20040607_859.pdf

DECISION MEMORANDUM
TO:CO MMISSI 0 NER KJELLAND ER
COMMISSIONER SMITH
CO MMISSI 0 NER HANSEN
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:DOUG COOLEY
DATE:JUNE 2, 2004
RE:QWEST'S APPLICATION FOR WAIVER TO ACQUIRE NEW
NUMBERING RESOURCES IN MERIDIAN. CASE NO. QWE-04-10.
BACKGROUND
On May 24, 2004, the Commission received a request for a waiver from Qwest Corporation
following denial of their Application filed with Neustar, the North American Numbering Plan
Administrator (NANP A). In the earlier Applications to NANP A, Qwest requested a new NXX
central office code (10 000 telephone numbers) to meet the requirements of a Qwest customer in
Meridian, Idaho.
On May 4, 2004, Qwest submitted an automated central office code (NXX) assignment
request to Neustar to obtain a dedicated NXX to meet the demands ofCitigroup s new customer
call center served by Qwest in Meridian. Citigroup requested a full NXX for use as a code for its
Dedicated Direct Inward Dial service. Qwest's Application was denied because it did not meet the
months-to-exhaust (MTE) criteria of 6 months as set forth in the NANP A's guidelines for each rate
center. In the Meridian rate center, Qwest's numbering resources would exhaust in approximately
8 months.
Qwest asserts that NANP A's denial impedes its ability to serve its customers within the
state of Idaho.
STAFF ANALYSIS
Qwest participates in thousand-block-pooling in the Meridian rate center. While methods
such as pooling and rate center consolidation help make number conservation efforts more
DECISION MEMORANDUM JUNE 2, 2004
effective, they are designed to extend the time it takes to exhaust (MTE) a rate center s number
resources. Further, Staff does not believe granting the requested waiver will result in an
inefficient use of Idaho s numbering resources. According to FCC orders and numbering
guidelines, carriers can appeal NANP A decisions of this nature to the appropriate state
regulatory authority. 1 The Commission has granted similar waivers in the past to meet the
requests of large customers. (See Order Nos. 28769 and 29279.
RECOMMENDATION
Staff recommends that the request for waiver sought by Qwest Corporation be granted so
that the Company can serve the specific needs of Citigroup. Staff also recommends that Qwest
continue to follow FCC numbering guidelines by assigning numbers in 1 000 blocks as demand
requires before opening new 1 000 blocks within an assigned prefix. Further, Staff recommends
that Qwest remind its customer that unused 1 000 blocks will be returned to the NANPA within
six months.
COMMISSION DECISION
Should the request for waiver from Qwest Corporation be approved?
i:udmemoslcitigroup waiver memo
Number Optimization Order. CC Docket No. 99-200 and 96-, FCC 00-104, reI. Mar. 31 , 2000.
DECISION MEMORANDUM JUNE 2, 2004