20260120Staff Comments.pdf

RECEIVED
January 20, 2026
JEFFREY R. LOLL IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 11675
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF TELEPORT )
COMMUNICATIONS AMERICA, LLC'S ) CASE NO. TCS-T-25-01
PETITION FOR A SAFETY VALVE WAIVER )
COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its attorney of record, Jeffrey R. Loll, Deputy Attorney
General, submits the following comments.
BACKGROUND
Under rules promulgated by the Federal Communications Commission("FCC"), a
telecommunications carrier can challenge the North American Numbering Plan Administrator's
("NANPA") decision to withhold numbering resources with the Commission. 47 C.F.R. §
52.15(g)(4). The Commission may affirm or overturn NANPA's decision based on a
determination of compliance with the relevant reporting and numbering resource application
requirements. 47 C.F.R. § 52.15(g)(5). The Commission may also overturn the NANPA's
decision"based on its determination that the carrier has demonstrated a verifiable need for
numbering resources and has exhausted all other available remedies." Id.
On July 3, 2025, Teleport Communications America, LLC ("Company")petitioned the
Commission for a waiver of the FCC's guidelines for numbering resources in the Coeur d'Alene
rate center("Petition"). The Company petitioned for the waiver after NANPA denied its
STAFF COMMENTS 1 JANUARY 20, 2026

application for additional numbering resources, citing a failure to meet the months-to-exhaust
and utilization requirements. Petition at 1.
THE PETITION
According to the Company, its application with NANPA for numbering resources in
the form of a single thousand block of numbers was the result of a customer requesting 100
consecutive numbers that do not start with the number eight. Id. The Company states that
there is not currently a continuous block of 100 numbers that do not begin with the number eight
in the Coeur d'Alene inventory pool. Id. The Company represents NANPA denied its
application while stating the request did not meet the months-to-exhaust and utilization
requirements. Id.
STAFF ANALYSIS
Staff reviewed the Petition and its accompanying documentation, including a copy of
the application that was denied by the NANPA, and information available in the North
American Numbering Plan Administration System ("NAS"). Staff also reviewed the
numbering resource application requirements set forth in 47 C.F.R. § 52.15. As it does not
believe the Company has demonstrated a verifiable need for the requested numbering
resources, Staff recommends the Commission affirm NANPA's decision to deny the
Company's request.
At the time of the Company's application to NANPA, it had approximately 2,018
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 of 100
continuous numbers 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.
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.
STAFF COMMENTS 2 JANUARY 20, 2026

STAFF RECOMMENDATION
Staff recommends the Commission issue an order affirming NANPA's decision
to deny the Company's request for numbering resources.
Respectfully submitted this 20th day of January 2026.
Jeffrey R- Loll
Deputy Attorney General
Technical Staff. Allison Moore
I:\Utility\UMISC\COMMENTS\TCS-T-25-01 Comments.docx
STAFF COMMENTS 3 JANUARY 20, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 201h DAY OF JANUARY 2026,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF IN CASE
NO. TCS-T-25-01, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DAVID COLLIER
AT&T, LEAD REGULATORY RELATIONS
AT&T SERVICES, INC.
P.O. BOX 11010
RENO,NV 89520
E-MAIL: dc1787&att.com
PATRICIA JORD , SECRETARY
CERTIFICATE OF SERVICE