20030619Application.pdf

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101 S, Capitol Boulevard, Suite 1900
Boise, Idaho 83702
main 208.389,9000
fax 208.389,9040
ATTORNEYS AT lAW
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June 18, 2003
MARY S, HOBSON
Direct [phone]
msbobson0stoel.com
VIA HAND DELIVERY
Jean D. Jewell
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83720-0074
CaseNo.Otuf- f(j &.,-/1WAIVER REQUEST FOR NEW IDAHO NXX (PREFIX) IN BOISE, IDAHO FOR
SAINT ALPHONSUS REGIONAL MEDICAL CENTER
Re:
Dear Ms. Jewell:
Enclosed for filing with this Commission is an original and eight copies of Qwest Corporation s Request
for Waiver ofthe Neustar s Denial of Application for New Central Office Code in Area Code 208. Qwest
requests the Idaho Public Utilities Commission direct the Neustar to release a new NXX (prefix) to meet
requirements of Saint Alphonsus Regional Medical Center in Boise, Idaho. FCC rules denied Qwest'
application for the new NXX despite Qwest's inability to provide the requested NXX in the central office
serving the hospital. The customer requests the new prefix be available as soon as practicable to
accommodate new construction activity at the hospital.
Qwest's Request for Waiver describes the FCC rules, the Qwest application for the new NXX with
Neustar and Neustar s denial of the Qwest application. A summary statement regarding the application is
attached to this letter. Commission Staff manager, Doug Cooley, was previously notified that this request
for waiver was being prepared. It is Qwest's hope that the Staff and Commission review ofthis request
can be accomplished without delay and a decision can be reached at an upcoming Commission decision
meeting.
Thank you for your cooperation in this matter.
Very truly yours
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Mary S. Ifubson
MSH:blg
Enclosure
Oregon
Washington
California
Boise-!58439.! 0029164-00012
Utah
Idaho
JUN 13 2003 11: 51 FR QWEST TECH REGULATORY3037079577 TO 912083858081
Friday, June 13 , 2003
Idaho - Boise (BOISIDMADS3)
Request for Waiver for Additional Numbering Resources
BACKGROUND:
.:. According to FCC requirements, to qualify for additional numbering resources carriers must submit
paperwork demonstrating the rate center for which the numbers are requested is at six months or less to
exhaust and is at 65%or more utilization, increasing to 70% on June 30, 2003 (FCC 01-362, Section
, C, paras. 57-66).
.:. In cases where a service provider is not able to meet a specific customer request with available
inventory, the FCC has determined that the state commissions will have jurisdiction.
SITUA TION:
.:. Qwest received a request from Saint Alphonsus Regional Medical Center for 10,000 DIDs. That
equates to 10,000 numbers out of the BOISIDMADS3 switch in the Boise rate center. The request is
for a whole NXX.
.:. Qwest first examined the BOISIDMADS3 switch to confirm we did not have the numbers meeting the
customer s criteria.
.:. Next, Qwest examined the remaining Qwest switch in the Boise rate center and confirmed that we do
not have numbers meeting the customer s criteria.
.:. On June 12,2003, Qwest submitted a Dedicated NXX request and MTE (Months to Exhaust)
Worksheet to Neustar via their online system (PAS) requesting block(s) to satisfy the customer. The
request was immediately denied.
.:. The Boise rate center is at 59 MTE and at 78% utilization. Due to the MTE, Qwest does not qualify
for an additional numbers at this time.
ACTION REQUIRED:
.:. Contact the Idaho Public Utilities Commission Staff to determine the best approach to obtain the
NXX for the customer. Try to get the Commission to go along with an informal process where Qwest
provides the request along with data for review by the Commission staff. If the staff approves, a letter
or email is sent to the Pooling Administrator and Qwest granting the waiver. In the interest of time, try
to avoid any formal process where a docket is opened, comments are filed, etc..
.:. Prepare and file a request for waiver.
SPECIFICS:
NPA: 208
Switch: BOISIDMADS3
Rate Center: Boise
Application Date for Numbers: 06/l2/03
Months to Exhaust (MTE) for the rate center: S9 months
Utilization for the rate center: 78%
Customer: Saint Alphonsus Regional Medical Center(letter attached)
Requested Effective Date for the NXX: ASAP (FCC recommends the State respond within 10 days -
FCC 01-362, Section IV, C paragraph 66). Once the waiver is obtained Qwest will re-apply for the
block(s) from NANPNNEUsTAR.
Please find attached
Code Request
Months to Exhaust (MTE) Certification
Worksheet
Automated Denial from NeuStar
Customer letter
A vailable Upon Request
Section ofthe order FCC 01-362 describing
waivers (safety valve).
Colorado Example of a waiver request and
actual waiver.
