20040217_752.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
COMMISSIONER SMITH
COMMISSIONER HANSEN
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM:WELDON STUTZMAN
DATE:FEBRUARY 12,2004
RE:PETITION BY IDAHO TELEPHONE ASSOCIATION FOR A SUSPENSION
OF NUMBER PORTABILITY REQUIREMENT; CASE NO. GNR- T -04-
Section 251 (b) of the federal telecommunications act requires all local exchange
carriers to provide number portability to the extent technically feasible and in accordance with
requirements prescribed by the Federal Communications Commission.In an order issued
November 10, 2003 , the FCC requires that incumbent LECs in areas outside the largest 100
metropolitan areas implement number portability no later than May 24 2004. Section 251(f)(2)
allows local exchange carriers with fewer than 2% of the nations subscriber lines to petition a
state commission for suspension or modification of the requirements of Section 251(b).
On February 5 , 2004, a Petition was filed by the Idaho Telephone Association on
behalf of 16 of its members requesting a six-month suspension of the requirement that they
provide number portability from wireline to wireless carriers.The petition states that the
member companies are pursuing an economically and technically feasible way to provide
number portability, but that a system upgrade is required. Specifically, the companies propose to
provide number portability through shared equipment and services provided by Syringa
Networks, LLC, requiring that Syringa convert its switch to a tandem switch. The petition states
that the conversion is already underway but that it cannot be completed prior to the May 24
2004, deadline.
The ITA on behalf of the 16 companies asks the Commission to suspend their local
number portability obligation for six months, until November 24, 2004, to enable Syringa to
convert its switch and make the necessary conversion and upgrades. The petition asserts this
DECISION MEMORANDUM
solution will avoid significant adverse economic impact on users of telecommunication services
and that the suspension is consistent with the public interest, convenience and necessity.
The ITA asks that its petition for a six-month suspension of number portability
requirements be processed by Modified Procedure. Staff also recommends that the petition filed
by IT A be processed by Modified Procedure.
COMMISSION DECISION
Should the Petition filed by ITA for a six-month suspenSIOn of local number
portability requirements from wireline to wireless carriers be processed by Modified Procedure?
Weldon Stutzman
Vld/M:GNRTO401
DECISION MEMORANDUM