20160303075356.pdfFebruary 4, 2016
City of Edmonds
Planning and Development Services Department
121 5th Avenue North
Edmonds, WA 98020
Dear Planning and Development Services Department:
Please accept this letter as a request by Astound Broadband, LLC d/b/a Wave ("Wave") for a
variance to Edmonds City and Community Development Code ("ECDC") Section 18.05.010 regarding
underground requirements for the construction of telecommunications facilities. The permit request for
Wave's project has previously been filed and a copy is attached to this letter (the "Project"). This
request seeks a variance under ECDC Section 18.05.040.
Wave is seeking a variance for the Project to permit Wave to place telecommunications fiber on
existing communications poles. Wave is not seeking to construct new poles. Wave is asking for the
variance because the cost of undergrounding in order to complete the Project is excessive in light of the
benefits to be derived from aerial placement of facilities and would outweigh any perceived benefit of
underground construction. Specifically:
The undergrounding requirement would deprive Wave of rights and privileges permitted to
other utility companies providing service in the area. Astound has competitors in providing
telecommunications services in the City, including Frontier Communications and Comcast. Each
of these competitors has enjoyed the benefit of placing fiber or other communications cable on
communications poles within the City, receiving a significant cost discount in its construction
over underground facilities. installation of underground facilities for the Project will increase
the total cost of construction roughly two times over the cost of an aerial placement on existing
pole lines — making provision of services to customers unfeasible.
Approval of the variance requested does not constitute the granting of special privileges to
Wave. Wave seeks to be afforded the same aerial placement opportunities as its competitors.
The Project will also permit Wave to offer competitively priced services to businesses along the
fiber route. This marketplace activity is exactly the result intended by the Telecommunications
Act of 1996 — allowing upstart industry to compete on price and quality with entrenched
telecommunications incumbents. The variance will advance the goal of fair and equal treatment
for all providers. At such time as all of these competitors place their facilities underground,
Wave will join them in placing its facilities underground as well.
Approval of the variance would not be detrimental. The variance would not cause a loss of
property value, scenic view or use of surrounding properties. Wave will use existing
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communications poles for the Project — no new poles will be built. These poles have at least 2
cables already attached. The fiber strand that Wave proposes to use is less than one inch in
diameter, approximately three times smaller than some of the cables already present on the
poles. The addition of the Wave facilities will not be noticeable in comparison to the existing
array of cables.
4. The proposed variance is the minimum variance needed to complete the Project. Wave woulc
use existing poles. The placing of new aerial cable on existing poles will be accomplished in
much less time than underground construction. Wave estimates that traffic control and other
construction activities will take 2-3 times longer for underground construction than the
proposed aerial placement. By deferring any underground placement to a time when all
providers are required to relocate underground, the City will minimize, manage and control
disruptive construction activities — consolidating all underground construction into a single
project rather than suffer a series of separate underground projects.
The proposed variance advances the general welfare of the City's residents and business. Without
the variance requested, advanced telecommunications services required by area businesses and
provided by Wave or any other new entrant into the market (such as Gigabit Internet, Wavelength
services of 10 Gbps or more, dark fiber, and others) will be prohibitively costly . For underground
projects, Wave has seen construction costs of over one hundred thousand dollars for a single customer„
These costs make the provision of service unfeasible for the customer, even where the advanced
services are not offered by the incumbent providers.
If you have any questions or concerns, please do not hesitate to call either me at 425-896-1724 or
Jeremy Anderson, Senior Construction Manager at 425-319-0216.
Sin rely,
Byron E. Springer Jr.
Attachment (copy of permit request)