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Mary S. Hobson (ISB# 2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ID 83702-5958
Telephone: [phone]
Facsimile: [phone]
mshobson~stoe1.com
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Adam Sherr
Qwest
1600 7th Avenue - Room 3206
Seattle, WA 98191
Telephone: [phone]
Facsimile: [phone]
asherr~qwest.com
Attorneys for Qwest Corporation
IN THE MATTER OF THE PETITION OF
QWEST CORPORA nON'S REQUEST FOR
WAIVER OF THE NEUSTAR'S DENIAL OF
APPLICATION FOR NEW MAIN OFFICE
CODE IN AREA CODE 208 FOR SAINT
ALPHONSUS IN BOISE, IDAHO
BEFORE THE IDAHO PUBLIC UTLITIES COMMISSION
CASE NO. (Yq;Jt-
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QWEST CORPORATION'S REQUEST
FOR WAIVER
Qwest Corporation ("Qwest"), by and through its attorneys of record, and
pursuant to IDAPA 31.01.01.256, files the following Request for Waiver.Qwest
petitions the Commission for review of the denial of Qwest's application for use of
central office code numbering resources in area code 208 by the administrator of the
North American Numbering Plan, Neustar.
This waiver filing is made in conformity with the Federal Communications
Commission s ("FCC") procedures for challenging determinations ofNeustar, as outlined
in In the Matter of Numbering Resource Optimization, Petition for Declaratory Ruling
and Request For Expedited Action on the July , 1997 Order of the Pennsylvania Public
QWEST CORPORATION'S REQUEST FOR WAIVER -
Boise-158440.10029164-00012
Utility Commission Regarding Area Codes 412 610 215, and 717, CC Docket Nos. 99-
200 and 96-FCC 00-104, reI. Mar. 31 , 2000 Number Optimization Order
Appendix A, Final Rules, ~ 53.15 (g) (3) (iv) ("The carrier may challenge Neustar
decision to the appropriate state regulatory authority ), as well as the Industry Central
Office Code (NXX) Assignment Guidelines, ~ 13.0 ("Appeals may include but are not
limited to one or more of the following options: . . . C. The CO Code Administrator(s)
and code holders/applicants may pursue the disagreement with the appropriate
governmental/regulatory body
In support of this petition Qwest states:
Qwest is a telephone corporation regulated by the Idaho Public Utilities
Commission ("Commission ) providing intraLA T A, local exchange telecommunications
services in the Boise Rate Center.
The goal of the FCC'Number Optimization Order was to implement
uniform standards governing requests for telephone numbering resources in order to
increase efficiency in the use of existing telephone numbers and to avoid further
exhaustion of area codes under the North American Numbering Plan ("NANP"
Among other things, the Number Optimization Order adopted a revised
standard for assessing a carrier s need for numbering resources by requiring rate-center
based utilization rates to be reported to Neustar. The FCC further required that before
applicants could qualify for access to new numbering resources, applicants had to
demonstrate that the existing numbering inventory within the applicant's rate center will
be exhausted within six months of the application. Prior to this ruling, the Central Office
Code Assignment Guidelines, used by the industry and Neustar to make code
QWEST CORPORA nON'S REQUEST FOR WAIVER - 2
Boise-158440.!0029164-00012
assignments, required the applicant's existing number inventory within the applicant'
serving switch to exhaust within six months of the code application in order for a code to
be assigned.
The FCC's shift to a "rate center" basis for detennining the need for new
numbering resources was intended to "more accurately reflect how numbering resources
are assigned" and to allow "carriers to obtain numbering resources in response to specific
customer demands.(Number Resource Optimization Order , 105)
On or about June 12 , 2003, Qwest submitted an automated Central Office
Code (NXX) Assignment Request to Neustar via its online system (PAS) to obtain NXX
resources necessary to meet the demands of Saint Alphonsus Regional Medical Center
served by Qwest in Boise, Idaho. That application is attached hereto as Attachment A.
The reservation request made on behalf of the regional medical center was
for a full NXX for use as a code for its Dedicated Direct Inward Dial service, which it
purchases from Qwest.
Due to this specific customer request, Qwest submitted a request to obtain
a central office (NXX) code in the Idaho 208 area code because Qwest did not have
inventory within its supply of 208 area code numbers available through the Boise Main
(BOISIDMADS3) central office to provide the full NXX code requested by the customer.
Qwest completed the application in accordance with the industry's Central
Office Code (NXX) Assignment Guidelines and filled out the necessary "Months-to-
Exhaust Certification Worksheet" required by Neustar.
QWEST CORPORATION'S REQUEST FOR WAIVER - 3
Boise-158440.10029164-00012
Using the Boise rate center for the months-to-exhaust calculation as
required under the Number Optimization Order Qwest's rate center numbering resources
are calculated to exhaust in 59 months.
