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HomeMy WebLinkAboutCUP 154C; Pacific Bell Expansion; Conditional Use Permit (CUP) (10)WRY 13 '96 09:57FIM 415 974-1099 - P. 2/18 .. Before the @Q&?Ft) FEDERAL COMMUNICATIQNS COMMISSION 4.. Washington, D.C. 20554 In the Matter of 1 Expanded Interconnection with ) CC Docket No. 91-141 Local Telephone Company Facilities ) 1 PETITION FOR EXEMPTION FROM PHYSICAL COLLOCATION REQUIREMENT AND FOR WAIVER OF VIRTUAL COLLOCATION REQUIREMENT I. INTRODUCTION Pacific Bell petitions the Commission for an exemption for our Carlsbad 12 (CRLSCA12) central office from the requirement that we provide physical collocation in response to a bona-fide request.' waiver of the requirement that, in lieu of physical collocation, we provide virtual collocation in that central office. there is a lack of available space in our Carlsbad 12 central office for either form of collocation. We request the exemption and waiver until December I, 1996, by which time we plan to have built an additional building for this central office. We also petition for a There is goad cause to grant our petition because ' Expanded Interconnection with Local Telephone Company Facilities, CC Docket No. 91-141, Memorandum Opinion and Order, El FCC Rcd. 127, para. 16 (1992). WY 13 '96 69:58FH1 415 974-1699 4 P. 3/10 This is the first time that Pacific Bell has requested an exemption or waiver of the collocation requirements.2 We have not petitioned for exemptions or waivers concerning any of our initial subset of central offices, and we have tariffed expanded interconnection service for all of them. we have added additional central offices to our expanded interconnection service in order to meet bona fide requests for physical collocation. Today we are filing tariff On three occasions prior to today, materials to add six additional central offices to our expanded interconnection service in order to meet bona fide requests for physical collocation in those offices. One of those six central offices is Vista 12, which is less than six miles from Carlsbad 12.3 We, however, are unable to meet the request for physical collocation in our Carlsbad 12 central of€icef4 or to substitute virtual collocation, because there is no space available in that central office for transmission equipment for use by collocators. The Commission has granted exemptions and waivers of the physical and virtual collocation requirements to other Tier 1 LE& based on a lack of available sfice. *, e.g., Expanded Interconnection with Local Telephone Company Facilities, CC Docket NO. 91-141, Memorandum Opinion and Order, 8 FCC Red. 4569 (1993). Pacific Bell has three other central offices that are less than six miles from Carlsbad 12, including Carlsbad 11. These are not initial collocation Offices, and we have not received bona fide requests for collocation in these offices. Carlsbad is in Southern California on the San Diego area coast. 2 MQY 13 '96 89:58FIM 415 974-1899 P. 4/18 11. WE CANNOT PROVIDE PHYSICAL OR VIRTUAL COLLOCATION UNTIL WE ADD A NEW BUILDING Our Carlsbad 12 central office has about 9,480 square feet of space. occupied by our transmission equipment, switching equipment, distribution frames, vaults, maintenance control center for switching operations, power service modules and batteries, facility maintenance administration area, mechanical room (generator and heating and plumbing equipment), administrative offices, aisles, and restroom facilities. About 8,142 of those square feet are The remaining 1,338 square feet are unavailable for physical or virtual collocation. This space is unavailable because of the unique nature of the central office. The office is composed of three interdependent parts. The first part consists of five adjoining trailers. The second part consists of a concrete slab, with walls and a roof, that was added next to the trailers. consists of a building that was added next to the concrete slab. We plan to add a new building by the end of 1996 which will be adjacent to the existing building and will replace our use of the trailers and the concrete slab. The third part Because we intend to move all the equipment from the trailers and concrete slab into the new building once it is constructed, providing physical or virtual collocation in the trailer or concrete slab areas would be inefficient and wasteful. The expenses of physical collocation could not possibly be justified in an area that will be put out of 3 - MFIY 13 '96 89:58W 415 974-1899 - P. 5/10 -- service in about two and one-half years; And Pacific Bell could not be expected to pay the costs of moving virtually collocated equipment and of rearranging a virtual collocator's customers' circuits to the new building. In case, however, a potential virtual collocator were willing to pay these expenses, and because of the interdependent nature of the three parts of the central office, we describe below other reasons why neither physical nor virtual collocation can be provided in the trailer or concrete slab areas. Those reasons, and the nature of the space both in the existing building and in the planned building, also prevent physical or virtual collocation in the existing building. The Five Trailers There are about 209 square feet of space disbursed through the five trailers. From this space, we could not make available 100 contiguous square feet needed for physical collocation. A more fundamental problem, which prevents either physical or virtual collocation, is that the foundation and floor in some of the trailers is unstable as a result of recent earthquakes in Southern California. The floor