20180511Decision Memo.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLA}IDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM: CAROLEE HALL
DATE: MAY 8, 2018
RE:QWEST CORPORATION DBA CENTURYLINK QC ("CENTURYLINK")
PETITION FOR A WAIVER OF FCC THRESHOLD REQUIREMENTS
FOR NUMBERING RESOURCES IN IDAHO'S BOISE RATE CENTER;
cAsE NO. QWE-T-18-04.
BACKGROTJND
On May 1,2018, 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 Boise, Idaho area that is requesting a
full N)O( (10,000 consecutive numbers). The company is requesting assignment preferences of
208-510, 208-516, or 208-517, to incorporate with the existing internal dialing plan of its
customer. Centurylink filed this waiver following Neustar's denial of the Company's
Application for additional numbering resources.
On April 25,2018, CenturyLink filed its request with Neustar and its Application was
denied due to the "Months to Exhaust" (MTE) and/or usage threshold calculation for the rate
center. According to the report, the MTE for the Boise rate center exceeds the FCC guidelines.r
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,
l7 F.C.C.R.252 Q00l) arrd Errata (Feb.2, 2002) (the "Optimization Order").
I To be assigned an additional thousands-block (NPA-NXX) for growth, "Months to Exhaust" must be less than or
equalto 6 months. 47 C.F.R. $ 52.15 (gX3Xiii)).
DECISION MEMORANDUM MAY 8,2018I
STATF ANALYSIS
Staffhas reviewed the Company's customer request and agtees that the growth in Idaho
certainly has increased the demand for numbering resources. Staffagrees with the request.
RECOMMENDATION
Staff recommends that the Commission approve CenturyLink's petition for a waiver for
10,000 sequential numbers within the 208 NPA, either the 510, 516 or 517 N)O(.
COMMISSION DECISION
Does the Commission agree?
,-//
Carolee
u/chalUdecision memo/numbering-Safety Valve RequestyQwest Corporation dba Century Link QC (Conturylink) QWE-T-I8-04
t,
2DECISION MEMORANDUM MAY 8,2018
L t
I