20160318Decision Memo.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:CAROLEE HALL
DATE:MARCH 16,2016
RE:QWEST CORPORATION DBA CENTURYLINK QC (“CENTURYLINK”)
PETITION FOR A WAIVER OF FCC THRESHOLD REQUIREMENTS
FOR NUMBERING RESOURCES IN IDAHO’S NAMPA RATE CENTER;
CASE NO.QWE-T-16-03.
BACKGROUND
On March 14,2016,the Commission received a petition for a waiver of numbering
resource guidelines from Qwest Corporation dba CenturyLink QC (“CenturyLink”).In this
petition,CenturyLink indicated that it has a large customer in the Nampa.Idaho area that is
requesting a full NXX (10,000 consecutive numbers)ending with either 3,5 or 8 to incorporate
with the existing internal dialing plan.CenturyLink filed this waiver following Neustar’s denial
of the Company’s Application for additional numbering resources.
In January 2015.CenturyLink filed its request with Neustar and its Application was
denied due to the “Months to Exhaust”(MIE)calculation for the rate center.According to the
report,the MTE for the Nampa rate center exceeds the FCC guidelines.’The FCC has delegated
authority to state commissions to waive the FCC threshold required for releasing numbering
resources where there is a demonstrated need,through a process called the “safety valve.”Third
Report and Order on Reconsideration,CC Docket No.99-200,17 F.C.C.R.252 (2001)and
Errata (Feb.2,2002)(the “Optimization Order”).
To be assigned an additional thousands-block (NPA.NXX)for growth,“Months to Exhaust”must be less than or
equal to 6 months.47 C.F.R.§52.15 (g)(3)(iii)).
DECISION MEMORANDUM 1 MARCH 17,2016
STAFF ANALYSIS
Staff contacted the Company requesting the Full NXX to discuss resource demand.Staff
was concerned that recommending an entire code dedicated to one organization may compromise
the remaining 208 inventory that is rapidly approaching exhaust.After some constructive
discussions with the Company,it was decided that they could use seven of the ten blocks within
the code and agreed to return three to the pool.This will satisfy the Company’s request as well
as providing numbers in the Nampa rate center for future requests.Staff contacted CenturyLink
to discuss the specifics of the arrangement and asked that they contact Neustar and reserve the
208-205 NPA satisfying the Company’s request for an NXX ending in a 3,5 or 8.Staff
appreciates the Company and CenturvLink’s efforts to work through possibilities to resolve the
numbering request while preserving the 208 resources.
RECOMMENDATION
Staff recommends that the Commission approve CenturyLink’s petition for a waiver for
the NPA NXX of 208-205 with the understanding that the Company will assign the first seven
blocks and return the remaining three to the pool.
COMMISSION DECISION
Does the Commission agree?
/
Cplee Hall/
u/cImll/dctision memo/numbering-Safiny Valve Requests/Qvcst Corporalion dba Ce,,Iuo Link QC (CcoiuLink)QWE-T-16-D3
DECISION MEMORANDUM 2 MARCH 17,2016