The FCC adopted a process known as the "safety valve" mechanism (see FCC 01-362), whereby the states may grant requests by carriers that receive a specific customer request for numbering resources that cannot be met by the carrier's available inventory, but is denied additional numbering resources by the Pooling Administration because its inventory does not meet the FCC 6 months to exhaust (MTE) threshold and/or 75% utilization rate.

Carriers may request safety valve relief with the CPUC as set forth by the FCC.  Carriers requesting safety valve relief must demonstrate a verifiable need for additional numbering resources by providing the following documentation:

  1. Part 1A form - application
  2. Denial form from the Pooling Administrator (PA)
  3. MTE worksheet
  4. Numbering resources in the current inventory and quantity of available numbers
  5. Documentation of customer request, e.g., letter from the customer (if applicable)

Additionally, carriers must respond to the following questions

  1. What amount of numbering resources is needed by the customer in the next six months and twelve months?
  2. Does the customer currently have numbering resources?  If so, what amount of numbering resources does it already have?  Are they in the same rate center?  Are they from the same service provider?  Will they be returned after receiving the new numbering resources?  If the customer plans to return its numbering resources, will it do so within the next six months (this is preferred)?
  3. What kind of internal dialing structure does the customer currently have?
  4. Has the service provider reviewed its numbering resources categorized as Aging, Administrative, Reserved, and Intermediate before submitting the safety valve request? Are there any numbering resources from these categories that the customer can use?
  5. What prevents the customer from using numbering resources that are currently available in the service provider's inventory?
  6. Does the service provider have any 10% or less contaminated blocks in the applicable rate center? If so, how many blocks are 10% or less contaminated?
  7. Will the service provider be able to donate block(s) to the numbering pool in exchange for the block(s) requested to meet the customer's needs? If not, why not?

Submit safety valve relief requests with the required documentation and information to Joanne Leung at  A determination on a safety valve relief request is generally made within 10 business days of the receipt of the request.