the company, an address
where the contact person may be reached, in addition to the correct phone, fax, and e-mail
address. The Pooling Administrator section also requires the Service Provider to fill in the Pooling
Administrator s name, address, phone, fax and e-mail.
Section 1.2 Service Providers who need a thousands-block assignment or for an Location
Routing Number (LRN) are required to fill in this section. lf needed for an LRN, a CO Code
Application needs to also be submitted to the PA. The Service Provider should supply the
Numbering Plan Area (NPA); the Local Ao:qess Transport Area (LATA), which is a three-digit
number that can be found in the Telcordia'''' LERG "'' Routing Guide. The Operating Company
Number (OCN) assigned to the service provider and.lhe OCN its parent company. An OCN is a
four-character alphanumeric assigned by Telcordia""' Routing Administration (TRA). ln addition, the
number of thousands-blocks requested should be supplied. The Switch ldentification as well as the
city or wire center name, rate center, rate center sub zone, homing tandem and CLLITM tandem of
the facilities based provider ''. Explanations of these terms may be found in the footnotes.
Section 1.3 The date the Service Provider completes the application should be entered in this
section, as well as the Effective Date of the requested thousands-block.
Sec(on 1.4 Service Providers should indicate their type, e.9., local exchange carrier, competitive
local exchange carrier, interexchange carrier, CMRS. The also indicate the primary type of
business in which the numbering resource is to be used. Service Providers also may indicate their
preference for a particular thousands-block, e.9., 321-9XXX, or indicate any thousands-blocks that
may be undesirable, e.9., 321 -6XXX.
Section 1.5 Service Providers indicate the type of request. lnitial requests are for first applications
for thousands-blocks in a rate center, groMh for additional thousands-blocks in a rate center in
which the applicant already has numbering resources, and provide the required evidence as
ordered by the FCC.
Section 1,6 Service Providers must indicate the updated/current information in regards to
contaminated TNs on the block they are returning to the pool. Blocks with over 107o contamination
(101 TNs or more) shall not be returned to the pool unless they meet criteria outlined in section
9.1.2 of these Guidelines. lf the block being returned is over 10% contaminated the PA shall seek a
new block holder. lf question c and/or d have a response of No, the request for return shall be
denied. The thousands-block applicant certifies veracity of this form by signing their name, and
providing their title and date.
Foot Notes :
' ldentify the type of change(s) in Section 1.5.
" The Pool Administrator is available to assist in completing these forms.
"'A CO Code application will also need to be submitted to the PA.
'' Operating Company Number (OCN) assignments must uniquely identify the applicant. Relative to
CO Code assignments, NECA-assigned Company Codes may be used as OCNs. Companies with
no prior CO Code or Company Code assignments should contact NECA (800 524-1020) to be
assigned a Company Code(s). Since multiple OCNs and/or Company Codes may be associated
with a given company, companies with prior assignments should direct questions regarding
appropriate OCN usage to (TRA) (732-699-6700).
'This is an eleven-character descriptor of the_switch provided by the owning entity for the purpose
of routing calls. This is the 1 1 character CLLI'- code of the switch /POl.
'' Rate Center name must be a tariffed Rate Center.
'" Acknowledgment and indication of disposition of this application will be provided to applicant
within seven calendar days from the date of receipt of this application. An incomplete form may
result in delays in processing this request.
'"'Please ensure that the NPA-NXX of the LRN lo be associated with this block(s) is/will be active
in the network prior to the effective date of the block(s).
TitIE
'' Select il you are the current Block Holder.
'Select if you are nol the current Block Holder
'Telcordia, LERG Routing Guide, and CLLI are trademarks ol Telcordia Technologies, lnc.
