20251209Decision Memo.pdf

DECISION MEMORANDUM
TO: COMMISSIONER LODGE
COMMISSIONER HAMMOND
COMMISSIONER HARDIE
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM: ALLISON MOORE, COMMISSION STAFF
JEFFREY R. LOLL, DEPUTY ATTORNEY GENERAL
DATE: DECEMBER 9, 2025
SUBJECT: IN THE MATTER OF TELEPORT COMMUNICATIONS AMERICA,
LLC'S PETITION FOR A SAFETY VALVE WAIVER; CASE NO. TCS-T-
25-01.
On July 3, 2025, Teleport Communications America, LLC ("Company") submitted a
petition ("Petition") for a Safety Valve waiver to the Idaho Public Utilities Commission
("Commission"). The Company filed for the waiver after the North American Numbering Plan
Administrator("NANPA") denied its application for additional numbering resources.
STAFF ANALYSIS
In its filing, the Company included the denied application (Attachment B) for a single
thousand block of numbers from the Coeur d'Alene rate center. Petition at 1. The Company states
in the filing that the request is the result of a customer requesting one hundred consecutive numbers
that do not start with the number eight. Id. The filing also states that NANPA denied the
Company's application due to the request not meeting the months-to-exhaust and Utilization
requirements. Id.
Staff reviewed the Company's Petition, attachments thereto, and information available in
NANPA's administration system(NAS). At the time of the Company's application to NANPA, it
had approximately 2018 available numbers. Based on the information available to Staff in the
NAS, the number blocks that the Company owns have a low contamination and have at least one
block that could accommodate the customer's request. Additionally, NANPA's denial of the
application stated the Company had approximately 11.5 months to exhaustion of numbers and had
utilized 30.8% of the current numbers assigned. Petition, Attachment B at 6-7.
DECISION MEMORANDUM - 1 - DECEMBER 9, 2025

In the Company's application to NANPA it also requested numbers specifically from the
986 area code. Id. at 1. It should be noted that the State of Idaho has an area code overlay which
means that the 208 and 986 area codes work throughout the entire state. As a result,the Company
can use either area code to satisfy the customer request.
RECOMMENDATION
Staff has reviewed the Company's waiver request and recommends the Commission deny
the Company's request for an additional single thousand block of numbers.
COMMISSION DECISION
Does the Commission wish to deny the Company's waiver request?
Allison Moo•e
Commission Staff
I:\Uti1ity\UDMEM0S\TCS-T-25-01 Decision Memo.docx
DECISION MEMORANDUM - 2 - DECEMBER 9, 2025