20150429Amended Petition.pdf

CENTURYLINK
1 600 7th Avenue, Room 1 506
Seattlo, Washington 98191
(206) 73$s17E
Maura E. Reynolds
Paralsgal
Regulalory Law
April28, 2015
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ATTd
Trrv CenturyLink'
VA OWRNIGHT DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472West Washington
Boise, lD 83702-5983
RE: Docket No. QWE-T-15-04
Dear Ms. Jewell:
Enclosed for filing with this Commission are an original and seven (7) copies of the Petition of
CenturyLink for Waiver of FCC Threshold Requirements for Numbering Resources for
Pocatello, Idaho. CenturyLink is re-filing these documents to include confidential and public
versions.
If you have any questions, please contact me.
Sincerely,
DS
Enclosures
(REDACTEDI CON FIDENTIAL ATTACHMENT A
ll:ir r': rl l-:! lr i1i
April20,2015
Idaho Public Utilities Commission
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-007 4
Dear Ms. Jewell:
James B. Farr
Regulatory Affairs Director - ldaho and Utah
Room 1601
250 Bell Plaza
Salt Lake City, Utah 841 11
Office: 801-238-0240Fax: [phone]
iames.farr@centurylink. com
& ani'ts'U+
Qwest Corporation d/bia CenturyLink QC ("CenturyLink") submits this confidential
leffer to the Idaho Public Utilities Commission requesting a waiver of the months-to-exhaust and
utilization threshold requirements outlined in the Numbering Resource Optimization Orders (CC
Docket No. 99-200, FCC 00-429 & FCC 0l-362). This waiver is being requested in order to
allow Neustar Inc., the Pooling Administrator for the state of Idaho, to provide CenturyLink with
a lK Block (one thousand numbers) for the Pocatello Rate Center. This request is to deploy new
technology for our customers. The new technology
(CONFIDENTIAL INFORMATION REDACTED)
CenturyLink submitted a Part 1A and MTE Worksheet to Neustar/PA on April 14,2015,
requesting numbering resources to meet the requirements for the new GPON technology. The
request was denied through a Part 3 denial. Thus, a waiver by the Idaho Public Utilities
Commission is necessary so that CenturyLink can provide the new fiber to the home technology.
(Please see attached requestfrom CenturyLink to NANPA/PAwith denial labeled Confidential
Attachment B)
The FCC Second Report and Order onNumbering Resource Optimization allows for a
waiver of the rules when there is a demonstrated need such as a "specific customer request for a
large block of numbers." (See FCC 00-429, n 186) or in cases where carriers "have demonstrated
a verifiable need for additional numbering resources outside of these specifically enumerated
instances." (See FCC 0l-362, n 6l). The waiver process is more specifically addressed in the
FCC Third Report and Order as the "safety valve" process (FCC 0l-3 62, see flfl 5 7-66). The
Third Report and Order delegates the authority to hear claims for waivers to the state
Jean Jewel, Secretary
April20, 2015
Page2
commissions and recommends they act expeditiously and proposes a waiver be reviewed within
10 business days. (Seeparas. 61, 66).
CenturyLink respectfully requests the Idaho Public Utilities Commission approve its
waiver and direct Neustar Inc. to assign to CenturyLink a lK Block (1,000 numbers) from the
Industry Pool lnventory that satisfies the requirement in the Pocatello Rate Center allowing
CenturyLink to deploy the new GPON technology. The directive can be mailed to:
John Auerbach
Pooling Administrator
NeuStar,Inc.
1800 Sutter Street, Suite 780
Concord, CA94520
Email: i ohn. auerbach@,neustar.biz
Fax: [phone]
Thank you for your affention to this matter. Should you have any questions or concerns
about this request, please do not hesitate to contact me or Bruce Bennett at CenturyLink (303)
707-7013.