Tracking Number: 208-KENDRICK-lD-637454
Full NXX: LRN
l'rli3i'"", l" New r chansel
1.0 GENERAL INFORMATION
1.1 Contacl lnformation:
Code Applicant:
company/Entity porLATcH TELEPHoNE co.. rNC.Name:
Headquarters 525 Junction RdAOOTeSS:
City, State, Zip: Madison .Wl .53717
Contact Name: Paul Nejedlo
Contact Address: 525 Junction Rd
City,State,Zip: Madison.Wl.53717
Phone: [phone] FAX:
Code Administrator:2
Name: David Morgan
Address: 46000 Center Oak PIaza
City,State,Zip: Sterling,VA,20166
Phone: [phone]
1.2 NPA:208 NXX:3 LATA:676 ocN:4 2230
Company's OCN(s) 0881
Switching ldentif ication(Switch Entity/POl) u XNORT OXXGTO
Locality/CityMire Center: KENDRICK
Homing Tandem Operating Co:TOWEST
CORPORATION
1.3 Dates: Date of Application:0513012013
r Detete
E-mail: [e-mail]
FAX:[phone]
Parenl
Bate Center: 6 feruoRlct<
Tandem Homing CLLIs
:SPKNWAOlC9T
Request Etfective Date: e
11t29t2013
r' By selecting this checkbox, I acknowledge that I am requesting the earliest possible effective date the
Administrator can grant. Please note that this only applies to a reduction in the Administrator's processing time,
however the request will still be processed in the order received.
Request Expedited Treatment? Yes _No
1.4 a) Type of company/entity requesting the code:lncumbeni Local Erchanoe Carrier {ILEC}(LEC,
lc, CMRS, orheOb) Types of service: Wireline (e.9., Cellular - Type 2)
c) Code Assignment Preference (Optional)
d) Codes that are undesirable, if any
208-500
e) Type of change(Mark all that apply)
r ocN-lntra-corpuny " r
r ocN-tnter-corp"ry " r
Switching ld f Rate Center f Tandem Homing CLLI
Effective oate f LATA f Extend Reservation
1.5 Type of Request (lnitial, growth, etc.) Grovrrth
lf an initial code. attach(1) evidence of certification and (2) oroof of ability to place code in service within 60 days. lf a
growth code. attach months to exhaust worksheet.
Pooling lndicator: 13 F Yes F No
1.6 NPA Jeopardy Criteria Apply: f Y", F No
1.7 Code request for new service (Explain):
1.8 lt is the code applicant's responsibility to arrange input of Part 2 information into BIRRDS. The 4s-calendar
day nationwide minimum interval cut-over for BIRRDS will not begin until input into BIRRDS has been completed.
Comments:
I hereby certify that the above information requesting an NXX code is true and accurate to the best of my
knowledge and that this application has been prepared in accordance with Central Office Code (NXX)
Assignment Guidelines posted to the ATIS Web Site (http://www.atis.org/atis/clc/inc/incdocs.htm) as of
the d='ate of this application: 14
Paul Neiedlo
Signature of Code Applicant
Sr. 05/3020
Administrator 13
Title Date
1 ldentify type and reason for change(s) in Section 1.4(e).
'A list ol the current Code Administrato(s) who can provide assistance in completing this form is available upon
request from NANPA.
'The NXX field is required for any code request in which there is a change or the NXX is being returned.
a Operating Company Number (OCN) assignments must uniquely identify the applicant. Relative to CO Code
assignments, NECA-assigned Company Codes may be used as OCNs. Companies with no prior CO Code or
Company Code assignments may contact NECA (800-228-8597) to be assigned a Company Code(s). Since multiple
OCNs and/or Company Codes may be associaled with a given company, companies with prior assignment should
direct questions regarding appropriate OCN usage to the Telcordia '* Routing Administration (TRA) on 732-699-
6700.
t This is an eleven-character descriptor of the switch provided by lhe owning entity for the purpose of routing calls.
This is the eleven-character TelcordiarM COMMON LANGUAGE CLLITM Lo-cation ldentification of the applidant's
switch or POl. (Telcordia and CLLI are trademarks and COMMON LANGUAGE is a registered trademarks of
Telcordia Technologies, lnc.)
6 Rate Center name must be a tariffed Rate Center associated with toll billing.
7 Applies to any code applicant connecting to the Public Switched Telephone Network via a tandem owned by a
ditferent carrier.
sThis is qn eleven-character descriptor provided by the owning entity for the purpose of routing calls. This must be
the CLLITM Location ldentification iode-of the switthing entity/Pol, ind is th6 same on Part 2, Form 1, Page 2 ot 2.
'Code applicants should request an effective date that is at least 66 calendar days from the submission of this form.
It should be noted that interconnection arrangements and facilities need to be in place prior to activation of a code.
Such arrangements are outside the scope of these guidelines.
10 Requests for code assignment shall not be made more than six months prior to the requested etfective date.
11 Select if you are the current Code Holder
12 Select if you are lot the current Code Holder
13 The Applicant will indicate "YES" if the NXX being requested will be used for thousands-block number pooling and
will leave this field blank if it is not.
