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HomeMy WebLinkAbout4 Wireless Network 5a r � aF a Staff Report To: Board of Directors From: Alan Harry, Director of Telecommunications Services Date: October 11, 2002 Subject: Pros and Cons of a Wireless Network On October 2"d, after hearing a presentation of Wireless Telecommunications Services, the Board directed me to prepare a brief"pro and con" report for your review, and possible discussion at your October 160 Regular Meeting. As such, I have summarized information below. In order to provide the Board with information pertinent to the October 2"d presentation I have used information received from Mr. Devin Koch for the "Pros", and information received from Mr. James Salter as the "Cons". As an introduction, Mr. Koch is the President and C.O.O. of CLOUDX, a new wireless telecommunication venture in the Truckee Tahoe region, and the presenter of the wireless report on October 2Id, and Mr. James Salter, P.E., is President of Atlantic Engineering Group. I received Mr. Salter's information at a session entitled "Making the Right Decision: How to choose between HFC, FTTH and Wireless", held at the recent APPA Community Broadband Conference. During that session equal time and weight was given to each technology. BANDWIDTH Pro—Wireless won't be the bottleneck in delivering bandwidth. With 802.11 a which is now commercially available and within a month or so can be inside our antenna/routers, we will have the ability to transport almost 54 megabits per second between homes or the equivalent of 36 T-1 lines. We will be able to carry packetized (streaming) video over our network as easily as any other. It's just not yet implemented over commercial wireless networks yet. Con —Wireless Bandwidth, Capacity, is limited by Physics. You may be able to send out 54Mbps, however the last user in line may receive speeds that are equal to the telegraph. 0 Page 1 Con — Unlike Multicast Video, Streaming video requires the use of bandwidth for each user watching video programming. That means that if one household had 2 television sets, and were watching both of them, that household could use up to half of the bandwidth available to the area being served. Con —The Wireless Spectrum is subject to politics. Congress can give and Congress can taketh away. Con — It is estimated that up to 40.064 Mbps will be required for Voice, Video and Data services in the coming years. Wireless will not be capable of guaranteeing the provision of that much Bandwidth to each user. Especially at an economical cost. SECURITY Pro— "Security: You can find lots of people who say that wireless networks are insecure just like you can find lots of people who say the earth is flat. If you don't want to believe it you can't be made to. The president of Intel is our first client. His information is VERY valuable to him and to Intel yet it runs across lake Tahoe, twice, on our network. There are lots of stories and every one I've ever seen are about networks that have not been built or configured correctly. Con —Wireless systems are easy to "hack". Recently articles have been written about the young people who used Pringles Potato Chip cans as antennas to get on a 802.11 wireless system. Con — Medical Institutions will not use a wireless Broadband system due to the inability of service providers to guarantee the security of the systems. CLIMATE, GEOGRAPHY AND FOLIAGE Pro - Radio signal doesn't penetrate water or metal well. Rain and falling snow, however, do not impact these antennas over the short distances we are transmitting -- and actually not even over the long distances we are transmitting (up to 15 miles) to deliver bandwidth to neighborhoods. Build-ups of snow and ice on the antennas can impact them. After one year of running antennas on people's homes in Tahoe Donner however, I believe there was not one instance of an antenna problem as a result of snow or ice. There are some homes that would be difficult to serve and, as a matter of fact, it may be these homes that are the first you would want to serve by cables instead of wireless. Trees do impact signal strength and we have to plan for trees when we install an antenna - not a problem, just a consideration. Con —Wireless systems are sensitive to weather, hills, valleys and foliage. In many heavily forested areas problems occur. Oak trees have not been found to be the cause, however Pine trees, especially wet Pine trees have. Studies have been conducted to ascertain why this is the case and have discovered that a needle from a Pine tree 0 Page 2 carries the same frequency as many of the 802.11 wireless systems in use today, thus interfering with clear transmission. In general, I