HomeMy WebLinkAbout03-18-2015 AT&T LTR from JdB to S Gross_Truckee Donner PUDJOHN DI BENS AT&T Services, Inc.
General Attorney 2600 Camino Ramon
Le. -al Department Room 2W901
San Ramon, CA 94583
925.543.1548 Phone
925.867.3869 Fax
jdbOatt.com
March 18, 2015
VIA E-,MAIL AND L1. S. MAIL
Steven C. Gross
Porter Simon
40200 Truckee Airport Road. Suite One
Truckee, CA 96161
Re: TDPUD March 18, 2015 Board of Director's Meeting - Action Item # 9
Establishing Fees for Third Party Attachments to Poles Owned by the District
Dear Steve:
I am writing regarding the above -reference item on the agenda for tonight's meeting of the Truckee Donner
Public Utility District Board of Directors whereby the Board will consider establishing fees for third party
attachments to poles owned by the District. AT&T pole regulatory and pricing experts have reviewed the
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methodology, as you know, and we appreciate the fact that the TDPUD have worked with us on several issues
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with the methodology and figures used to arrive at the proposed fees. However, the proposal on tonight's agenda
continues to have significant errors in the rate calculations, including the following rate components:
• Administrative Element
• Determination of the value of the poles under GASB 33
• The "Cost of Borrowing" funds to pay for poles as an annual capital cost.
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• The "Required rate of return" as an annual capital cost.
More specifically, we have found (a) there are discrepancies in the inputs used in the AB 1027 formula for
calculating administrative carrying charges and (b) TDPUD's restatement of the investment in the poles is not
adequately supported. The result is a proposed rate that is many times higher than can be supported by the
existing Federal Communiciations Commission and California Public Utility Commission methodologies.
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we very much appreciate the time and effort the TDPUD staff has spent working on this rate issue.
er. AT&T believes more needs to be done to ensure the rate is properly cost based. and thus we urge the
,to delay consideration of this rate to allow give us time to work with the staff on the remaining issues.
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cc: Barbara Cahill (via e-mail only at BarbaraCahfl d.org)
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,iobert Mescher (via e-mail only at robertr,iescherido�,id.,orLY)