20041129Decision Memo.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
COMMISSIONER SMITH
COMMISSIONER HANSEN
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:DOUG COOLEY
DATE:NOVEMBER 26, 2004
RE:RURAL TELEPHONE'S APPLICATION FOR AN EXTENSION OF ITS
LOCAL NUMBER PORT ABILITY RESPONSIBILITIES.
CASE NO. RUR-04-02.
On November 22 2004, Rural Telephone filed an Application asking to extend its current
suspension of wire line- to-wireless local number portability (LNP). Section 251(f)(2) of the
Telecommunications Act allows local exchange carriers with fewer than 2% of the nation
subscriber lines to petition a state commission for suspension or modification of the portability
requirements, which was initially required to be implemented by May 24, 2004. Rural
Telephone was one of sixteen Idaho Telephone Association (ITA) companies that was granted a
six-month suspension ofLNP responsibilities by this Commission in Order 29452. In that Order
Rural Telephone and other companies were given a suspension from implementing intermodal
LNP from May 24 2004 to November 24 2004 and were directed to file progress reports
regarding the status of implementing LNP. Staff received a progress report from the ITA on July
2004, stating in part that "Rural Telephone Company has sought quotes on switch upgrades
that it is in the process of evaluating." Rural's Application now requests a further 12-month
suspension of LNP requirements in its Tipanuk exchange and a 36-month suspension in its
Atlanta, Boise River, Prairie, Shoup, and Three Creek exchanges. The Application states that
switches in these exchanges would require major upgrades at an estimated cost of $740 012 to
implement LNP, and that no customers have requested that their number be ported. Finally,
Rural claims that only its Tipanuk exchange has any wireless service coverage while its Atlanta
Boise River, Prairie, Shoup and Three Creek exchanges are not served by the wireless carriers
that have requested LNP.
DECISION MEMORANDUM NOVEMBER 26, 2004
STAFF ANALYSIS
Staff has reviewed the filing and recommends the case be processed by modified
procedure. This will allow other companies an opportunity to comment and allow Staff time to
investigate some of the points raised in Rural's Application and determine whether there is
adequate reason to further suspend Rural's LNP responsibilities.
COMMISSION DECISION
Does the Commission wish to process Rural Telephone s Application by Modified
Procedure?
udmemos/rurallnp memo
DECISION MEMORANDUM NOVEMBER 26, 2004