have found that Wireless technology is quite appropriate to deliver residential Data services, especially in areas that have an unmet need. Systems that have been deployed over the last 24 months have been economical to build and operate, and deliver only Data services. Service level reliability has been an issue. Cellular phone service in our region is an excellent example. In that the District has been evaluating the provision of Video, Data and possibly Voice services to it's customers, a wireless technology has had cursory evaluation due to its inability to provide all services to all customers in a secure, equal manner. Mr. Koch has provided me with two proposals for the use of wireless technology in place of FTTH. It is my recommendation that the District thanks Mr. Koch for his input, and advises him of its plans to continue on the path of providing services over a FTTH infrastructure. • Page 3 Agenda Item # 4qb Memorandum To: Board of Directors From: Alan Harry, Director of Telecommunications Services Date: October 11, 2002 Subject: Consideration of an agreement for services related to the sale or lease of District owned conduit On October 2°d I submitted to the Board for consideration an Agreement with Aggregate Network for the Brokerage of District owed "conduit. As part of the Williams Communication project, completed approximately two years ago, the District was to receive 16.5 miles of two 2" conduits. In May of this year the District received a Bill of Sale from Williams, deeding over the conduit to the District. At the meeting the Board directed me to seek input from additional parties so as to compare experience and compensation. Staff has advertised such a request in the Sacramento Bee and Reno Gazette-Journal and has not received a response. In the past when the District required assistance of an outside contractor, and at that time was utilizing the services of a contractor that held the expertise necessary to conduct the additional work, the District added the additional work to the contractors scope of work. In that the District has not received a response form the ads placed, and that Aggregate Networks has the expertise needed to market and negotiate the sale of District owned conduit, it is staffs recommendation that the Board direct its General Manager to approve the attached Brokerage Agreement, approved by Legal Counsel, for the sale and or lease of a portion of the District's Broadband Conduit. • Page 1 Brokerage Agreement This Brokerage Agreement (the "Agreement"), dated this day of September 2002 is entered into by and between the Truckee Donner Public Utility District ("TDPUD"), and Aggregate Networks, LLC, an Illinois limited liability company ("Aggregate"). TDPUD and Aggregate may hereinafter be referred to individually as a "Party", or collectively as the "Parties". Recitals WHEREAS, the TDPUD is the owner of certain facilities, which include certain conduit, ducts, manholes pull boxes and splice cases (collectively the "Facilities") which were obtained from Williams Communications, LLC, d/b/a Vyvx, Inc. in California, which cover lands extending approximately sixteen and one half (16.5) miles along the route in Truckee, California described and depicted in Exhibit attached hereto (the "Route"). WHEREAS, Aggregate is in the business of brokering, structuring and negotiating transactions to lease, sell, swap or provide indefeasible rights of use (IRU's) of conduit(s), duct(s), and dark and lit fiber. WHEREAS, the Parties desire to set out their rights and obligations with respect to the disposition of some or all of the TDPUD's assets along the Route. NOW, THEREFORE, in consideration of the foregoing premises, the mutual promises of the Parties and other good and valuable consideration, the receipt and sufficiency of which being hereby acknowledged, each Party consents to Aggregate being appointed the exclusive Broker of Record for the disposition of the Facilities under the conditions set forth herein: TERM The term of this Agreement shall be for six (6) months from the date of execution. If negotiations, evidenced by written documentation, involving the Facilities have commenced during the Initial Term and are continuing at the time that the Initial Term would otherwise expire, then the Term shall be automatically extended until the earlier of: 1) the termination of such negotiations or the consummation of the transaction, or 2) ninety (90) days from the date of the original expiration of the Initial Term, as indicated above. Either Party shall have the option to terminate this Agreement after ninety (90) days from commencement of this Agreement, upon fifteen (15) days written notice to the other. The term "transaction" as used herein shall include any arrangement acceptable to the TDPUD which grants to a third party the right to purchase, lease, IRU, use, occupy, possess, swap, or barter for some or all of the Facilities. SERVICES Aggregate shall perform the following services on behalf of the TDPUD: 1) Assessment of the Network Assets to be disposed of 2) Definition of which Network Assets are to be disposed of 3) Marketing of the Network Assets to the appropriate parties 4) Conduct negotiations with interested parties 5) Structuring the transaction(s) 6) Facilitating and finalizing the transaction(s) 7) Any other services reasonably necessary to close the transaction(s) COMPENSATION TO AGENT TDPUD agrees to pay Aggregate a fee in accordance with the Fee Schedule attached hereto as Exhibit A, under the following circumstances: a) The Network Assets or any part thereof is leased, sold, IRU'd, swapped, used, occupied or bartered for prior to the expiration of the Initial Term as a result of Aggregate's efforts; or b) Within ninety (90) days after the expiration of the Term, or if a Transaction is consummated beyond the ninety (90) day period with a party Aggregate had already negotiated with during the Initial Term, either: 1) the Network Assets or any part thereof is transferred to any person or entity with whom Aggregate has negotiated regarding the Network Assets, or: 2) TDPUD enters into any negotiations which lead to the execution of a Transaction within ninety (90) days after the expiration of the Initial Term to any person or entity previously negotiating with Aggregate. ADDITIONAL PROVISIONS a. Cooperation With Agent. TDPUD agrees to provide Aggregate with any and all information reasonably necessary to consummate the proposed transaction. In addition, TDPUD agrees to refer to Aggregate all inquiries of any party interested in obtaining some or all of the Network Assets. b. Independent Contractor. Aggregate is and shall remain at all times an independent contractor. It shall be the sole responsibility of Aggregate to pay any and all expenses, taxes, fees and wages of its employees or agents who participate in any way in the disposition of the Network Assets, unless specifically agreed to in writing by the TDPUD. 2 C. Assignment. Aggregate shall not have the right to assign its rights or delegate its duties under this Agreement unless consented to by TDPUD. Aggregate shall have the right, upon reasonable notice, to assign, convey or otherwise transfer its rights, title, interest and obligations under this Agreement to any entity controlled by, controlling or under common control of Aggregate, or any entity which Aggregate may be merged or consolidated or which purchases all or substantially all of the assets of Aggregate. d. Notices. Any notice of communication to be given relating to this Agreement shall be given by personal delivery in writing, nationally recognized overnight carrier, or by United States Mail, registered or certified, postage prepaid with return receipt requested. Mailed and overnight carrier notices shall be addressed to each party at the addresses set forth below: If to TDPUD: Truckee Donner Public Utility District 11570 Donner Pass Road P.O. Box 309 Truckee, CA 96160 Attention: Alan Harry If to Aggregate: Aggregate Networks, LLC 650 Warrenville Road, Suite 103 Lisle, IL 60532 Attention: Laurance Lewis e. Time. Time is of the essence in this Agreement. f. Successors. The terms and conditions of this Agreement shall be binding on the heirs, successors and assigns of the parties hereto. g. Governing Law & Venue.This Agreement shall be governed and construed in accordance with California law. Any action or arbitration arising out of this Agreement shall occur in, or any claim brought in, Nevada Count, CA. h. Entire Agreement. Each of the Exhibits to this Agreement is incorporated into this Agreement in its entirety by this reference as if set forth in full. This Agreement constitutes the entire agreement between the parties and supercedes any prior oral agreements. No amendment, modification, or extension of this agreement shall be binding unless made in writing and signed by both Parties. 