20251215Comments.pdf

` AT&T David A.Collier AT&T Services,Inc.
Lead Regulatory Relations P.O.Box 11010
Reno,NV 89520
775-527-4252 Wireless
[e-mail]
VED
Filed via Email DecembeE15,12025
IDAHO PUBLIC
December 15,2025 UTILITIES COMMISSION
Monica Barrios-Sanchez
Commission Secretary Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Building 8, Suite 201-A
Boise,ID 83720-0074
RE: COMMENTS -IN THE MATTER OF TELEPORT COMMUNICATIONS
AMERICA, LLC'S PETITION FOR A SAFETY VALVE WAIVER
CASE NO. TCS-T-25-01
Dear Ms. Barrios-Sanchez:
Pursuant to the Idaho Public Utilities Commission("Commission") Agenda held on December 9,
2025, Teleport Communications America, LLC ("TCAL") submits the following Comments as
instructed during the Commission's deliberation of Action Item 2 of the Consent Agenda.
In its initial request for a Safety Valve waiver filed with the Commission on July 3, 2025, TCAL
explained that its customer requested 100 consecutive numbers that do not begin with the
number 8. NANPA had initially denied the request due to the MTE (Months to Exhaust) not
being equal to or less than 6 months and the utilization rate not being equal to or more than 75%.
TCAL stated and still maintains that although it only has a 30.8%utilization rate, it does not
have 100 consecutive numbers to provide the Customer with, so it cannot fulfill the customer's
request without the Commission granting a waiver.
TCAL respectfully requests that the Idaho Commission grant its exception request in the interest
of our customer, as we are unable to satisfy the numbering needs of this customer without such
exception.
Please let me know if you have any questions regarding this filing.
Sincerely,
z4 41L
David Collier
AT&T—Lead Regulatory Relations
[phone]
Cc: Allision Moore,Commission Staff
Jeffrey R.Loll,Deputy Attorney General