20260203Reply Comments.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]
RECEIVED
Filed via Email February 3, 2026
IDAHO PUBLIC
February 3,2026 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: REPLY 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")Notice of Modified
Procedure issued on January 13, 2026, Teleport Communications America, LLC ("TCAL")
submits the following Reply Comments.
The Commission Staff("Staff') correctly points out that 47 C.F.R. § 52.15(g)(5)provides that
"The Commission may 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."
The Company meets both requirements here.
First, the Company has demonstrated a verifiable need. The customer requested from the
Company 100 consecutive numbers, that do not begin with the number 8, in the Coeur d'Alene
inventory pool. The customer has also requested that we secure a block where the beginning
telephone number range ends in 00 and the last number in the range ends with 99. Example:
[phone] to 6199.
TCAL initially confirmed and has reconfirmed again through its Telephone Number Assignment
Center("TNAC"), that it does not have 100 consecutive numbers available that do not begin
with the number eight and constitute a range from 00 to 99 in the Coeur d'Alene inventory pool.
In other words, TCAL is not able to meet the customer requests. This demonstrates TCAL's
verifiable need for the numbering resources. Simply put, without a waiver from the Commission,
TCAL is not able to meet the requirements of the customer.
As Staff notes in its comments, at the time it applied to NANPA, TCAL had approximately
2,018 available numbers. However, TCAL cannot use these numbers to meet the customer
request,partially due to one of TCAL's three number blocks begins with an 8. These do not meet
the customer requirements.

Additionally, TCAL assigns numbers to its active customers randomly, and numbers are ported
out to other carriers non-consecutively. That leaves a patchwork of numbers available to TCAL.
Accordingly, despite the fact that TCAL has a utilization rate of approximately 30.8%, TCAL
currently does not have 100 consecutive numbers that meet the customer's requirements.
The TNAC offered to supply 100 telephone numbers from sporadic existing available telephone
numbers,but the customer rejected that offer as they need the numbers to be consecutive. This
further confirms that the Company has a verifiable need for numbering resources.
In its comments, Staff asserts that TCAL can use either the 208 or 986 area code to satisfy the
customer request. While either area code might work in the Coeur d' Alene area, TCAL only
has access to area code 208, as explained in its initial waiver request filed on July 2,pursuant to
the Local Exchange Routing Guide ("LERG"). (The LERG is an industry reference
product/database that focuses on routing/operational data used by carriers.) So, while Staff is
technically correct that 208 or 986 area codes could, in theory,be used, that option is not
available for TCAL. As noted, TCAL does not have 100 consecutive numbers that meet the
customer's requirements.
TCAL has also exhausted all other available remedies. It properly applied to NANPA, and the
request was denied. TCAL then filed this waiver request, as allowed under the regulations. It has
no other avenue to pursue.
In addition to the rate center not qualifying from a utilization perspective, and all of the customer
restrictions outlined above and on the customer Letter of Interest, these are all the reasons a
Safety Valve request was initiated where we are requesting a waiver to order a new lk growth
block for our customer.
In summary, TCAL meets the requirements for the waiver. It has a verifiable need, since its
existing resources cannot meet the customer's requirements, despite the existing utilization rate.
Without a waiver, TCAL cannot fulfill the customer's request. And TCAL has exhausted
available resources.
TCAL respectfully requests that the Idaho Commission grant its exception request in the interest
of our customer, as we are otherwise unable to satisfy the numbering needs of this customer.
Please let me know if you have any questions regarding this filing.
Sincerely,
David Collier
AT&T—Lead Regulatory Relations
[phone]
Cc: Allison Moore,Commission Staff
Jeffrey R.Loll,Deputy Attorney General
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