Copper Distribution
Overall
Zone 1
Zone 2
Zone 3
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41.68%
41.80%
42.46%
43.90%
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There is a trade off between investing in spare capacity and incurring operating expenses and future higher facility augmenting costs and SBC has had the economic incentive since 1989 to reach the most efficient level of spare capacity so that long run, overall costs are minimized. Because TELRIC requirements require that fills reflect SBC's actual usage and SBC's long term experience is the best indicator of the future, SBC's proposed fills are based on what SBC can really achieve operating a forward-looking efficient network. Bash Opening Decl., 10/18/02 pp. 18-37, Attachments CMB 4-12; Rebuttal Decl., 3/12/03 6-9, 17-27, 34-42; Smallwood Opening Decl., 10/18/02 pp. 4-16; Smallwood Rebuttal Decl., 3/12/03 32, 43-45, 47, 48, 53-56, 57-59, 65-68; Aron Opening Decl., 10/18/02, pp. 32-37; Aron Rebuttal Decl., 3/12/03 46-47, 55-56; Cohen Opening Decl., 10/18/03, pp. 11-12; SBC Rebuttal Brief 44-46; Tardiff Rebuttal Decl., 3/12/03, pp. 15-16, 34-37; Makarawicz Rebuttal Decl., 3/12/03, pp. 25-29; Cass Rebuttal Decl., 3/12/03 pp. 5-6 ; PreProcess Fill Tab in LoopCAT contains the achieved fills for suburban, urban, and rural wire centers and the attached worksheet calculates the statewide averages and zone averages.
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LoopCAT does not directly produce any of the achieved fill numbers presented in this document and the calculations for producing those numbers do not appear anywhere in the record.
Overall: SBC's fill is based on its embedded network data, which is the cumulative result of decades of now sunk investments based on different demand characteristics, technical limitations, regulatory incentives, etc. (Joint Applicants' Reply Comments, 2/7/03, p. 44.)
There is no basis for expecting that embedded data is a reasonable proxy for forward-looking, efficient fill. The FCC has found that fill levels as low as those in LoopCAT are inappropriate in a TELRIC analysis. (Murray Declaration, 2/7/03, ¶¶ 34-37 and 103-104.) SBC's embedded fills are not consistent with its own engineering guidelines for forward-looking plant. (Donovan/Pitkin /Turner Declaration, 2/7/03, ¶¶ 261-268.)
SBC's claim that even modest increases from its embedded fill would result in increased maintenance expenses is contradicted by SBC's own actual forward-looking engineering practices (Donovan/Pitkin /Turner Declaration, 2/7/03, ¶¶ 409-413), by its own LoopCAT results (id., ¶¶ 428-430), and by the data it attempts to rely on to make that claim (id., ¶¶ 418-420). SBC's practice shows it is striving to increase fill (id., ¶¶ 261-268 and 409-411), but that its embedded plant is dominated by routes SBC built with inefficiently large levels of excess capacity. (Id., ¶¶ 423-427.)
SBC further understates fill by assuming a substantially lower level of 2nd line deployment in LoopCAT than occurs in its actual network. (Id.. ¶¶ 162-164.)
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Fiber Feeder
Overall
Zone 1
Zone 2
Zone 3
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16.22%
14.81%
17.36%
20.11%
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See above summary of position and citations
Calculation (as defined in LoopCAT, TAB Fiber_Cable_Unit_invt, column J) = DLC Chassis fill* Active fiber strand percentage DLC Chassis fill from PreProcess Fill Tab in LoopCAT Active Fiber strand percentage from User_Input Tab in LoopCAT (line 23)
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SBC's calculation of fiber feeder fill in LoopCAT incorrectly determines the percent of active fiber strands serving a DLC system. This error significantly overstates fiber costs. (Donovan/Pitkin/Turner Declaration, 2/7/03, ¶¶ 370-371.)
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Copper Feeder
Overall
Zone 1
Zone 2
Zone 3
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66.20%
64.95%
68.67%
71.42%
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See above summary of position and citations
PreProcess Fill Tab in LoopCat
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SBC's reliance on embedded fill factors for copper feeder ensures that its fill estimate does not reflect an efficient level because SBC counts the very low fill on old copper facilities where SBC has subsequently overlaid its old network with fiber plant. For example, SBC's extensive Project Pronto program calls for SBC to place duplicate facilities, all of which are included in LoopCAT. (Donovan/Pitkin/Turner Declaration, 2/7/03, ¶¶ 141-156.) The LoopCAT copper feeder calculations are not consistent with SBC's own guidelines (id., ¶¶ 154 and 269-273.)
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DLC Equipment
1) Hard-Wired Equipment
Overall
Zone 1
Zone 2
Zone 3
2) Plug-In Equipment
Overall
Zone 1
Zone 2
Zone 3
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47.40%
43.40%
50.72%
58.76%
53.10%
48.87%
56.66%
65.93%
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See above summary of position and citations
PreProcess Fill Tab in LoopCAT
See above summary of position and citation
PreProcess Fill Tab in LoopCAT
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See above summary of positions and citations for Feeder.
Hard-wired equipment: SBC's DLC Hard-Wired Equipment (a.k.a., "Common Equipment") fill in LoopCAT is much lower than fills currently set for SBC by other state regulators. (Donovan/Pitkin/Turner Declaration, 2/7/03, ¶ 348.) As noted above, SBC is placing new "overlay" fiber and DLC facilities on top of its older copper plant but is only gradually moving customers from all copper loops to those new facilities. Thus, use of these historic DLC fill levels in a forward-looking cost study is particularly inappropriate.
Plug-in equipment: SBC's LoopCat assumptions are inconsistent with its own engineering guidelines. Because plug-ins have a relatively small capacity and are placed on an as needed basis it is reasonable to achieve much higher fill. (Donovan/Pitkin/Turner Declaration, 2/7/03, ¶¶ 350-352.)
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SAIs/FDIs
Overall
Zone 1
Zone 2
Zone 3
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47.20%
46.46%
47.92%
50.94%
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See above summary of position and citations
Computed using 2/3 distribution fill, 1/3 feeder fill
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SBC's approach of applying its distribution fill factors to the number of FDI terminations effectively double-counts the spare terminations required at the FDI. This occurs because SBC already applies an effective fill adjustment by assuming three terminations per loop when it initially sizes the FDI in LoopCAT. (Donovan/Pitkin/Turner Declaration, 2/7/03, ¶ 289-298.)
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Premises Termination
1) Business
Overall
Zone 1
Zone 2
Zone 3
2) Residence
Overall
Zone 1
Zone 2
Zone 3
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45.60%
46.94%
43.73%
41.16%
17.58%
17.81%
17.72%
17.80%
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See above summary of position and citations
Yearly_Input Tab in LoopCAT
See Above summary of position and citations
PreProcess Fill Tab in LoopCAT
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SBC's business premises termination fill relies on lines per business rather than considering the actual number of business locations, which is incorrect because many businesses can be located in the same building. (Donovan/Pitkin/Turner Declaration, 2/7/03, ¶¶ 230-232.)
SBC's residential premises termination fill is incorrect because it understates the level of 2nd line penetration, improperly models high density terminations in multiple dwelling units, and ignores the existence of smaller 2-pair NID sizes, which SBC actually deploys. (Donovan/Pitkin/Turner Declaration, 2/7/03, ¶¶ 198-201and 222-233.)
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