20050415Decision memo.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
COMMISSIONER SMITH
COMMISSIONER HANSEN
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:CAROLEE HALL
DATE:APRIL 14, 2005
RE:QWEST'S APPLICATION FOR WAIVER TO ACQUIRE NEW
NUMBERING RESOURCES IN IDAHO FALLS, IDAHO.
CASE NO. QWE-05-07.
BACKGROUND
On March 14 2005, the Commission received a request for a waiver from Qwest
Corporation following denial of their Application filed with Neustar, the North American
Numbering Plan Administrator (NANP A). According to its Application, on February 14, 2005
Qwest requested 3000 additional numbers in the IDFLIDMADSI switch in the Idaho Falls rate
center where the Company confirmed that it did not have numbers meeting its customer
cri teria.
On or about March 8 , 2005 , Qwest submitted an automated Part lA and MTE (Months to
Exhaust) Worksheet to N eustar via its online system (PAS) to obtain numbering resources
necessary to meet the demands of its customer in Idaho Falls, Idaho. Qwest's Application was
denied because it did not meet the months-to-exhaust criteria of 6 month as set forth in the
NANPA's guidelines for each rate center. Qwest's pooling numbering resources, in this
particular rate center, may exhaust in approximately 108 months. Therefore, there are more than
enough numbers available for this request. The reason for the denial was based upon Qwest'
utilization calculation of73.561 percent, which is slightly below the required 75 percent for
Idaho.
Qwest asserts that NANP A's denial impedes its ability to serve its customers within the
state of Idaho
DECISION MEMORANDUM - 1 -APRIL 14, 2005
STAFF ANALYSIS
Qwest participates in the thousand-block-pooling in the Idaho Falls rate center. While
methods such as pooling and rate center consolidation help make number conservation efforts
more effective, they are designed to extend the time it takes to exhaust (MTE) a rate center
number resources. Further, Staff does not believe granting the requested waiver will result in an
inefficient use of Idaho s numbering resources. According to FCC orders and numbering
guidelines, carriers can appeal NANP A decisions of this nature to the appropriate state
regulatoryauthority.l The Commission has granted similar waivers in the past to meet the
requests of larger customers. (See Order Nos. 28769 and 29279.
RECOMMENDATION
Staff recommends that the request for waiver sought by Qwest Corporation be granted so
that the Company can service the specific needs of its Idaho Falls customer. Staff also
recommends that Qwest continue to follow FCC numbering guidelines by assigning numbers in
000 blocks as demand requires before opening new 1 000 blocks within an assigned prefix.
Further, Staff recommends that Qwest remind its customer that unused 1 000 blocks will be
returned to the NANP A within six months.
COMMISSION DECISION
Should the request for waiver from Qwest Corporation be approved?
u/chall/decision memo/QWE-O5-07 Waiver of FCC Numbering Resources Idaho Falls
Number Optimization Order. CC Docket No. 99-200 and 96-, FCC 00-104, reI. March 31 2000.
DECISION MEMORANDUM - 2-APRIL 14, 2005