3 The undersigned Parties hereby agree to all of the terms and conditions of this Agreement and of said Fee Schedule. Executed as of the date first written above. Truckee Donner Public Utility District By: Its: Date: Aggregate Networks, LLC By: Its: Date: 4 EXHIBIT A Commission Schedule Upon successful completion of a transaction or transactions, Aggregate shall have earned and be entitled to receive a commission equivalent to four percent (4%) of the total value received* by the Sublessor**. The fee is to be paid as follows: i. If the Transaction is a purchase or a lump sum IRU, then the entire four percent (4%) fee shall be paid to Aggregate out of the closing proceeds. ii. If the Transaction involves a lease or an IRU with scheduled payments, then Aggregate shall be paid four percent (4%) of the total lease or IRU obligation upon execution of the contract. The Sublesee shall be responsible for depositing an amount equivalent to the 4% fee in escrow prior to execution of the contract. In the event the Transaction is a lease or IRU with renewal options, then Aggregate shall be paid a commission equivalent to 4% of the total value of the exercised option, payment shall be made to Aggregate at the time written notice from the Sublessee is given to Sublessor of its intent to renew. iii. In the event the Transaction is a swap or barter where no actual monies are required to change hands, then the Sublessee shall be required to deposit an amount equivalent to the 4% commission payable to Aggregate upon execution of the contract. The Sublessor may then credit the Sublessee back for this amount in Network Assets or services, at the Sublessor's sole discretion. Sublessor shall also have the option of paying the 4% commission directly to Aggregate upon execution of the agreement. * Total Value Received is defined as the total amount of the benefit derived by the TDPUD from the Transaction. In the event of a barter or swap, the value received by the TDPUD would be equivalent to what those products or services received would cost on the open market. That value will be determined by obtaining quotes from reasonably similar companies offering reasonably similar products or services in the Truckee region. If available, a minimum of two quotes for similar products or services will be obtained, and the assigned value will be the average of the two quotes. If no agreement can be reached by the Parties as to the Total Value Received within 30 days from execution of the Transaction Agreement, then each party hereto agrees to submit to binding arbitration, by a neutral third party regarding the Total Value Received. ** Under the Co-Occupancy Agreement between TDPUD, Williams, 360 Networks, and Sierra Touch America, any transfer of the Network Assets is deemed to be a Sublease. SAJERS ENGINEERING ES0 2SS 6S34 10/10J02 04:04pm F. 001 A leyl do -* 4e. San.ers Fn.gineering, Inc. Civil & Environmental Engineers Memorandum October 10, 2002 TO: Board of Directors FROM: Keith Knibb, Consulting Engineer SUBJECT: FIBER OPTIC INSTALLATION PROJECT- CEQA REVIEW As of October 10, 2002, the California Environmental Quality Act (CEQA) review period is closed for the Fiber Optic Installation Project negative declaration. Two comment letters were received during the comment period. The Board of Directors is held a Public Hearing on September 18, 2002. No comments were received during the public hearing. Along with this memo are the final documents for the CEQA environmental review. The final CEQA documents included with this memo are: ► Comments and Responses ► Final Negative Declaration ► Notice of Determination ► Department of Fish and Game Certificate of Fee Exemption RECOMMENDATIONS I recommend the Board of Directors take the following actions: P. Adopt the Final Negative Declaration. ► Approve the project for purposes of CEQA. ► Authorize the filing of the Notice of Determination with the Office of the Nevada County Clerk, the Office of the Placer County Clerk, and the Governor's Office of Planning and Research. ► Adopt the De Minimis Impact Finding and authorize the filing of the Certificate of Fee Exemption with the Nevada County Cleric. ► Adopt a finding that the draft documents as circulated and the negative declaration reflect the District's independent judgement. SAUERS ENGINEERING SS0 266 6S34 10/10/02 04:04pm P. 002 Truckee Donner Public Utility District Fiber Optic Installation Project COMMENTS AND RESPONSES The following are responses to comments received during the circulation and review of the proposed negative declaration and initial study for the Fiber Optic Installation Project." Copies of each of the comment letters are attached. Letter from Placer Local Agency Formation Commission dated September 17, 2002: Comment: Although this action may affect Placer County,the activation of latent power comes under the jurisdiction of Nevada LAFCO. Response: Comment acknowledged. No response necessary. Letter from Department of Toxic Substances Control received October 7, 2002: Comment: After reviewing our hazardous substance database (Calsites), we have identified five sites in the immediate area(list enclosed). DTSC recommends that if any of the installation work requires digging around these locations