Sincerely,
a\
James B. Fa:r
Regulatory Affairs Director
Attachment
cc: Bruce Bennett, CenfuryLink
PartlA REDACTED
CoNFTDENTTAL ATTACHMENT B age I of 4
TBPAG Attachment I - January 12,2015
Thousands-Block Application Form - Part 1A
Tracking
Number:
lndividualBlock
Request
Type of i--:- i-, Change :-lai,iiiJ",i""' l' New i pisconnect
GENERAL APPLICATION INFORMATION
1. I Contact Information:
Block Applicant:
Company Name: OWEST CORPORATION
|ladcuarters 100 centurvltnk Dr.Address:
City, State, Zip: Monroe. LA.71203
Contact Name: Bruce Benneft
9:l"t-1 700 w. Minerar, Room MN pi9.28
Address:
City, State, Zip: Liftleton. CO.80120
Phone: 303-707- -::-:.-'
-Fax:[phone]
E-mail: [e-mail]7013
Pooline Administraror: ii ?
Contact Name: John Auerbach
i:t*::, {Boo sutter st. ste. 780
City, State, Zip: Concord. GA.94520
Phone: 925-363€706 Fax:[phone]
E-mail: [e-mail]
1.2 General Information:
Check one : No LRN needed LRN needed iii
NPA:- LATA:- oCN: rY
Parent Company's oCN
Number of Thousands-Blocks R"q,r"rt"Af
Switch Identification (Switching EntitylPOl) : v
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PartlA
a) Is this block Contaminated: Yes or No
b) If Yes how many TNs are NOT available for assignment :-
c) Have all new Intra SP ports been completed in the NPAC: Yes
-
or No
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REDACTED
IDENTIAL ATTACHMENT B
Rate Center: vi
1.3 Dates:
Date of Application: uii olnntzots ReguestedBlock Effective Date: v,r
t-. By selecting this checkbox, I acknowledge that I am requesting the earliest possible
effective date the Administrator can grant. Please note that this only applies to a reduction in
the Administrator's processing time, however the request will still be processed in the order
received.
Request Expedited Treatment? (See Section 8.6) Yes X No
Expedited Explanation:
1.4 Type of Service Provider Requesting the Thousands-Block :
a) Type of Service Provider :lncumbent Local Exchanqe Carrier (lLECl (LEC, IXC,
CMRS, Other)
b) Primary type of service Blocks to be used for : Wireline
c) Thousands-Block(s) (NXX-X) assignment preference (Optional)
d) Thousands-Block(s) (N)O(-X) that are undesirable for this assignment , if any
e) If requesting a code for LRN pu{poses, indicate which block(s) you will be keeping (the
remainder of the blocks will be given to the pool)
-
1.5 Type of Request:
Initial block for rate center : Yes If Yes, attach evidence of authorization and proof of
capability to provide service within 60 days.
Growth block for rate center : Yes X If Yes, attach months to exhaust worksheet
: By selecting this checkbox, I acknowledge that I am willing to accept a block in red and
explicitly understand that the underlying CO code may not yet be activated in the PSTN and
loaded in the NPAC on the block effective date.
Type of change (Mark all that apply)
I OCN: Inta-compuny i* I Switching Id I Part 1B
rl OCN: Inter-company x L Effective Date
Change block: Yes If Yes,listNPA-N)O(-X
1.6 Block Return:
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PartlA REDACTED
CONFIDENTIAL ATTACHMENT Bd) Has this block been protected from further assignment: Yes orNo
Disconnect block : Yes
Remarks:
If Yes,listNPA-NXX-X
I hereby certiff that the above information requesting an NXX-X block is true and accurate to
the best of my knowledge and that this application has been prepared in accordance with the
Thousands'Block (NO(-X) Pooling Adminishation Guidelines ,4.T15-0300066 available on
the ATIS web site (http//www.atis.org/inc) or by contacting [e-mail] as of the date of this
application.
Page 3 of4
Bruce Benneft
Signature of Block Applicant
Senior Lead Analyst - Numbering
Operations
Title
0411412015
Date
Instructions for filling out each Section of the Part lA form:
Section 1.1 Contact information requires that Service Providers supply under "Block
Applicant" the company name, company headquarters address, a contact within the company,
an address where the contact person may be reached, in addition to the correct phone, fax, and
e-mail address. The Pooling Administrator section also requires the Service Provider to fill in
the Pooling Administrator's name, address, phone, fax and e-mail.
