20190125Decision Memo.pdf

DECISION MEMORAI{DUM
TO:COM]\{ISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER A}IDERSON
COMMISSION SECRETARY
LEGAL
WORKING T'ILE
FROM: CAROLEE HALL
DATE: JAIYUARY 23,2019
RE:TELEPORT COMMUNICATIONS AMERICA,LLC ((TCAL') F'ILED A
PETITION FOR A SATETY VALVE WAIVER OF FCC THRESHOLI)
REQUIREMENTS FOR NUMBERING RESOURCES IN THE
CALDWELL RATE CENTER; CASE NO. TCS-T-19-0r.
BACKGROIJND
On January 22,2019, the Commission received a Petition for a Safety valve waiver of
numbering resource guidelines from Teleport Communications America, LLC (TCAL"). The
Safety Valve was filed following Neustar's denial of the Company's Application for additional
numbering resources in the Caldwell rate center. In this Petition, TCAL indicated that on
December 21,2017, it had requested three consecutive one-thousand blocks of numbers for its
customer in the Caldwell rate center.
TCAL's Neustar Application was denied due to the "Months To Exhaust" (MTE)
calculation for the rate center. According to the report, the Ml E for the Caldwell rate center
exceeds the FCC guidelines.l Moreover, TCAL's customer requested consecutive thousands-
block numbers and TCAL does not have enough numbers in its inventory to meet this request.
STAFF ANALYSF
Staff has reviewed the request for the Safety Valve waiver of the "months to exhaust"
threshold requirements and believes it is reasonable for the customer's business plan.
t To be assigned an additional thousands-block (NXX-X) for growth, "Months to Exhaust" must be less than or
equalto 6 months. (FCC 00-104, Section 52.15 (gX3Xiii)).
1DECISION MEMORANDUM JANUARY 23,2019
RECOMMENDATION
Staff recommends that the waiver request for the tlree consecutive one-thousand blocks
of numbers be granted to TCAL for its customer in the Caldwell rate center.
COMMISSITiN NNCISION
Does the Commission agree?
ulchall/decision memoinumbering/Teleport Communications America, LLC GCAI) TCS-T-19-01
2DECISION MEMORANDUM JANUARY 23,2019
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