10.Despite the fact that Qwest's inventory of available number resources for
the Boise rate center may not exhaust for 59 months, Qwest is unable to provide the
regional medical center s requested numbers through the switch that serves the customer
in the Boise rate center. This is because the individual switch (BOISIDMADS3) does not
have a full vacant NXX to meet this custom~r s request.
11.On June 12, 2003 , the automated Pooling Administration System (PAS)
denied Qwest's NXX request on the grounds that Qwest had not met the rate center based
months-to-exhaust criteria now set forth in the Central Office Code (NXX) Assignment
Guidelines, notwithstanding the fact that Qwest does not have the numbering resources
needed to satisfy its customer s demands in the switch at issue. This decision is attached
hereto as page 5 of Attachment A.
12.Further, Qwest's inability to provide this customer with the full NXX it
requires for its Direct in Dial.("DID") service prevents Qwest from providing the quality
of service this "Customer desires and expects.
13.Qwest's requested numbering resources would not materially impact the
exhaust date of available numbers in the 208 area code.
14.Both the FCC'Number Optimization Order and Neustar s Central Office
Code (NXX) Assignment Guidelines provide that state regulatory authorities have the
power and authority to review Neustar s decision to deny a request for numbering
resources, as identified above in the opening paragraphs.
QWEST CORPORATION'S REQUEST FOR WAIVER - 4
Boise-158440.10029164-00012
15.Under prior months-to-exhaust procedures used by Neustar, waivers or
exceptions were granted where customer hardships could be demonstrated or where the
service provider s inventory did not have a full vacant code to meet the customer
request. Under existing procedures, Neustar looks at the number of months-to-exhaust
for the entire rate center without consideration of any exceptions.
16.Qwest seeks the Commission s review of Neustar s decision to withhold
numbering resources from Qwest on the grounds that the decision runs contrary to the
intent of the FCC to allow carriers access to numbering resources to meet specific
customer demands upon a sufficient showing of need. Further, Neustar s denial of
numbering resources to Qwest interferes with Qwest's ability to serve its customers
within the state of Idaho.
17.In support of this request for waiver, Saint Alphonsus Regional Medical
Center has prepared a letter to Qwest, attached as Attachment B, which details the need
for the new prefix.
WHEREFORE Qwest respectfully requests that:
The Commission review the decision of Neustar to deny Qwest's request
for additional numbering resources to serve Saint Alphonsus Regional Medical Center
with an established need for numbers.
The Commission direct Neustar to provide a new NXX to meet the
specific requirements of Saint Alphonsus Regional Medical Center in Boise, Idaho.
The Commission find this issue does not require industry review, is not
contentious, and does not justify opening contested docket prior to decision.
QWEST CORPORA nON'S REQUEST FOR WAIVER - 5
Boise-l 58440.1 0029164-00012
The Commission determine at its next available decision meeting to
expeditiously request a waiver ofNeustar s denial of a new NXX in Boise under Qwest'
original Central Office Code Assignment Request dated June 12 2003.
RESPECTFULLY SUBMITTED this 18th day of June, 2003.
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Mary S obson
Stoel Rives LLP
Attorneys for Qwest Corporation
QWEST CORPORATION'S REQUEST FOR WAIVER - 6
Boise-158440.10029164-00012
JUN 13 2003 11: 51 FR QWEST TECH REGULATORY3037079577 TO 912083858081
Resource Request Information Page 1 of 2
Pooling Administration System
.jgbarlo~qwest.com (SP)Sign Oul
Request Resources
State
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NOTE:
If you are selecting a Rate Center that is moving to a new NPA due to a split, PAS will automatically migrate the
request to the new NPA once the mandatory dialing date occurs.
ATTACHMENT A
to Qwest's Request for Waiver
Page 1 of 5
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JUN 13 2003 11: 51 FR QWEST TECH REGULATORY3037079577 TO 912083858081
Block Reque,st Successful!Page 1 of 2
Pooling Administration System
.jgbarlo~qwest.com (SP)Sign Out
Request Full NXX (Dedicated Customer)
Do you already have a block/code in this rate center? (i) Yes 0
Will all blocks be activated on the same switch? € Yes 0 No
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ATTACHMENT A
to Qwest's Request for Waiver
Page 2 .of 5
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JUN 13 2003 11: 51 FR QWEST TECH REGULATORY3037079577 TO 912083858081
MTE.Page 1 of 2
1tjgbarlo~qwest.com (SP)
Pooling Administration System
Sign Out
Months to Exhaust and Utilization Certification Worksheet - TN Level
Date Thursday, June 12, 2003
OCN 9636
Company Name QWEST CORPORATION
Rate Center BOISE
List all Codes NPA(s)-NXXs and Blocks NPA(s)-NXX.