Section 1.2 Service Providers who need a thousands-block assignment or for an Location
Routing Number (LRN) are required to fill in this section. If needed for an LRN, a CO Code
Application needs to also be submitted to the PA. The Service Provider should supply the
Numbering Plan Area (NPA); the Local Access Transport Area (LATA), which is athree-digit
number that can be found in the iconectivTM LERGTM Routing Guide. The Operating
Company Number (OCN) assigned to the service provider and the OCN its parent company.
An OCN is a four-character alphanumeric assigned by iconectiv Telecom Routing
Administation (TRA). In addition, the number of thousands-blocks requested should be
supplied. The Switch ldentification as well as the city or wire center name, rate center, rate
center sub zone, homing tandem and CLLITM tandem of the facilities based provider xi.
Explanations of these terms may be found in the footnotes.
Section 1.3 The date the Service Provider completes the application should be entered in this
section, as well as the Effective Date of the requested thousands-block.
Section 1.4 Service Providers should indicate their type, e.g., local exchange carrier,
competitive local exchange carrier, interexchange carrier, CMRS. The also indicate the
primary type of business in which the numbering resource is to be used. Service Providers also
may indicate their preference for a particular thousands-block, e.g., 321-9X)O(, or indicate
any thousands-blocks that may be undesirable, e.g., 321-6X)o<.
Section 1.5 Service Providers indicate the type of request. Initial requests are for first
applications for thousands-blocks in a rate center, growth for additional thousands-blocks in a
rate center in which the applicant already has numbering resources, and provide the required
evidence as ordered by the FCC.
Section 1.6 Service Providers must indicate the updated/current information in regards to
contaminated TNs on the block they are returning to the pool. Blocks with over 10olo
contamination (l0l TNs or more) shall not be returned to the pool unless they meet criteria
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PartlA REDACTED
outlined in section e.r.2 "rthc"?JElREl[IfhfiIiil?[1F,,lT"L"d is over r0%
contaminated the PA shall seek a new block holder. If question c and/or d have a response of
No, the request for return shall be denied.
The thousands-block applicant certifies veracity of this form by signing their name, and
providing their title and date.
Footnotes:
ildenti$, the type of change(s) in Section 1.5.
ii The Pool Administrator is available to assist in completing these forms.
iii A Co Code application will also need to be submitted to the PA.
iv Operating Company Number (OCN) assignments must uniquely identiff the applicant.
Relative to CO Code assignments, NECA-assigned Company Codes may be used as OCNs.
Companies with no prior CO Code or Company Code assignments should contact NECA (800
524-1020) to be assigned a Company Code(s). Since multiple OCNs and/or Company Codes
may be associated with a given company, companies with prior assignments should direct
questions regarding appropriate OCN usage to (TRA) (732-699-6700).
v This is an eleven-character descriptor of the switch provided by the owning entrty for the
purpose of routing calls. This is the 1l character CLLITM code of the switch /POI.
ui Rate Center name must be a tariffed Rate Center.
uii Acknowledgment and indication of disposition of this application will be provided to
applicant within seven calendar days from the date of receipt of this application. An
incomplete form may result in delays in processing this request.
niii Pleas" ensure that the NPA-NXX of the LRN to be associated with this block(s) is/will be
active in the PSTN prior to the effective date of the block(s).
ix Select if you are the current Block Holder.