that proper precautions to protect the public and workers be taken. Response: The areas identified on the Calsites list are currently served by overhead wire utilities. These areas are proposed to be served broadband by overhead fiber optic cable. Therefore, no digging is expected in these areas. SAVERS ENGINEERING S50 28S 6854 10f10/02 04:04pm P. 008 PLACER LOCAL AGENCY FORMATION COMMISSION 175 Fulweiler Avenue, Auburn, California 95603 530,889.4097 FAX: 530,886.4671 DATE: September 17, 2002 TO: Truckee Donner Public Utility District FROM: Deborah Cubberley, LAFCO Executive Officer SUBJECT: TDPUD Activation of Fiber Optic Powers Thank you for the opportunity to review this action. Although this action may affect Placer County, the activation of this latent power comes under the jurisdiction of Nevada LAFCO. SAUERS ENGINEERING 580 2S5 6684 10/10/02 04:04pm P. 004 Oct-09-2002 12.53pn From-TRUCKEE DONNER PUD +530567i199 T-576 P OD2/004 F-669 Department of Toxic Substances Control Edwin F. Lowry, Director 88D0 Cal Center Drive Winston H. Hickox Sacramento, California 95826-3200 Gray Davis Agency Secretary Governor California Environmental Protection Agency Mr. Peter L. Holzmeister General Manager Truckee Donner Public Utility District P.O. Box 309 Truckee, California 96160-0309 ENVIRONMENTAL INITIAL STUDY/NEGATIVE DECLARATION FOR FIBER OPTIC INSTALLATION PROJECT, TRUCKEE, CALIFORNIA (SCH #1999092032) Dear Mr, Holzmeister: , The Department of Toxic Substances Control (DTSC) has reviewed the document referenced above and has the following comment_ After reviewing our hazardous substances site database (Calsites),we have identified five sites in the immediate area (list enclosed). DTSC recommends that if any of the installation work requires digging around these locations that proper precautions to protect the public and workers be taken. DTSC has not done an evaluation to determine whether any of these sites could impact the subject project, DTSC had-referred these sites to the Lahontan Regional Water quality Control Board (LRWQCB) prior to the mid-1990s. LRWQCB has also been sent a copy of this document. If you have any questions, please contact Mr. Tim Miles at (916) 255-3710 or by email at tmiles disc ca gov, Sincerely, Megan Cadge, Chief Expedited Remedial Action Program Unit Enciosure cc: See next page. The energy chadanQe fidng C201fria Is real, Every cwiternien needs to take irnmediate acebn to redeae energy cvnsumpgon. Fora list of aimpAs ways you can mduto domaind and out your energy casts.see our Weo-sltn ar wwwdlac.ca.vov. a Printed an Recycled Paper SALTERS ENGINEERING S90 2SS GBa4 10/10/02 04a04pm P. 006 Oct-08-20OZ 12=53pm From-TRUCKEE DONNER PUD +53058T1180 T-576 P 003/004 F-86a 1 .Y1]/MJfj Mr. Peter L. Holzmeister Page 2 cc: Planning & Environmental Analysis Section (PEAS) CEQA Tracking Center 1001 "I" Street, 22nd Floor P.O. Box 806 Sacramento, California 95812-0806 Ms, Gregoria Garcia State Clearinghouse Office of Planning and Research 1400 10th Street, Room 121 Sacramento, California 95814.0613 Lahontan Regional Water Quality Control Board Attention: CEQA Review 2501 Lake Tahoe Boulevard South Lake Tahoe, California 96150 Mr. Tim Miles Hazardous Substances Scientist Expedited Remedial Action Program Unit Northern California-Central Cleanup Operations Branch Department of Toxic Substances Control 8800 Cal Center Drive Sacramento, California 95826-3200 P 0 y 10/Ol/02 CALIFDRNLA ERVIROMMIAL.FROTBCWM AGERCY PAGE 1 DEPARTMENT OF TOEICS M521SCES CORTROL CALSITES SHORT SUMMARY REPORT 6IY " R m sm RARE SITE ADDRESS SITE CITY CODE )IDND11 STATUS a w D 1 29 SEANEVA 10655 SwmvA ROAR TRMIXXE 95134 2916000/ BZMH m 1 29 MRTRSON AM URRCRIR❑ YARD 11036 NEST RIVER &MET `TUCKER 95734 292/0507 EE£RN � N 1 29 TRUCKER SOUTHERN PACIFIC ROUNDHOUSE EAST OF CORNER OF SCEDDL AND CEURCR STE TRUCKEE 95734 29400DOI REMN y 1 29 EIRSCSDALE AUTO NREC M OLD HIGM&Y 44 NEAR UIRSCRDALR TRUCKER 95134 2950DOO2 R.SvRH m m 1 29 TAYLOR'S TIES FACILITY 11464 DDUMRR PASS ROAD TAUCKRR 95134 297SUD66 REPHA m Z m m m TOTAL RUMRER OF RECORDS FOR TRLS REPORT - 5 Z a G) c UI w D 01 w N m w w a m µ V to 0 b � b o l] ❑ � m 0 O7 SAUERS ENGINEERING 630 26S 8834 10/10102 04:04pm P. 007 NOTICE OF DETERMINATION To:_ Office of Planning and Research P.O. Box 3044 From: Truckee Donner PUD 1400 Tenth Street,Room 121 P.O. Box 309 Sacramento, CA 95814 Truckee,CA 96160-0309 X County Clerk County of Nevada 201 Church Street Nevada City,CA 95959 Subject: Filing of Notice of Determination in compliance with Section 21108 or 21152 of the Public Resources Code. Fiber 012tic Installation Project Project Title 1999092032 Peter L. Holzmeister (530)587-3896 State Clearinghouse Number Responsible