has been dropping and shifting, bending the MDF, causing the tbof to leak, preventing effective earthquake bracing of equipment, and preventing us from adding additional cable racks to supplement the existing racks, which we are using at full capacity. fn addition, the 4 P. 6/10 trailers were not constructed to house modern technology or to meet current safety and NEB construction standards. Moreover, because of asbestos the trailer areas have been judged "habitable if not disturbed." Clearly, we will not provide collocation in this area. The Concrete Slab There are about 350 square feet of disbursed, vacant space on the concrete slab. Again, 100 contiguous square feet are not available for physical collocation in this area, Once again, however, there is a more fundamental problem that prevents either physical or virtual collocation. Our equipment (fiber optic terminals and DSX panels) that supports DS1 and DS3 services, including potential collocated services, is located in the trailers. Thus, collocated equipment would need to be cabled to the equipment in the trailers. In addition, if the collocator wanted service that we would provide by carrying its traffic on our transmission facilities at over 56 Kbs, the collocated equipment would need to be interconnected at a point of termination near our high capacity distribution frame in the trailer area. Moreover, if the collocator wanted service that we would provide by carrying its traffic on our fiber transmission facilities, the traffic would have to go from the concrete slab to the equipment in our trailers and back to our fiber distribution frame on the concrete slab. As described above, however, the existing 5 PlQY 13 '96 09:59W 415 974-1099 - P. 7/10 - cables and cable racks in our trailer area are being used at full capacity, and we need to avoid the addition of cable racks in the trailers. Therefore, we will not install facilities on the concrete slab unless we have no alternative means of meeting traffic growth of our customers. For this reason, we have delayed our own plans to equip the vacant space, and we cannot provide physical or virtual collocation in this area. The Existing Buildinq There are about 780 square feet of vacant space in the building part of the central office. None of this space is available for physical or virtual collocation for two independent reasons, either one of which, by itself, warrants the Commission's granting of Pacific Bell's pet it ion. First, as described above concerning the concrete slab area, any collocator transmission equipment in the building would have to be cabled back to the trailers in order to interconnect with our other transmission equipment. Since we are using the cables and cable racks that are in our trailers at full capacity, we would need to add cable racks in the trailers. As a result of the earthquake, however, the trailers cannot support additional cable racks. Therefore, transmission equipment cannot be placed in the building, and neither physical nor virtual collocation in the building is feasible. 6 - MFIY 13 '96 09:59FIM 415 974-1099 I P. 8/10 Second, collocating transmission equipment in the building would be an inefficient use of this space, which Pacific Bell has reserved for switch growth and into which we intend to add switching equipment during 1994 and in subsequent years. Limiting this area to switching equipment allows efficient operations because the switching components of a central office must be connected. they are the longer the cables must be. More cable racking is then needed to support the longer cables. This adds significant expense. Moreover, having switching equipment in disparate areas of a central office forces switching personnel to move between areas to do their job. It is much more efficient to have switching personnel together in one area and transmission personnel together in another area. When the first switch is installed in a central The furtber apart office, these efficiency concerns are planned for, and space is allocated to accommodate a certain number of lines, including new lines for traffic growth. That is how Pacific Bell allocated the space in our existing building and how we are planning to allocate space in our new building. Accordingly, in our existing building the vacant space is adjacent to existing switching equipment. This arrangement efficiently provides room for growth of our existing switch. Xn our new building, we also plan to provide room for efficient growth of our existing switch by having the new switching equipment space adjacent to the switching equipment space in the existing building, with the existing 7 WRY 13 '96 09:59RM 415 974-1099 - - '. P. 9/10 wall removed,'so that we will have one large, integrated switching area. Collocating transmission equipment in the switching area of our existing building would force us to extend our placement of switching equipment into areas of our new building further away from the switching equipment in our existing building. frustrate our plans and require an inefficient and uneconomic alternative. This placement of equipment would III. CONCLUSION For all the above reasons, the Commission should grant Pacific Bell's petition for an exemption from the a MQY 13 '96 10:00FIM 415 974-1099 . ? -. P. 18/10 physical collocation requirement and a waiver of the virtual collocation requirement for our Carlsbad 12 central office. Respectfully submitted, PACIFIC BELL 140 New Montgomery St., Rm. 1522-A San Francisco, California 94105 (415) 542-7661 1275 Pennsylvania Avenue, N.W. Washington, D.C. 20004 (202) 383-6472 Its Attorney Date: March 18, 1994 9