20091030Decision Memo.pdf

DECISION MEMORANDUM
TO:CO MMISSI 0 NER KEMPTON
COMMISSIONER SMITH
CO MMISSI 0 NER RED FO RD
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:CAROLEE HALL
DATE:OCTOBER 28, 2009
RE:PROJECT MUTUAL TELEPHONE'S PETITION FOR WAIVER OF
FCC THRESHOLD REQUIREMENTS FOR NUMBERING RESOURCES
IN IDAHO'S TWIN FALLS RATE CENTER; CASE NO. PRJ- T -09-01.
BACKGROUND
On October 21 2009, Project Mutual filed a formal request for a waiver of numbering
resource guidelines following denial of its Application filed with Neustar, the North American
Numbering Plan Administrator (NANPA). According to its Application, Project Mutual'
customer requires 10 sequential blocks (i., ten blocks of 1000 numbers) of numbers so as to
ensure all phases will have the same prefix and be sequential and fit into the customer s dial-
plan. Project Mutual's customer needs these numbers as soon as possible, and will begin using
them as soon as the Request for Waiver is granted and the numbers are released for service.
Once the new numbers are put into service , the customer plans to return 2 200 of its existing
numbers.
On September 15 , 2009, Project Mutual submitted an automated worksheet to Neustar via
its online system to obtain numbering resources necessary to meet the demand of its customer in
Twin Falls, Idaho. Project Mutual's Application was denied due to the "months to exhaust"
(MTE) and/or Utilization requirements not adequately met. To be assigned a full code to meet
the customer s request, Project Mutual was instructed to request a State Waiver.
DECISION MEMORANDUM OCTOBER 28, 2009
ST AFF ANALYSIS
Staff has reviewed the request for waiver of the requirements and notes that the customer
is a single entity that asserts it needs these numbers as a result of an expansion in its business.
These numbers will be held solely by this requesting customer and will enable it to meet its
demand for sequential numbers in Twin Falls.
Project Mutual participates in the thousand-block-pooling in the Twin Falls rate center.
Methods such as pooling and rate center consolidation help make number conservation efforts
more effective, and are designed to extend the time it takes to exhaust a rate center s number
resources. After evaluating Project Mutual's request for its customer, Staff believes that granting
this requested waiver will result in an efficient use of Idaho s numbering resources. According
to FCC orders and numbering guidelines, carriers may appeal NANPA decisions of this nature to
the appropriate state regulatory authority. The Commission has granted similar waivers in the
past to meet the requests of larger customers. (See Order Nos. 28769, 29279, 30351 and 30427).
RECOMMENDATION
Staff recommends that the request for authority to provide 10 000 numbers, a full NXX
be granted to Project Mutual for its customer s request with the caveat that the customer return
200 numbers as stated in its Application and that all numbers be used sequentially. In addition
any thousand blocks that are not used within six months of issuance of the NXX shall be
returned to the N ANP A.
COMMISSION DECISION
Does the Commission agree with Staffs recommendation?
u/chali/decision memo/numbering/Project Mutual's Safety Valve Request PRJ-O9. 01
DECISION MEMORANDUM OCTOBER 28 , 2009