Agency Area Code/Telephone Contact Person Truckee Nevada County and Placer County --- Project Location(include county) Project Description: Construction and operation a network of fiber optic cables along with electronic equipment to provide broadband telecommunications services for the District's existing water and electric facilities and for residential, commercial, and public agency customers. This is to advise that the Truckee Donner Public Utility District has approved the described project on Oct 16,2002 and N Lead Agency ❑ Responsible Agency Date has made the following determinations regarding the above described project: 1. The project[❑will Nwill not]have a significant effect on the environment. 2. ❑ An Environmental Impact Report was prepared for this project pursuant to the provisions of CEQA. X A Negative Declaration was prepared for this project pursuant to the provisions of CEQA. 3. Mitigation measures [❑were 0 were not]made a condition of the approval of the project. 4. A statement of Overriding Considerations[❑ was ® was not]adopted for this project. 5. Findings [N were ❑were not] made pursuant to the provisions of CEQA. This is to certify that the Negative Declaration with comments and responses and record of project approval is available to the General Public at: Truckee Donner Public Utility Dist. P.O. Box 309 11570 Donner Pass Road Truckee CA 96160-0309 Peter L. Holzmeister,General Manager Date DFG Fee $ 0.00 Date received for filing at OPR: SAUERS ENGINEERING 680 26S 6854 10/10/02 04;04pm P. 005 NEGATIVE DECLARATION ( ) Proposed ( X) Final NAME OF PROJECT: Fiber Optic Installation Project LOCATION: Truckee, California Entity or Person Undertaking Project: (XX) Truckee Donner Public Utility District It 570 Donner Pass Road P.O. Box 309 Truckee, CA 95959 Other( ) Name: Address: Phone: PROJECT DESCRIPTION: Construction and operation a network of fiber optic cables along with electronic equipment to provide broadband telecommunications services for the District's existing water and electric facilities and for residential, commercial, and public agency customers. Finding: It is hereby found that the above named project will not have a significant effect upon the environment. Initial An initial study of this project was undertaken and prepared in accordance with Article V Study: of the District's local environmental guidelines and Section 15063 of the EIR Guidelines for the California Environmental Quality Act for the purpose of ascertaining whether this project might have a significant effect upon the environment. A copy of such initial study is attached hereto and incorporated herein by reference. Such initial study documents reasons to support the above finding. Mitigation The following mitigation measures have been included in the project to avoid potentially Measures: significant effects: None. Date: By: Peter L. Holzmeister, General Manager SAUERS ENGINEERING 530 255 SBS4 10/10/02 04:04pm P. 009 CALIFORNIA DEPARTMENT OF FISH AND GAME CERTIFICATE OF FEE EXEMPTION De Minimis Impact Finding Project Title/Location, Name and Address of Project Proponent (including county): Fiber Optic Installation.Project, Truckee, Nevada County and Placer County. Truckee Donner Public Utility District P.O. Box 309 Truckee, Nevada County, CA 96160-0309 Project Description: Construction and operation a network of fiber optic cables along with electronic equipment to provide broadband telecommunications services for the District's existing water and electric facilities and for residential, commercial, and public agency customers. Findings of Exemption: An initial study has been conducted by the Truckee Donner Public Utility District so as to evaluate the potential for adverse environmental impact. When considering the record as a whole there is no evidence before the Truckee Donner Public Utility District that the proposed project will have potential for an adverse effect on wildlife resources or the habitat upon which the wildlife depends. The Truckee Donner Public Utility District has, on the basis of substantial evidence, rebutted the presumption of adverse effect contained in Section 753.5 (d) of Title 14, Code of California Regulations. Certification: I hereby certify that the Truckee Donner Public Utility District has made the above findings of fact and that based upon the initial study and hearing record the project will not individually or cumulatively have an adverse effect on wildlife resources, as defined in Section 711.2 of the Fish and Game Code. Peter L. Holzmeister Title: General Manager Lead Agency: Truckee Donner PUD Date: Truckee Donner Public Utility District Fiber Optic Installation Project REVISED COMMENTS AND RESPONSES (Reprised 