20160318Request for Waiver.pdf

CENTURYLINK
1600 7th Avenue, Room 1506
Seattle, Washington 98191
(206) 733-st18
Facsimile [phone]
Maura E. Reynolds
Paralegal
Regulatory Law
RECEIVED
?016 ltAR I B AH llr tr5 CenturyLink'srTdTrlv
ril' i 'ilt"JELtC
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March 16,2016
Via Overnight delivery
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 W est Washington Street
P.O. Box 83720
Boise, Idaho 83720-007 4
Re: Case No.: QWE-T-16-03
Request for Waiver
Dear Ms. Jewell:
Enclosed for filing is an original and seven (7) copies of the revised Request for Waiver pleading
in this docket. The header has been revised. Please replace this pleading with the previous
Enclosure(s)
cc: Carolee Hall
1600 7tn Avenue, Room 1506
Seattle, Washington 98191
www.centurylink.com
Lisa A Anderl (WSBA# 13236)
Centurylink
1600 7th Ave, Room 1506
Seattle, Washington 98 I 91
Telephone: [phone]
Lisa. anderl@centurylink. com
PETITION OF QWEST CORPORATION dba
CENTURYLINK QC ("CENTURYLINK")
FOR WAIVER OF FCC THRESHOLI)
REQUIREMENTS FOR NUMBERING
RESOURCES FOR BOTSE, rDAHO
RECE IVED
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cAsE NO. QWE-T-16-03
QWEST CORPORATION'S REQUEST
FOR WAIVER
BEFORE TIIE IDAIIO PUBLIC UTILITIES COMMISSION
Qwest Corporation dba CenturyLink QC ("CenturyLink") by and through its undersigned
attorneys, and pursuant to IDAPA 31.01.01.256, files the following Request for Waiver of
certain FCC threshold requirements for the release of numbering resources. CenturyLink
petitions the Commission for review of the denial by the administrator of the North American
Numbering Plan, NeuStar, of CenturyLink's application for use of central office code numbering
resources in area code 208.
Specifically, CenturyLink requests waiver of the utilization threshold requirernents
outlined in the FCC's Numbering Resource Optimization Orders, FCC 00-429 and FCC 0l-362
released in CC Docket No. 99-200. Such waiver would allow NeuStar the authority to provide
10,000 numbers, a fulINXX, to CenturyLink. The 10,000 numbers in question are in the 208
NPA in the Nampa Rate Center, and are required to meet a specific customer need in the Nampa
community. The customer requires these numbers as soon as possible, and will begin using them
for planned expansion at this location. The customer requires a complete NXX ending in digits
3, 5 or 8 to incorporate with the existing internal dialing plan and multi-campus locations. Once
REQUEST FOR WAIVER
the new numbers are placed into service, the customer plans to return 1,000 of their existing
DIDs. The customer's request is attached as Confidential Attachment A.
On March 1,2016, CenturyLink submitted the customer's request for numbering
resources to NeuStar. The request was immediately denied due to the "months to exhaust"
calculation for the Nampa Rate Center. See Attachment B. This waiver request is for the
"months to exhaust" usage threshold for numbering request.
The FCC permits a waiver of the kind request here when there is a demonstrated need,
such as a specific customer request for numbers. The waiver process is specifically addressed in
the FCC Third Report and Order ("Order") as the "safety valve" process. See FCC 01-362 fl'l|
57-66 (March 14,2002). The order delegates authority to hear requests for waivers to the state
commissioners and recommends that state commissions act expeditiously. See Id.,lTfl 61, 66.
CenturyLink respectfully requests that the Commission approve this Request for Waiver
of the "months to exhaust" threshold requirements and direct NeuStar to provide a new NXX
code (i.,e. ten blocks of 1000 numbers) in the Nampa Rate Center in the 208 NPA as outlined
above, to meet Centurylink's customer's request.
Respectfully submitted this 16th day of March,2016.
CENTURYLINK
Lisa A. Anderl
REQUESTFOR WAIVER
CONFIDENTIAL ATTACHMENT A
IS FILED UNDER SEPARATE COVER
January 12,2015
ATIS-0300066.at3
Tracking Number:
Date of Application:
Date of Receipt:
Service Provider Name:
(iconectiv rM LERG"
Routing Guide ) OCN:
Parent Company OCN:
NPAC SOA SPID :
ATTACHMENT B
Pooling Administrator's Response/Confirmation
TBPAG Part 3
2O8.NAMPA.ID.
