20260316Final_Order_No_36965.pdf

Office of the Secretary
Service Date
March 16,2026
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF TELEPORT ) CASE NO. TCS-T-25-01
COMMUNICATIONS AMERICA,LLC'S )
PETITION FOR A SAFETY VALVE WAIVER )
ORDER NO. 36965
On July 3, 2025, Teleport Communications America, LLC ("Company") petitioned the
Idaho Public Utilities Commission ("Commission") for a waiver of the Federal Communications
Commission's ("FCC") guidelines for numbering resources in the Coeur d'Alene rate center
("Petition").
On January 13, 2026, the Commission issued a Notice of Petition and Notice of Modified
Procedure establishing written comment deadlines. Order No. 36905. Commission Staff("Staff')
filed comments to which the Company replied. The Commission received no public comments.
Based on our review of the record, the Commission now issues this Final Order granting
the Company's Petition.
BACKGROUND
A telecommunications carrier can petition the Commission for an order overturning the
North American Numbering Plan Administrator's ("NANPA") decision to withhold numbering
resources pursuant to rules promulgated by the FCC. 47 C.F.R. § 52.15(g)(4). In rendering its
decision, the Commission may consider factors such as the petitioner's compliance with the
relevant reporting and numbering resource application requirements. 47 C.F.R. § 52.15(g)(5). The
Commission can 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.
THE PETITION
The Company requested a waiver of the FCC's guidelines for numbering resources in the
Coeur d'Alene rate center after the NANPA denied its application for additional numbering
resources, citing a failure to meet the months-to-exhaust and utilization requirements. Petition at
1. The Company stated that its application with the NANPA for numbering resources in the form
ORDER NO. 36965 1

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 represented that there is not
currently a contiguous block of 100 numbers that do not begin with the number eight in the Coeur
d'Alene inventory pool. Id.
STAFF COMMENTS
Staff reviewed the Petition, a copy of the application that was denied by the NANPA, and
information available in the North American Numbering Plan Administration System ("NAS").
Staff Comments at 2. Staff also reviewed the numbering resource application requirements set
forth in 47 C.F.R. § 52.15. Id. Staff did not believe the Company has demonstrated a verifiable
need for the requested numbering resources and recommended the Commission affirm the
NANPA's decision to deny the Company's request.Id.
According to Staff, the Company had approximately 2,018 available numbers at the time
of its application to the NANPA. Id. Following its review of information available in the NAS,
Staff determined the Company's current number blocks have a low contamination and contain at
least one block of 100 continuous numbers that would satisfy the customer's request. Id. Staff
noted that the NANPA's denial of the application stated that the Company had utilized only 30.8%
of its currently assigned numbers.Id. The denial also stated that the Company had approximately
11.5 months to exhaustion of numbers.Id. Staff also stated that,although the Company specifically
requested numbers with a 986 area code, the Company could use either of Idaho's two area codes
to satisfy the customer's request, as Idaho has an area code overlay.Id.
COMPANY REPLY COMMENTS
The Company contended that it had demonstrated a verifiable need for numbering
resources and that it had exhausted all other available remedies. Company Reply Comments at 1.
In addition to requesting 100 consecutive numbers that do not begin with the number eight, the
Company stated that the customer also requested"a block where the beginning telephone number
range ends in 00 and the last number in the range ends with 99."Id. According to the Company, it
has made multiple confirmations, including through its Telephone Number Assignment Center
("TNAC"), that it does not have the numbers to satisfy the customer's request.Id.
The Company added that while its utilization rate is approximately 30.8%, it randomly
assigns numbers to its active customers, leaving what the Company describes as "a patchwork"of
ORDER NO. 36965 2

available numbers.Id. at 2. The Company further asserted that it only has access to 208 area code
numbers, and not 986 area code numbers, pursuant to the Local Exchange Routing Guide—an
industry reference product and database that focuses on routing and operational data used by
carriers.Id.
COMMISSION FINDINGS AND DECISION
We have jurisdiction over this matter and the issues in this case under 47 C.F.R. § 52.15(g),
which empowers the Commission to review the NANPA's decision to withhold numbering
resources from telecommunications carriers in the state of Idaho.
After reviewing the Company's Petition, Staff s recommendation, and the Company's
reply, the Commission finds that the Petition should be granted. We accept the Company's
representation that it has confirmed through its TNAC that it is currently unable to meet the
customer's request. The Company has demonstrated a need for the numbering resources. We also
find that the assignment will not detrimentally affect number resources for the Coeur d'Alene rate
center.
We find it is reasonable to direct that the NANPA provide the new numbering resources
requested by the Company to meet its customer's requirements. Specifically, the NANPA should
issue the Company a single thousand-block of numbers with at least one range of 100 contiguous
numbers that do not begin with the number eight and wherein the beginning number of the range
ends in 00 and the last number of the range ends with 99.
Additionally, we note multiple actions the Company can take to avoid the need for future
filings of this nature. First, the Company should return unused numbers to offset those issued
pursuant to its Petition to prevent a further decrease in its utilization rate. Second, the Company
should cease its practice of randomly assigning numbers and should instead begin assigning
numbers sequentially to prevent unnecessary contamination of its available numbers.
ORDER
IT IS HEREBY ORDERED that the Company's Petition for a waiver of the FCC's
numbering guidelines is granted.
IT IS FURTHER ORDERED that a single thousand-block of numbers with at least one
range of 100 contiguous numbers that do not begin with the number eight and wherein the
ORDER NO. 36965 3

beginning number of the range ends in 00 and the last number of the range ends with 99 should be
granted to the Company in the Coeur d'Alene rate center.
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within twenty-one (21) days of the service date of this Order regarding any matter
decided in this Order. Within seven (7) days after any person has petitioned for reconsideration,
any other person may cross-petition for reconsideration. See Idaho Code §§ 61-626 and 62-619.
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 16th day of
March 2026.
G
EDWARD LODGE, PR „ DENT
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qJR. HAMMOND IR., COMMISSIONER
DAYN HA DIE, COMMISSIONER
ATTEST:
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Commission Secretary
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ORDER NO. 36965 4