[1st-mile-nm] Latest round on Santa Fe telecom ord and new fiber for Santa Fe.

[John Brown]

Having just received the latest draft of the Santa Fe Telecom Ordinance,
http://www.santafenm.gov/DocumentView.aspx?DID=5572 I have to say I am
quite concerned with the overly burdensome and expensive process that
the City wants folks to go through.

Section 16 of the document speaks to "Land Use Review...." and contains
seriously flawed language.

16(F)

We have to make application to the Land Use Dept.  The application
requires that we document what RF frequency we will be using.  Fiber
doesn't have any RF emissions.  That section should clearly separate
those that do RF with those that do not.

16(G)  

Requires that we pay a fee of $2,500 for each application to the Land
Use Dept.  

CITIZENS ALERT:  That is a fee that will be passed on to the customer.

There are typically two to three phases for a network deployment.

1. Backbone installation.  This is the CORE network being installed in
the ROW.

2. Lateral Connections.  This is when we connect fiber from the core
ring to a specific building.
Lateral connections encompass both public and private land use /
agreements.
Lateral's are typically done ONCE A CONTRACT FOR SERVICE has been
executed.

**  NOTICE **  
So 16(G) is very unclear on what happens 3 years from now when we want
to connect a building.
Do we have to go and make another $2500 application to the City??
Think, if that is a HOME we are connecting, then the cost of connecting
that home just went from $1500 (labor / equipment / construction) to
$4000 by adding this $2500 fee.  That pushes the ROI out to an
unacceptable period of time.


3. Ongoing maintenance / Ring Extensions

16(g) doesn't speak to what happens down the road.  Do we have to make
application to do a repair?
Will that cost $2500 and take the prescribed notice time?  Section 16 is
COMPLETELY silent on this matter.
What happens if we wish to extend the original ring in a direction???


Does 16(I) require that for each construction we have to go through this
15 day period.  What about emergency damage, damage because "things just
happen(tm)", etc.

Does 16(J et al) require that for each building connection (read home or
small business) a 15 day notice, the fee's ($2500 and counting) have to
be paid, the mailings to all residences and businesses, etc.

If so that would significantly impact the ability of a vendor to deliver
affordable services.

The costs for "display advertisement" is NOT CHEAP.  TO print such an ad
with a route map will cost THOUSANDS of dollars per ad per time printed.


I've taken these projected costs and placed them in our financial model.
As it stands, Santa Fe residences will pay approximately $120 MORE PER
MONTH for Fiber to the Home, than those in Albuquerque.

Albuquerque folks pay around 79 a month.   	Installation is 149.95

Santa FE will pay 199 for the same service.	Installation will be
$399


I doubt Qwest or Comcast will agree with these fees. Nor will they pay
them.


As it stands CityLink CAN NOT accept this and unless changed will NOT be
servicing Santa Fe anytime soon.

Google will have to deal with these fees and overly burdensome
requirements as well.