20070907Decision memo.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
CO MMISSI 0 NER SMITH
COMMISSIONER REDFORD
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:CAROLEE HALL
DATE:AUGUST 30, 2007
RE:QWEST CORPORATION'S PETITION FOR WAIVER OF FCC
THRESHOLD REQUIREMENTS FOR NUMBERING RESOURCES IN
IDAHO'S BOISE RATE CENTER; CASE NO. QWE-07-
BACKGROUND
On August 22, 2007 , Qwest Corporation filed a request for a waiver of numbering
resource guidelines following denial of its Application filed with Neustar, the North American
Numbering Plan Administrator (NANP A). According to its August 22, 2007 Application
Qwest's customer requires 10 sequential blocks (i., ten blocks of 1000 numbers) of numbers in
any NXX ending in digit 1 or 2. Qwest'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 1 000 of its
existing numbers.
On August 9 2007, Qwest submitted an automated worksheet to Neustar via its online
system to obtain numbering resources necessary to meet the demand of its customer in Boise
Idaho. Qwest's Application was denied due to the "months to exhaust" (MTE) calculation for
the Boise Rate Center. To be assigned an additional thousands-block (NXX-X) for growth, MTE
must be less than or equal to six months. According to the Application attached to Qwest'
request, the MTE for the Boise Rate Center is 161 months.
DECISION MEMORANDUM AUGUST 30, 2007
STAFF ANALYSIS
Staff has reviewed the request for waiver of the "months to exhaust" threshold
requirements and notes that the customer is a single entity that asserts it needs these numbers as a
result of expansion in its business. These numbers will be held solely by this requesting
customer and will enable it to meet its 400 000 square foot building expansion in Boise.
Qwest Corporation participates in the thousand-block-pooling in the Boise 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 Qwest's request for its customer , Staff does not believe that granting
this requested waiver will result in an inefficient use of Idaho s numbering resources. According
to FCC orders and numbering guidelines, carriers may appeal NANP A decisions of this nature to
the appropriate state regulatory authority. The Commission has granted similar waivers in the
past to meet the requests oflarger customers. (See Order Nos. 28769 and 29279).
RECOMMENDATION
Staff recommends that the request for authority to provide 10 000 numbers, a full NXX
be granted to Qwest for its customer s request with the caveat that all numbers be used
sequentially and that any unused thousand blocks be returned to the NANP A within six months.
COMMISSION DECISION
Should the request for waiver from Qwest Corporation be granted along with the
requirement that all numbers are used sequentially and any unused thousand blocks be returned
to NANP A within six months?
u/chall/decision memo/numberinglQwest Corporation s Safety Valve Request QWE-O7-
DECISION MEMORANDUM AUGUST 30, 2007