20030627Decision Memo.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
COMMISSIONER SMITH
COMMISSIONER HANSEN
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
WORKING FILE
FROM:DOUG COOLEY
DATE:JUNE 27, 2003
RE:QWEST APPPLICATION FOR A WAIVER TO ACQUIRE A NEW PREFIX
(NXX) IN BOISE; CASE NO. QWE-03-14.
BACKGROUND
On June 18, 2003, Qwest Corporation filed a request for a waiver regarding denial of an
Application Qwest filed with the North American Numbering Plan Administrator (NANP A). In its
earlier Application to NANP A, Qwest requested a central office code (NXX) to meet the growing
requirements of 8t. Alphonsus Regional Medical Center in Boise, Idaho. Qwest made the
Application to NANP A because it does not have an entire discrete prefix available in the Boise rate
center to meet the customer s request.
As required in its Application to NANP A, Qwest completed a Month- To- Exhaust (MTE)
worksheet indicating that Qwest's numbering resources in the Boise rate center would exhaust in
approximately 59 months. On June 12 2003, NANPA denied Qwest's NXX request on the
grounds that Qwest had not met the 6-month MTE criteria as set forth in the NANPA's guidelines
for each rate center.
Qwest asserts in its Application to this Commission that NANP A's denial "interferes with
Qwest's ability to serve its customers within the state of Idaho.
STAFF ANALYSIS
Qwest participates in thousand-block-pooling in the Boise rate center and consolidated
the Boise rate center with the Idaho City rate center in 2002 to further number pooling
effectiveness in this area. While these methods help make number conservation efforts more
DECISION MEMORANDUM JUNE 27, 2003
effective, they are designed to extend the time it takes to exhaust (MTE) a rate center s number
resources. Staff agrees with Qwest that, according to FCC Orders and numbering guidelines,
carriers can appeal NANP A decisions ofthis nature to the appropriate state regulatory authority.
The Commission has granted similar waivers in the past for specific customer requests. (See
Order No. 28769, Ricks College.
Staff has also been wormed that the customer is prepared to pay Qwest to dedicate all
000 numbers associated with a new prefix for Direct Inward Dial (DID) to assure St.
Alphonsus access to numbers within the new prefix as construction of new facilities continues
into next year. By paying Qwest now to active all 10 000 numbers (or all ten 1 000 blocks) for
St. Alphonsus, all 10 000 numbers are considered assigned and would not be subject to
reclamation after six months.
RECOMMENDATION
Staff recommends that Qwest's request for a waiver regarding denial of an Application
Qwest filed with the North American Numbering Plan Administrator (NANP A) be granted
that it may provide a prefix to St. Alphonsus Regional Medical Center. Staff also recommends
that Qwest continue to follow FCC numbering guidelines by assigning numbers in 1 000 blocks
as demand requires before opening new 1 000 blocks within the newly assigned prefix. Further
Staff recommends that Qwest remind its customer that unused 1 000 blocks will be returned to
the NANP A.
COMMISSION DECISION
Should Qwest's request for a waiver to provide a new NXX to St. Alphonsus Regional
Medical Center be approved?
i :dmemo/st al nxx memo
1 Number Optimization Order. CC Docket No. 99-200 and 96-, FCC 00-104, rel. Mar. 31, 2000.
DECISION MEMORANDUM JUNE 27 2003