10-15-02) The following are responses to comments received during the circulation and review of the proposed negative declaration and initial study for the Fiber Optic Installation Project." Copies of each of the comment letters are attached. Letter from Placer Local Agency Formation Commission dated September 17, 2002: Comment: Although this action may affect Placer County, the activation of latent power comes under the jurisdiction of Nevada LAFCO. Response: Comment acknowledged. No response necessary. Letter from Department of Toxic Substances Control received October 7, 2002:_ Comment: After reviewing our hazardous substance database(Calsites), we have identified five sites in the immediate area (list enclosed). DTSC recommends that if any of the installation work requires digging around these locations that proper precautions to protect the public and workers be taken. Response: The areas identified on the Calsites list are currently served by overhead wire utilities. These areas are proposed to be served broadband by overhead fiber optic cable. Therefore, no digging is expected in these areas. Potential impacts associated with work in areas identified in the hazardous substance database is considered less than significant. Letter from Colin Gilboy,PE dated October 7, 2002: Comment: This letter contains a lengthy discussion of the District's business plan, types of services to be made available, marketing issues, and broadband technologies. Comments relevant to the CEQA environmental review are summarized on page three of the letter under Summary Item 1. The PUD Broadband Proposal will have substantial economic impact on existing local businesses, and uses public money and public borrowing capacity to enter a market sufficiently served by private companies. Response: Most of the items discussed in the letter are considered outside of the scope of the CEQA environmental review. Issues associated with the District's marketing plan, assumptions 1 8 made in the business plan, cost of services, estimates of market share, and public agency involvement in broadband services are all considered outside the scope of this review. Economic impacts are a consideration under CEQA, however, CEQA focuses on physical changes to the environment associated with the economic effects of a project. Economic effects of a project shall not be treated as significant effects on the environment, according to the CEQA Guidelines. Economic effects of a project may be used to determine the significance of physical changes caused by the project. The comment letter offers no substantial evidence that the economic effects of the project will result in any significant changes in the environment. Physical changes in the environment associated with the economic effects of the project are considered less than significant. 2 r Colin 1l PE 10581 Heather Road Truckee CA 96161 FAX: 530.579.3202 Colin@4specs.com call me at: 530.582.8008 Or;T Uu�� October 7, 2002 _ TO: Truckee Donner Public Utility District cc: Sierra Sun Editor Sauers Engineering, Inc. Town of Truckee RE: Initial Environmental Study for Broadband Gentlemen, I missed the September 18' meeting as I had other plans that evening and could not attend. I disagree with the findings in this EIR that there will be minimal impact of the Broadband Project. I propose that Item XIIb must be changed from "Less than Significant" to "Potentially Significant Impact." The EIR states that: Construction of the fiber optic cable system and provision of the broadband telecommunication services will not affect the listed utilities. I have no financial relationship with Pacific Bell or USA Media other than as a paying subscriber. I propose the following: 1. It is inappropriate for a public agency, using public agency money, to enter into competition with existing suppliers of the same service provided by privately held companies. Not only will the PUD be competing with existing suppliers, but also competing with local dealers selling and installing satellite cable and Internet equipment. The Broadband Proposal may even be against your charter requiring that profits be returned to the ratepayers. The PUD profits should not be spent in litigation and or invested in new business ventures where there are already reliable and competent suppliers of these communication needs. 