20220906_FMTT2202_jk4.pdf

DECISION MEMORANDUM
TO:COMMISSIONER ANDERSON
COMMISSIONER CHATBURN
COMMISSIONER HAMMOND
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:JOHAN E.KALALA-KASANDA
MICHAEL DUVAL
DATE:SEPTEMBER 6,2022
RE:FARMERS MUTUAL TELEPHONE COMPANY FILED A PETITION
FOR A SAFETY VALVE WAIVER OF FCC THRESHOLDREQUIREMENTSFORNUMBERINGRESOURCESINFRUITLAND
AND PAYETTE,IDAHO RATE CENTERS;CASE NO.FMT-T-22-02.
BACKGROUND
On August 22,2022,Famers Mutual Telephone Company ("Farmers"or "the Company")
contacted the Idaho Public Commission ("Commission")Staff requesting that the Commission
enter an order waiving the Federal Communications Commission's ("FCC")Threshold
Numbering Resource Requirements for the Fruitland and Payette,Idaho rate centers.
On August 23,2022,Staff contacted the Company regarding its petition and instructed
the company on how to formally refile.On August 25,2022,the Company formally resubmitted
its petition to the Commission,with the proper documentation.
In the Petition,the Company asserted that it is replacing its existing Metaswitch VP3510
equipment/facilities in its Fruitland and Payette,Idaho exchanges.Because of this change,a new
Number Plan Area ("NPA-NXX")and Location Routing Number ("LRN")'are required to
establish homing arrangements for Local Exchange Routing Guide 7 Switching Homing
Arrangement information ("LERG7SHA")so the Company can order and install new trunking.2
I The NPA,or Numbering Plan Area,is commonly called the area code.The NXX refers to the three digits ofa
phone number immediately following the area code and is also called the "exchange"or Central Switching Office
Designation.The LRN,or Location Routing Number,is a unique 10-digit number used to identifya switch that
holds ported or pooled numbers.Calls to ported or pooled numbers are routed based on the NPA-NXX of the
numbers associated with the LRN.
2 The LERG provides routing data obtained from the iconectiv Business Integrated Routing and Rating Database
System ("BIRRDS")into which data is entered by service providers ("SPs")and/or their agents.
DECISIONMEMORANDUM -1 -SEPTEMBER 6,2022
Petition at 1.The Company stated once the new switch is operational,its existing customers will
be ported to it from the old switch.Id.Any unneeded 1,000 blocks will be returned to the North
American Numbering Plan Administrator ("NANPA").Id.
On August 22,2022,the Company applied through the Pooling Administration System
("PAS")of the NANPA for an LRN for the new Fruitland and Payette,Idaho switch within its
Local Access Transport Area ("LATA").NANPA's administrator,Somos,Inc.,denied the
Company's application because the Company did not meet the months-to-exhaustand/or
utilization requirements in the Thousands-Block Number Pooling Administration Guidelines3
(the "Guidelines").See Petition,Attachment A.
STAFF ANALYSIS
Federal regulations allow a carrier to appeal a NANPA decision to withhold numbering
resources.See 47 C.F.R.§52.15(g)(4)(iv)and (5).The Commission "may affirm or overturn
the NANPA's decision to withhold numbering resources from the carrier based on its
determination of compliance with the reporting and numbering resource"requirements.See
47 C.F.R.§52.15(g)(4)(iv)and (5).The Commission "also may overturn the NANPA's decision
to withhold numbering resources from the carrier based on its determination that the carrier has
demonstrated a verifiable need for numbering resources and has exhausted all other available
remedies."47 C.F.R.§52.15(g)(5).Lastly,the Company is a Title 61 regulated telephone
corporation organized under the laws of the state of Idaho and is authorized to do business in
Idaho and to provide basic and local exchange telecommunications services pursuant to a
Certificate of Public Convenience and Necessity No.305 that was issued to it by the
Commission.
After evaluating the Company's Petition,Staff believes that granting this waiver will not
have any detrimental effect on the numbering resources in the Fruitland and Payette rate centers.
Because of the Company's business need to replace the existing Metaswitch equipment/facilities,
it is reasonable for the Company to upgrade its facilities for the consumers of the Fruitland and
Payette rate centers.Staff believes that the new switch is going to improve the performance of
the two exchanges and will increase the need for additional numbers.
3 To be assigned an additional thousands-block (NXX-X)for growth,"Months to Exhaust"must be less than or
equal to 6 months.(FCC 00-104,Section 52.I5(g)(3)(iii))
DECISIONMEMORANDUM -2 -SEPTEMBER 6,2022
According to FCC orders and numbering guidelines,carriers may appeal NANPA
decisions of this nature to the appropriatestate regulatory authority.This Commission has
granted similar waivers in the past to meet similar requests of other carriers.(See Commission
Orders Nos.33976,34108,34238,34364,34501).
RECOMMENDATION
Staffrecommends that the waiver request for the full NXX-LRN be granted with the
caveat that any unused numbers be returned to the pooling administrator.
COMMISSION DECISION
Does the Commission wish to approve this Petition?
an E.Kalala-Kasanda
Udmemos/FMT-T-22-02 Decision Memo
DECISION MEMORANDUM -3 -SEPTEMBER 6,2022