On behalf of AT&T and CenturyLink, I hereby submit the attached Second Supplemental Declaration of Mark Israel, Daniel Rubinfeld, and Glenn Woroch (“Israel-Rubinfeld-Woroch Second Supplemental Decl.”). The Commission’s original releases of data last fall established that competitive carriers have deployed facilities-based networks in the vast majority of census blocks that contain special access demand.[1] The Commission recently released new tables, however, which for the first time provide the exact distance of each competitor’s fiber network from each unique building with special access demand (within a 1000-meter radius).[2] As the attached declaration shows, these new, more precise data show even more dramatically that the vast majority of locations with special access demand are extremely close to multiple facilities-based competitors – indeed, in most cases, within a few hundred feet.

[1] See Mark Israel, Daniel Rubinfeld, and Glenn Woroch, “White Paper: Competitive Analysis of the FCC’s Special Access Data Collection,” at 16-17 (filed Jan. 28, 2016) (“Israel-Rubinfeld-Woroch Decl.”).

[2] FCC, “FCC Special Access Data Collection Project” at 1 (circulated April 4, 2016) (“Cross-Walk Table Delivered to NORC on March 30, 2016:  The table provides the shortest distance between each filer’s fiber network and the building, though fiber networks more than 1000m from the building were not analyzed.  The table contains three fields: BuildingID, which identifies the building; filer_frn, which identifies the competitive provider’s fiber network; and DistanceToFiber_Meters, which identifies the distance in meters between the competitive provider’s fiber network and the building.”).

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