1a An incomplete form may result in delays in processing this request.
(Thousands-Block Number Pooling Growth Block Request)
Tracking Number: 208-KENDRICK-!D-637454
Date:0513012013
Rate Center: KENDRICK
OCN:2230 Company Name:POTLATCH TELEPHONE CO..
!NC.
List all Codes NPA(s)-NXX(s) and Blocks NPA(s)-NXX-X(s):208-289-2. 3. 4. 5. 6. 7. 8
Name of Block Applicant:Paul Neiedlo Signature: Paul Nejedlo
Title:Sr. Administrator Telephone No.: 608-664-4659 FAX No.:
E-mail: [e-mail]
A. Available Numbers:6405
B. Assigned Numbers: 595
C. Total Numbering Resources:7000
D. Quantity of numbers activated in the past 90 days (increments of 1 ,000 or 10,000) and excluded
from the Utilization calculation':0
List
Excluded
Code(s)
or
Block(s):
Month Month Month Month Month Month Month Month Month Month Month
#1 #2 #3 #4 #5 #6 #7 #8 #9 #10 #11
E. Growth
History -
Previous 6
months3
F.
Forecast -
Next 12
monthsa
Mont
h
#12
G. Average Monthly Forecast (Sum of months 1-6 (Part F above)divided by 6):5.0
H. Months
to
Exhaust5
t.
Utilization6
Numbers Available for Assignment to
Customers(A)
Average Monthly Forecast(G)
Block Requested
1
Assigned Numbers(B) - Excluded
Numbers(D)
Total Numbering Resources(C)-Excluded
Numbers(D)
Available Numbers
6405
X 100 = 8.5
Months To Exhaust
1281.00
Explanation:
'A copy of this worksheet is required to be submitted to the Pooling Administrator when requesting
additional numbering resources in a rate center. For auditing purposes, the applicant must retain a copy of
this document.
2Quantity of numbers activated in the past 90 days is based on blocks and/or codes received from the
administrator and shall be reported in increments of 1 ,000 or 10,000 TNs (e. g.: 2 blocks received=2,0OO
and 1 code received =10,000).
'Net change in TNs no longer available for assignment in each previous month, starting with the most
distant month as Month #1, and Month #6 as the current month.
aForecast of TNs needed in each following month, starting with the most recent month as Month #'l .
tTo 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)).
oNewly acquired numbers may be excluded from the Utilization calculation (FCC OO104, section 52.15
(gXs)(ii))
Tracking Number:
Date of Application:
Date of Receipt:
Service Provider Name:
(Telcordia '' LERG ''
Routing Guide ) OCN:
Parent Company OCN:
NPAC SOA SPID:
NPA-NXX or
NPA.NXX.X:
2O8.KENDRICK.ID-
637454
05/30/2013 Effective Date:
05/30/2013 Date of Response; O5l3Ol2O13
POTLATCH TELEPHONE CO., INC.
2230
0881
KNDRIDXXGTO
KENDRICK
KENDRICK
Pooling Administrator Contact lnformation:
Dora Wirth Phone:
Signature of Pooling Administrator
Dora Wirth Fax:
Name (print)
Email: [e-mail]
925-363-7653
925-363-7686
Block Assigned:
Block Reserved :
Block Reservation
Expiration Date:
Block/Code
Modified:
BlockiCode
Disconnected :
Block Contaminated(Yes or No) :
lf Yes,enter the number of TNs contaminated :
Switch ldentification(Switch Entity/POl): 1
Rate Center:
Rate Center Sub Zone:
Form Complete, request denied.
Explanation:
DR-57: You do not meet the MTE and/or Utilization requirements, therefore lhis request
for a new code is denied. You may proceed with requesting a State Waiver from the
appropriate state commission using this Part 3 denial. lf you are in disagreement with
the disposition of this requesl, please refer to the Thousands'Block Number (NXX-X)
Pooling Administration Guidelines for the appeals process.
Request withdrawn.
Explanation:
Assignment activity suspended by the admlnistrator.
Explanation:
Remarks:
t This is an eleven-character descriptor provided by the owning entity for the purpose of
routing calls.This must be the CLLI 'M Location ldentification code of the switching entity/POl
shown on the Part 1A form (Telcordia,LERc ROUTING Guide and CLLI are trademarks of
Telcordia Technologies,lnc.)