11 know of no complaints about the cable TV services provided by USA Media. I know of no complaints about the high-speed Internet access provided by PacificBell through their DSL and faster lines. Most of the few complaints about the USA Media cable modem service will be resolved by their upgrade to 2-way cable Internet from the telco-return system in use now. 3. Using the May 2001 PUD business plan, by the middle of the third year, the first year of profitability, the PUD projects having 3,822 cable TV subscribers. In my opinion, the PUD projection calls for an unrealistically high number of cable-tv subscribers to use the PUD service. Further, to reach this number of subscribers, the PUD will significantly reduce the revenues of the existing suppliers, and may cause layoffs through staffing reductions. 4. As there is virtually no TV in Truckee from an antenna, of the estimated 10,000 potential homes, Truckee has a high cable TV penetration estimated to be about 80% for cable TV plus another 15% for satellite TV subscribers. There is only an estimated 5% non-subscribers, primarily for second homes used on an infrequent basis. I project the current TV access market share to be: USA Media - 8,000 subscribers Satellite TV - 1,500 No TV - 500 Total Homes - 10,000 The PUD cannot achieve the required market penetration projected (and required for profitability) from new home construction alone. The PUD will need to convert existing customers and new residents to their cable-tv service. The end result, if the PUD meets the projections in their business plan in the third year, this is the probable market shares: PUD - 3,822 subscribers USA Media - 5,000 Satellite TV - 1,188 No TV - 500 Total Homes - 10,500 For USA Media to lose 3,800+ customers can only be considered as a major economic impact on the current cable TV provider and not the "will not affect listed utilities" appraisal in the EIR. 5. A similar case can be made for the broadband Internet access. To have 25% of the homes in Truckee as $40 per month broadband subscribers is unrealistically high, and is above many optimistic projections for total broadband usage by residences in 3 years. This does not consider that the 25% will be divided among 4 providers - PUD, USA Media, PacBell and satellite. I expect that the majority of the local businesses and home-based offices already have either high-speed connectivity from Pacific Bell through ISDN (or faster connections) or the USA Media cable Internet system or a direct connection through an Internet supplier such as UUNet. The next group of high-speed Internet users will have to come from residences where cost plays an important role in decisions. While some cable systems are providing a restricted-access Internet program for around $20 per month to be competitive with dial-up services, this type of offering has significantly reduced income potential from these users combined with high-support costs. v . USA Media currently has about 400 high-speed Internet access subscribers after 2 years. I would expect this increase to 1,000 or so once USA Media upgrades their telco-return system to full-time two-way access over the next 12 months. This is about the time that the PUD's system will go online, and the PUD will have to convert users to their system. 6. Much of the projected PUD SCADA savings can achieved by leasing fiberoptic lines from USA Media or Pacific Bell, or the PUD can string a limited amount of fiber optic for their own use if that is more economical. 7. The PUD proforma business plan projects$137,000 in advertising revenues from broadband for the third year. I must question where this advertising is going to come from. Most Internet businesses are having difficulty in selling Internet advertising, and where is the PUD going to display these ads. I sell advertising on the Internet and am very familiar with the problems and rates. Summary: 1. The PUD Broadband Proposal will have a substantial economic impact on existing local businesses, and uses public money and public borrowing capacity to enter a market sufficiently served by private companies. 2. The PUD's business plan has unrealistically high projections for number of subscribers for both cable TV and high-speed Internet access. 3. I propose that the PUD be required to make a detailed market study of the conversion of Truckee's existing customers to their service. The expenditure of $100,000 (or even $250,000) for a detailed survey would not be inappropriate for a $14 million project. A survey costing $10-25 per household will prove or disprove the viability of the PUD's business plan and the impact on existing businesses. This study must include identifying, and getting commitments, from local business for the $550 per month ethernet subscriptions. 4. Before starting the survey, I propose that the survey questions and methods be reviewed by the existing competitors (Pacific Bell, USA Media and a satellite TV provider) to reduce any pro-PUD bias of the questions and methods which could distort the survey results. Sincerely, Colin Gilboy, PE 7