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Comment 6: The University of Oregon expressed concerns #hat: (a) the notice <br />` provisions in R-7.302-C-2 will not supply private system operators with facilities in the <br />public way sufficient notice to install facilities in a joint trench with other providers; {b) <br />private system operators should not have to meet the same notification requirements as <br />utility service providers; and (c) requested that the City Public Works Department be <br />required to provide notice of planned public improvement projects that may impact private <br />system operator facilities. <br />Findinas: In response to comment 6.(a): The notice is intended to provide other <br />utilities and license holders an opportunity to install facilities in a joint trench or to <br />coordinate work along the same street segment while not unduly interfering with the <br />provision of services to the originating provider's customers. Requiring formal notification <br />of all projects to private system operators would impose an unreasonable burden on utility <br />and telecommunication providers. City staff are in a better position to identify .individual <br />projects for which a particular private system operator may be interested in collocating <br />facilities and can provide individual notice to private system operators when a project is <br />proposed in an area where an operator has facilities or has expressed an interest in <br />placing facilities. In response to comment 6.(b): The rule as proposed recognizes that <br />private system operators should not be subject to the same notification requirements as <br />utility and telecommunication providers. Notice provisions are directed at "providers" and <br />private system operators are not included in the definition of "provider" in the rule. In <br />response to comment 6.( c): The City's Public Works Department:endeavors to provide <br />`= project notification to utility and telecommunications providers and other owners and <br />operators who may have facilities affected by public improvement or rehabilitation projects. <br />City staff are developing better documentation and tracking methods for private facilities <br />placed in the public 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 rules, other than those noted above, are necessary. <br />Exhibit C - 3 ovosiss <br />