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Comm n 6: The University of Oregon expressed concerns that: (a) the notice <br /> rovisions in -7.302-C-2 will not supply private system operators with facilities in the <br /> ublic way su icient notice to install facilities in a joint trench with other providers; (b) <br /> <br /> private syste operators should not have to meet the same notification requirements as <br /> <br /> utility service providers; and (c) requested that the City Public Works Department be <br /> equired to pr vide notice of planned public improvement projects that may impact private <br /> ystem opera r facilities. <br /> Findi In response to comment 6.(a): The notice is intended to provide other <br /> tilities and li ease holders an opportunity to install facilities in a joint trench or to <br /> oordinate w rk along the same street segment while not unduly interfering with the <br /> rovision of s ices to the originating provider's customers. Requiring formal notification <br /> fall projects private system operators would impose an unreasonable burden on utility <br /> nd telecom unication providers. City staff are in a better position to identify individual <br /> rojects for w ich a particular private system operator may be interested in collocating <br /> acilities and an provide individual notice to private system operators when a project is <br /> roposed in n area where an operator has facilities or has expressed an interest in <br /> lacing faciliti s. In response to comment 6.(b): The rule as proposed recognizes that <br /> rivate syste operators should not be subject to the same notification requirements as <br /> tility and tele ommunication providers. Notice provisions are directed at "providers" and <br /> rivate syste operators are not included in the definition of "provider" in the rule. In <br /> <br /> response to c mment 6.( c): The City's Public Works Department endeavors to provide <br /> <br /> project notific tion to utility and telecommunications providers and other owners and <br /> perators who may have facilities affected by public improvement or rehabilitation projects. <br /> ity staff are eveloping better documentation and tracking methods for private facilities <br /> laced in the ublic way to ensure consistent and timely project notification.. . <br /> Having fully responded to the comments received, I find that no revisions to the <br /> proposed rule ,other than those noted above, are necessary. <br /> Exhibit C - 3 ovo5rss <br /> <br />