904613
03/01/2016 Effective Date:
Date of
Response:03t01t2016
Attachment 3
Page I of2
03101/2016
QWEST CORPORATION
Pooling Administrator Contact Information:
John Auerbach Phone:
Signature of Pooling Administrator
John Auerbach Fax:
Name (print)
Email:
NPA-NXX or
NPA-NXX-X:
Block Contaminated(Yes or No) :
If Yes,enter the number of TNs
contaminated:
925-363-8706 td?
925-363-7684 Sr
joh [e-mail]
Block Assigned:
Block Reserved :
Block Reservation
Expiration Date :
Block/Code
Modified:
Block/Code
Disconnected:
https ://www.nationalpooling.com/pas/print_form j sp 3ly20t6
ATTACHMENT B
NMPAIDMADSO
NAMPA
X
Explanation:
DR-57: You do not meet the MTE and/or Utilization requirements, therefore
this request for a new code 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.
_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 rM Location Identification code
of the switching entity/POl shown on the Part 1A form (LERG ROUTING
Guide and CLLI are trademarks of Telcordia Technologies,Inc. dba iconectiv)
Switch Identification(Switch
Entity/POI): I
Rate Center:
Form Complete, request denied.
Page2 of2
https : //www.nationalpooling. com/pas/print_form j sp 3tLl20t6
ATTORNEY'S CERTIFICATE
Qwest Corporation dlbl a CenturyLink
Case No. QWE-T-16-03
This Certificate is made pursuant to Rule 67 of the Idaho Public Utilities Commission's
Rules of Procedure I.D.A.P.A. 31.01.01000.
This Certificate applies to the enclosed Confidential Waiver Request by Qwest
Corporation dlbla CenturyLink on behalf of a customer. These documents are considered
proprietary and confidential due to the CenturyLink proprietary information and the customer-
specifi c proprietary information contained therein.
The undersigned hereby attests that she is familiar with the material claimed not to be
available for public inspection, examination and copying, and that she, in good faith, believes
that there is a basis in law for that claim, namely that the information contained therein
constitutes a"trade secret" as defined in Idaho Code Section 48-801 and is by virtue the Idaho
Trade Secrets Act, Title 48, Chapter 8, Idaho Code subject to protection.
DATED this // 6 day of Mar ch,2016.
Lisa A. Anderl
MTE Block REDACTED
CONFIDENTIAL
Page 1 of3
Appendix 3 January 12,2015
MONTHS TO EXHAUST and UTILIZATION CERTIFICATION WORK SHEET - TN Levelr
(Thousands-Block Number Pooling Growth Block Request)
Tracking Number: 208-NAMPA-ID-904613
Date: Tuesdav' March 1' ocN:!f!{ companyName:@ZUIO
Rate Center: MUB
List all Codes NPA(s)-NXX(s) and Blocks NPA(s)-NXX-X(s
468.505-2
Name of Block Applicant:IUg.,l$g@iq Signature: Rita Schmitz
Title:@!II relephone No.: !9!&!!99 $t FAX No.:
E-Mail : [e-mail]
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 #5 #6 #7 #8 #9 #10 #11 #t2
E. Growth
History -
https : //www.nationalpooling. com/pas/print_form j sp 3/U2016
MTE Block REDACTED
CONFIDENTIAL
Previous 6
monthsa
F. Forecast
- Next 12
monthss
G. Average Monthly Forecast (Sum of months # l-6 (Part F above) divided by 6):,
I y:"n:. Numbers Available for Assisnment toto trxnaust-Customers(A)
Average Monthly Forecast(G)
Block Requested Available Numbers
I
Page? of3
Months To Exhaust
I.
UtilizationT Assisned Numbers(B) X 100 :
Total Numbering Resources(C)-Excluded
Numbers(D)
Explanation:
lA copy of this worksheet is required to be submitted to the Pooling Administrator 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.
3Quantity 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,O00 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)(X-X) for growth, "Months to Exhaust" must be
less than or equal to 6 months. (FCC 00-104, section 52.15 (g) (3) (iii)).
https : //www. nationalpooling.com/pas/print_form j sp 3lv20t6
MTE Block REDACTED Page 3 of 3
CONFIDENTIAL
TNewly acquired numbers may be excluded from the Utilization calculation (FCC 00104, section
s2.ls (g)(3)(ii))
https ://www.nationalpooling. com/pas/print_form j sp 3lU20t6