x Select if you are not the current Block Holder
*iLERG Routing Guide, and CLLI are trademarks of Telcordia Technologies, [nc. dba
iconectiv
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MTE Block REDACTED page I of 3
Appendix 3 CoNFIDENTIAL ATTACHMENT B
January 12,2015
MONTHS TO EXHAUST and TJTILIZATION CERTIFICATION WORK SHEET - TN Levell
(Thousands-Block Number Pooling Growth Block Request)
Tracking Number:
Date:ruesday,April14,2015 ocN:e636 3sfr$fiilIffiS[trS
Rate Center: I
List all Codes NPA(s)-N)C((s) and Blocks NPA(s)-NXX-X(s)2
Name of Block Applicant:Bruce Bennett Signature: Bruce Bennett
Title:Senior Lead Analvst - Numberins Onerations Telephone No.: 303-707-7013-
FAX No.: 303-707-9577
E-Mail : bruce.bennett@CenturryLinkcom
A. Available Numbers
B. Assigned Numbers:
C. Total Numbering Resources
D. Quantity of numbers activated in the past 90 days (increments of 1,000 or 10,000) and excluded
from the Utilization calculation 3:0
List
Excluded
Code(s) or
Block(s):
Month Month Month Month Month Month Month Month Month Month Month Month
#t #2 #3 #4 #s #6 #7 #8 #9 #10 #tt #12
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MTE Block REDACTED
CONFIDENTIAL ATTACHMENT B
Page2 of3
E. Growth
i',:|!fl;6 -ro reo -460 208 -t4e -2ot
months4
F. Forecast-Nextl2 1000 q q a q q q 0 0 a q q
months5
G. Average Monthly Forecast (Sum of months # l-6 (Part F above) divided by 6):166.667
il#:$
Average Monthly Forecast(G)
Block Requested Available Numbers Months To Exhaust
I 63519 381.113
I.
UtilizationT Assigned Numbers(B) X 100 = 46.301
Total Numbering Resources(C)-Excluded
Numbers@)
Explanation:
lA copy of this worksheet is required to be submitted to the Pooling Administator when requesting
additional numbering resources in a rate center. For auditing purposes, the applicant must retain a
copy of this document.
2Report on all resources for the requested geographic area, including newly acquired blocks/codes.
3q.,*tity of numbers activated in the past 90 days is based on blocks and/or codes received from
the administrator and shall be reported in increments of 1,000 or 10,000 TNs (e. g.: 2 blocks
received:2,0OO and I code received:10,000).
4Net change in TNs no longer available for assignment in each previous month, starting with the
most distant month as Month #1, and Month #6 as the current month.
SForecast of TNs needed in each following month, starting with the most recent month as Month #1.
6To be assigned an additional thousands-block (N)O(-X) for growth, "Months to Exhaust" must be
less than or equal to 6 months. (FCC 00-104, section 52.15 (g) (3) (iii)).
TNewly acquired numbers may be excluded from the Utilization calculation (FCC 00104, section
s2.1s (eX3)(ii))
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MTE Block REDACTED
CONFI DENTIAL ATTACHMENT B
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Part3 REDACTED
CONFI DENTIAL ATTACHMENT B
January 12,2015
ATIS-0300066.a13
Pooling Adminishator's Response/Confi rmation
TBPAG Part 3
Tracking Number :
Date of Application: 0411412015 Effective Date:
Date of Receipt: 0:411!!2015 Date of Response: 0411412015
ServiceProviderName: QWESTCORPORATION
(iconectiv TM LERG rM
Routing Guide ) OCN:
Parent Company OCN:
NPAC SOA SPTD :
Page I of2
Attachment 3
Pooling Administator Contact Information:
John Auerbach Phone:
Signature of Pooling Administrator
John Auerbach
NPA-NXX or
NPA-NXX.X:
925-363{706
Fax:[phone]
Name (print)
Email: [e-mail]
Block Assigned:
Block Reserved :
Block Reservation
Expiration Date :
Block/Code
Modified:
Block/Code
Disconnected:
Block Contaminated(Yes or No) :
If Yes,enter the number of TNs contaminated :
Switch Identification(Switch Entity/POI): I
Rate Center:
X Form Complete, request denied.
Explanation:
DR-57: You do not meet the MTE and/or Utilization requirements, therefore this request for
a new block is denied. You may proceed with requesting a State Waiver from the
appropriate state commission using this Part 3 denial. lf you are in disagreement with the
disposition of this request, please refer to the Thousands-Block Number (NXX-X) Pooling
Administration Guidelines for the appeals process.
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Part3 REDACTED Page2 of 2
CONFIDENTIAL ATTACHMENT B
_Request withdrawn.
Explanation:
_Assignment activity suspended by the administrator.
Explanation:
Remarks:
I This is an eleven-character descriptor provided by the owning entity for the purpose of
routing calls.This must be the CLLI TM Location ldentification code of the switching
entity/POl shown on the Part lA form (LERG ROUTING Guide and CLLI are trademarks of
Telcordia Technologies,Inc. dba iconectiv)
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