(s)
208-321 , 208-322 , 208-323-0, 208-323-1, 208-323-2, 208-323-3, 208-323-4, 208- 323-208-323-208-323-208-323-8, 208-323-9, 208-327 , 208-331, 208-332,208-333, 208-334, 208-336, 208-338, 208-341 , 208-342 , 208-343, 208-344, 208- 345,208-348,208-362,208-363,208-364 208-367, 208-368, 208-373, 208-375, 208-376 208-377,208-378,208-381,208-383, 208-384,208-385,208-386,208- 387 , 208-388, 208-389 , 208-392-4, 208-392-6, 208-392-9, 208-393, 208-395, 208-
396, 208-422 , 208-424, 208-426, 208-429, 208-433, 208-562-0, 208-562-1, 208- j562-5, 208-562-6, 208-562-8, 208-658-0, 208-658-1, 208-658-2, 208-658-3, 208- r658-4, 208-658-5, 208-658-6, 208-658-7, 208-658-8, 208-658-9, 208-672, 208- ~;685-0, 208-685-1, 208-685-, 208-685-3, 208-685-4, 208-685-5, 208-685-6, 208- II. "'. n,
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Name of Block Applicant Mr Jacob Barlow
Title Code Administrator
Telephone Number [phone]
Fax Number [phone]
Mail Jgbarlo~qwest.com
A. Available Numbers * Iz.~?.~_
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B. Assigned Numbers *
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C. Total Numbering Resources *
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D. Quantity of numbers activated in the past 90 days
and excluded from the Utilization calculation *
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List excluded Code(s) or Block(s)
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E. Growth History - Previous 6 months2 .
Month 1 I~-Month 2 171 9
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Month 3
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Month 5 t681 Month 6 l~~.....,.
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F. Forecast. Next 12 months3 .
Month 1 19610 -..J Month 2 1-391
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Month 3 I~!...Month 4 j-391
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Month 6 :?91
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JUN 13 2003 11: 52 FR QWEST TECH REGULATORY3037079577 TO 912083858081
MTE Page 2 of
Month 7
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Month 9
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G. Avefage Monthly Forecast (Sum of months # 1-6 (Part F above) divided by 6)1275.833
H. Months to Exhaust 4 (Numbers Available for Assignment to customers (A) I Average Monthly Forecast (G))
Block Requested A. Available Numbers
75781
H. Months to Exhaust
59.397
I. Utilization (Assigned Numbers (8)) 1 (Total Numbering Resources (C) . Excluded Numbers (0)) .
100 78.949
Explanation
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1. 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.
2. 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.3. Forecast of TNs needed in each following month, starting with the most recent month as Month #1.
4. To 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, S 52.15 (g)(3)(iii)).
5. Newly acquired numbers may be excluded from the Utilization calculation (FCC 00104, section 52.15 (g)(3)(ii))
ATTACHMENT A
to Qwest's Request for Waiver
Page 4 of 5
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JUN 13 2003 11: 52 FR QWEST TECH REGULATORY3037079577 TO 912083858081
MTE Page 1 of 2
Pooling Administration System
4-jgbarloi/!)qwest.com (SP)
Months to Exhaust and Utilization Certification Worksheet - TN Level (Continued)
Sign Out
Based on the information provided, you will not exhaust all blocks in the requested NXX in 6 months.
Select One Option and Submit
€c Return to the Months To Exhaust Form
Discard all the information provided for the request and start with a fresh Part 1A
State Waiver Option
ATTACHMENT A
to Qwest's Request for Waiver
Page 5 of 5
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TELECOMMUN I CAT IONS
Saint Alphonsus
Regional Medical Center
Date: June 3, 2003To: DarIa Larson. Qwest
From: Elaine Schnebly, Saint AlphonsusRe: New Pre~x Request
DarIa,
Saint Alphonsus is on the verge of outgrowing the 367 prefix and is requesting a new prefix from
Qwest for the reasons listed below.
New prefix should start at XXX - 0001 to XXX . 9999.
We currently have !h~ /"lumber range 367-2000 through 367-8999 sans 5900
to 5939 and have about 800 numbers left. We are beginning a new
construction sHe within the next year which will be the same footprint,
if not larger, as the main hospital and I am anticipating that \"i111
consume at least 1000 numbers if not more. In addi!ion to the new
building we are always adding new off site physician offices and clinics
which we tie to our switch via T1'5 and use our DID numbers for 4 digits
dialing.
This is difficuftbecause 1his changes monthly, but at this point
We have the new infill tower which will be 1000'" nu mbers, and I believe
we also have (! new medical building scheduled which is generally 200
numbers. Anticipated growth is extremely hard to predict.
Thank you (or your consideration in this matter.-t~
Elaine Schnebly
Voice Ne!Work Engineering
Saint Alpnonsus Regional Medical Center
ATTACHMENTB
to Qwest's Re uest li alver
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